How would you respond to this?

[Tommy]

The following is a short exerpt from this month's Australian Mooney Pilots Associations' newsletter. In short, CASA (Australian equivalent of FAA) has put out a proposed AD for compulsory prop / hub inspection every 6 years (without actually stipulating what standard is required, thus making pricing extremely difficult for the prop shop). The AMPA is encouraging its members to send in a well-written courteous letter to CASA's safety division and asking them what the f*bleep* are they thinking?

 

How would you respond to this?

 

 

 

What does the S in CASA stand for again?

John Hillard

Over Easter, there seemed to be a new crash in the paper almost every day – some GA aircraft and others that were homebuilt and ultralight. Sadly, in some of these, people were killed or badly injured. It prompted me to think back to the content of the CASA Safety Seminar that I attended last year. Most of the agenda was devoted to stuff like the new licensing regulations and ageing aircraft. Each topic seemed to start with a motherhood statement that whatever CASA was doing was going to "enhance safety" but then didn’t really go on to explain exactly how. I’ve not looked at the detail of them, but I’d be very surprised if any of those accidents over Easter could have been attributed to the pilot not yet having received their new Part 61 licence, or to a structural failure of an older aircraft. Once the ATSB reports come out, I’d bet money that the major factor in most of those accidents will be human error in its various forms. How can I predict this? Well, CASA and ATSB’s own reports show that the vast majority of accidents involving GA aircraft occur due to pilot decision-making or aircraft handling errors of one form or another.

So, what are CASA’s priorities? If we look at the Part 61 licencing project, it is hard to see any safety benefit in it. From my own point of view, I have a type rating on one twin engined aircraft (a Piper Seneca) yet, apparently, I’m now licensed to fly most single-pilot light twins that don’t have turbine engines. CASA then go to great lengths to explain why I should not just jump in a Chieftain and go, even though they are also saying that my licence permits it. The justification for this whole exercise seems to have been lost somewhere along the way, but the most likely reason appears to be "standardisation". So, if you looked at this aspect of CASA’s current focus, you’d think that you were dealing with the Civil Aviation Standardisation Authority as it is not obvious what the whole exercise does to "enhance safety".

Let’s now turn to the other item that gets top billing in CASA’s safety seminars – Ageing Aircraft. Given the high priority it gets, you’d think that age of the aircraft would be cited as a major factor in lots of accidents. So, let’s look at the evidence. ATSB published a report in June 2010 entitled "Improving the odds: Trends in fatal and non-fatal accidents in private flying operations" (Aviation Research and Analysis Report – AR-2008-045). This report is an excellent analysis of the causes of fatal and non-fatal accidents in private aviation over the decade 1999-2008 and, perhaps more importantly, gives advice to pilots on what they should do to avoid becoming a statistic. While it must have been a contributing factor in some of these accidents, mechanical failure (airframe or engine) was clearly not a major factor in most accidents and there is no mention of the age of the aircraft having any significance whatsoever. To get any better data on this, we have to look to the annual report published by the AOPA Air Safety Institute in the USA. The latest report indicates that "Mechanical or Maintenance related" causes were cited in 13% of GA accidents in the USA in 2011 of which 38% were "power plant" related. The report does not identify what proportion of the "Mechanical or Maintenance related" failures were attributable to the age of the failed part as opposed to failures caused by maintenance errors (e.g. mechanics improperly performing maintenance) or deferred maintenance (i.e. where the need for maintenance was identified by not done).

Whichever way you cut it, structural or mechanical failures are a relatively minor cause of aviation accidents and there is no evidence at all that the age of the aircraft has any bearing on the likelihood of being involved in such an accident.

So, why have CASA embarked on the Ageing Aircraft crusade and its various offshoots - and how have they justified it? If you ask "why", the answer you will get is that they were acting on an instruction in the 2009 White Paper on National Aviation Policy. In that 246 page document, the main reference to ageing aircraft is: Page 11

Ageing aircraft

Ageing technology, particularly ageing aircraft, is an increasing feature of the Australian aviation environment. This is largely an issue for small and medium sized operators who find it difficult to upgrade their equipment. In addition, discontinuance of production of a number of aircraft types has reduced the global availability of new aircraft for low capacity passenger transport.

Older aircraft are not necessarily a risk to safety in itself but an ageing fleet has clear safety implications for both industry and regulators. CASA will increase its focus on this issue and has advised Australia’s regional airline sector that it will be giving particular attention to the adequacy of the ageing fleet’s airworthiness programs. As Australia is not alone in facing the challenges posed by the use of ageing equipment, CASA is liaising with counterparts in other jurisdictions to ensure best practice.

CASA will also be focusing on the small aircraft types that are not supported by either manufacturer-approved instructions for maintaining airworthiness, or guidance from the aviation safety regulatory authority of the aircraft’s state of design.

So, who do you think drafted that section of the White Paper? There is no way of knowing for sure but I’d put my money on its having come from CASA themselves. It is worthwhile quoting it full. You’ll note the assertion that "an ageing fleet has clear safety implications for both industry and regulators". From its outset in 2009, the Ageing Aircraft Management Program has been a conclusion in search of a problem. The crusade started as a presentation of a series of lurid photographs of corroded structures and broken parts that concluded that the problem was the age of the aircraft fleet in Australia. While CASA are fond of asking people in the industry to conduct root cause analysis whenever a problem is identified, it does not appear to be a discipline that they apply to themselves. The problem with the Ageing Aircraft presentations was that there was virtually no analysis to support the conclusions:

 Were the aircraft faults identified during normal annual inspections? In thatcase, the inspection process is working as intended with defects being identified and rectified before they become a threat to flight safety;

 Should those faults have been identified in previous annual inspections? If so, then the root cause might be inadequate or insufficient maintenance (i.e. cheapie annuals) and the solution should be education/enforcement action;

 Was the fault due to improper repairs and maintenance in the past? If so, then the remedy should be education/enforcement action; and

 If the fault would not have been identifiable during a normal annual inspection, was the fault likely to result in a structural failure that could have crashed the aircraft?

If such questions are posed to CASA staff, the response is usually "we don’t have the resources" to do that sort of analysis. I think that this is a complete cop out. They have data available in the form of Service Deficiency Reports and they should be conducting and publishing analyses that identify the root causes of the aircraft faults that are reported to them, and should act accordingly. If they are not prepared to do that then, given the lack of evidence that structural or mechanical failures are a major cause of accidents, then they should leave well enough alone.

If you discuss these issues with CASA airworthiness staff, they know full well that many (most?) of the "horror stories" out there are the product of inadequate maintenance rather than age alone. Such aircraft are being signed out at annuals with defects that should have been identified and rectified but are not because some owner/operators are not prepared to pay for a proper annual - and a minority of LAMEs who will oblige. If that is the case, then it is perverse to require additional SIDS inspections if the root cause is that some aircraft are not getting proper annual inspections. The net result is that the people that do proper SIDS inspections will be the same ones that already pay for proper annual inspections. The minority that get cheapie annuals will also get cheapie SIDS. The safety benefit of that "solution" is near enough to zero. Page 12

The other discipline that good regulators apply before taking regulatory action is cost:benefit analysis but there is no sign that CASA have done any such analysis of SIDS or any of their other recent airworthiness initiatives. Instead, CASA have simply launched into a program of saving private aircraft operators from ourselves. The main manifestation of this so far has been SIDS. They have mandated SIDS for Cessna aircraft and are looking forward to doing the same for other types. One can only speculate about Cessna’s motivation in encouraging CASA along this path. They have certainly been happy to send specialists to ageing aircraft conferences in Australia to spread the good word on SIDS. Maybe it is out of the goodness of their hearts, but it might also be driven by a desire to get people to retire their old aircraft in the hope that they might buy new ones. Whatever the reason, it has certainly had an impact on the value of older Cessna aircraft – even in the USA, despite SIDS not being mandatory there.

In a recent Airworthiness Bulletin, CASA say that "The Civil Aviation Authority of New Zealand has stated that up to 95% of the aircraft that have had the SIDS undertaken have reported damage being found, of which 20% could be classified as major." Well, I hear you, but I could just as well say that 80% of the SIDS inspections have identified only minor issues and, in some cases, nothing at all. Either way you cut it, that quoted percentage is meaningless unless you can answer the questions above and understand the root cause of those defects.

But the CASA crusade is not just about SIDS. They have been working (for years) on amendments to ADs for engines and propellers to require that all aircraft operators conduct additional maintenance at the manufacturers recommended calendar Time Between Overhaul (TBO) in addition to a full overhaul at the hourly TBO (typically 1500-2000 hours). In April this year, CASA published a proposed amendment 3 to "AD/PROP/1 - Propellers - Inspection and Overhaul". The main change is that all props (now including those on private aircraft) would require fairly major maintenance every six years. That maintenance can either be an overhaul or (for private aircraft) a "hub/blade inspection" that includes (for variable pitch propellers like those on our Mooneys) :

i. Dismantling of the propeller sufficiently to gain access to the blade root bearing assemblies.

ii. Thorough cleaning of the blade root assemblies in accordance with the manufacturer’s instructions.

iii. Examination for pitting, fretting, corrosion, cracking and other damage of the hub, bearings, blade roots, and housing, together with replacement of all seals and gaskets.

iv. All of the blade surfaces shall be examined for damage, delamination (where applicable), and the presence of corrosion, removing the paint finish as necessary.

v. In cases where de-icer boots are installed on the blades, a detailed examination for corrosion around their edges shall be carried out, and, if any evidence is found, the boots shall be removed to permit a full inspection of the masked areas.

vi. Removal of blade ferrules to perform a thorough inspection of the blade thread on McCauley threaded series propellers.

vii. Painting and application of protective coatings as required.

viii. Functional testing of the propeller.

ix. Balance in accordance with manufacturer requirements.

x. Incorporation of any Service Bulletins and Airworthiness Directives that may be applicable.

The estimated cost of this "hub/blade inspection" for the 3 blade prop on my Mooney is about $1600 (AUD) compared with an "overhaul" cost of $4,000 (AUD). For an owner doing 100 hours per annum, doing a hub/blade inspection every six years will cost an extra $x per flying hour and double that for someone doing 50 hours per annum. … And for what purpose? CASA say that they have been "…receiving many Defect Reports, particularly from maintenance providers, of propellers that are significantly past their recommended TBO, in some cases in excess of 25 years since the last overhaul." Well, in the words of another famous service provider, "that’s Page 13

what they would say, wouldn’t they". Again, where is the analysis? This is just more regulation by anecdote and unsubstantiated assertion.

Again, the airworthiness folks in CASA appear to be again breaking new regulatory ground in how they implement these initiatives. The amendment to the prop AD is being done by creating a PAD – Proposed Airworthiness Directive. I thought that ADs (other than emergency ones) had to proceed through a rule making process (NPRM etc.) that allows for the proposal to be amended as a result of comments received. This "Proposed AD" says that internal (i.e. within CASA) consultation took place in September 2014 and that external consultation closes on 15 June 2015 (12 June 2015 elsewhere in the document) and that owners will have to comply "within 2 years of the effective date of this PAD". If this is how the new CASA consults then I don’t see much difference from the old one. Like the "Ruling" that the CASA airworthiness folks used to implement Cessna SIDS, the Proposed AD is simply a means of bypassing the proper consultation mechanisms.

If CASA get away with this, the next cab off the rank will be a similar amendment to AD ENG/4 to require us to "inspect" our engines at the manufacturers recommended calendar TBO for engines – 12 years. That exercise has been an active project on the CASA website since 2012. The cost of this prop AD will pale into insignificance compared with having to bulk strip our engines every 12 years.

My one faint hope is that the new Director of Air Safety is an aircraft owner himself, and that maybe he’s not fully appreciated what his merry men in airworthiness are up to. So far as I know, no-one in that group actually owns an aircraft so their approach to these matters is unsullied by any concern with what it all means to the private aircraft owner. The combined effect of SIDS, ADSB-out, PBN and prop/engine inspections every 6/12 years will be make the cost of private VH aircraft ownership untenable for all but its most dedicated (and wealthy) participants. Hopefully, Mark Skidmore will have the good sense to recognise that the airworthiness initiatives that his people are proposing have no appreciable safety benefit.

Last but not least, what is CASA’s strategic objective regarding private aviation? In the not too distant past, I thought that CASA had been directed to focus their resources on protecting the fare paying public. But in the past few years we have had a swathe of initiatives emerging from the CASA airworthiness people that are primarily directed at general aviation. So, what has changed and why? To the average private aircraft owner, CASA’s behaviour in the airworthiness space is capricious and unpredictable. These bright ideas appear out of nowhere and grind their way to implementation without any proper consultation, justification or cost/benefit analysis. That is simply not good public policy.

[ryoder]

Mandatory yearly inspections by an independent psychologist and medical doctor for all government employees engaged in aviation. Mandatory job fitness testing every two years. Mandatory two years time in service before receiving any salaried benefits. Immediate termination following any failed drug test or if on any undesirable medication. Mandatory recurrent training in any area of supervision.

[yvesg]

In Canada, we have prop overhaul mandatory every ten years. It is a PIA and adds several AMU when due. It use to be every five. Our pilot association got it bumped to ten at some point.

Yves

[Shadrach]

Another piece of data that would be nice to break out is how many of the mechanical failures were induced by recent and incorrectly performed MX. I am of the opinion that a system of components that is working well and shows no signs of wear or misadjustment stands the best chance of remaining that way if human hands stay away from it. I am all for noninvasive inspection. NDT inspection, visual analysis, oil analysis etc are wonderful tools.

I am glad the U.S. does not require a mandatory OH on calendar time, but I fear it's only a matter of time until some beuraucrat decides that we need to be like our more progressive neighbors to the north and across the Atlantic...after all if the cool kids are doing it it must be the cool thing to do.

[Yetti]

Most of the O&G industry is moving to condition based maintenance from prescriptive based maintenance.   Not vice verse

[Danb]

basically the gov't,lawyers, insurance carriers at work..

[Shadrach]

Most of the O&G industry is moving to condition based maintenance from prescriptive based maintenance.   Not vice verse

I believe commercial aviation is doing the same.

[rob47v]

I believe commercial aviation is doing the same.

No commercial aviation isn't doing the same. There are time checks, limits and so forth. Nothing is on condition, unless is furnaturings. I beat Hartzell and mccauley love Canada and Australia. Countries that will make them money. Capitalism at it's best wow!!!!!

[jetdriven]

Whole engines at airlines are on condition, some of which run 25,000 hours between overhauls. 

[Shadrach]

No commercial aviation isn't doing the same. There are time checks, limits and so forth. Nothing is on condition, unless is furnaturings. I beat Hartzell and mccauley love Canada and Australia. Countries that will make them money. Capitalism at it's best wow!!!!!

 

 

I think you are mistaken. There will always be checks and analysis and even life limits on certain components. These are all good things.  However, rebuilding a perfectly good system of components for no other reason than an arbitrary time limit is silly unless it is for data collection regarding an unproven component.  

 

Your "capitalism at it's best"comment suggests that you're a true scholar of economic theory and a savvy political mind (though maybe not as well versed in grammar).   I'll avoid engaging in a discussion on such high minded matters.

[Guest]

No commercial aviation isn't doing the same. There are time checks, limits and so forth. Nothing is on condition, unless is furnaturings. I beat Hartzell and mccauley love Canada and Australia. Countries that will make them money. Capitalism at it's best wow!!!!!

No more than the FAA loves issuing ADs against propellers which haven't seen the inside of a prop shop in decades. Somewhere there is a happy median.

Personally I'd rather overhaul it before the failure, afterward its more difficult. There is a picture posted here on MS of a hub cracked in two which actually flew in to a shop for some work.

Clarence

[ryoder]

No commercial aviation isn't doing the same. There are time checks, limits and so forth. Nothing is on condition, unless is furnaturings. I beat Hartzell and mccauley love Canada and Australia. Countries that will make them money. Capitalism at it's best wow!!!!!

Grammarly.com ftw

[tony]

On condition is too expensive for the big airlines.  They try to predict the failures and schedule the maintenance before the failure.  Doesn't always work but that's their mode of operation.   

[rob47v]

First , I had no idea this was a grammar oriented forum , OMG so sorry!!! Second I work for an airline and engines, landing gears and some actuators are on time limits. Again not everything is on condition. Engines under go time checks, bore scope, and several other checks to insure its durability. I can't tell you how many engines are change do to time, but the fact are many. But also most engines are on what we call power by the hour. Guaranteed by the manufacture in such way. Last two airlines I've work for operate in such manner.    

[Guitarmaster]

No more than the FAA loves issuing ADs against propellers which haven't seen the inside of a prop shop in decades. Somewhere there is a happy median.

Personally I'd rather overhaul it before the failure, afterward its more difficult. There is a picture posted here on MS of a hub cracked in two which actually flew in to a shop for some work.

Clarence

Here you go.

Sent from my iPad using Tapatalk

[jetdriven]

First , I had no idea this was a grammar oriented forum , OMG so sorry!!! Second I work for an airline and engines, landing gears and some actuators are on time limits. Again not everything is on condition. Engines under go time checks, bore scope, and several other checks to insure its durability. I can't tell you how many engines are change do to time, but the fact are many. But also most engines are on what we call power by the hour. Guaranteed by the manufacture in such way. Last two airlines I've work for operate in such manner.

GE's power by the hour was "on condition". It takes a snapshot of every takeoff at 1500 AGL and when the trend lines started diverging, you would pull it. But not before.

[tony]

Byron, that's not really on condition.  GE has a concept called time limited dispatch.  Pratt tries but doesn't do it well.  You can release with known failures and they mathematically predict when the next failure would be based on flight history.  That way you can schedule the maintenance when you are at the maintenance facility. 

[Shadrach]

Here you go.

Sent from my iPad using Tapatalk

This crack was related to time in service or exceeding calendar life? It sure looks like it was induced by trauma . Link to the thread?

[rob47v]

GE's power by the hour was "on condition". It takes a snapshot of every takeoff at 1500 AGL and when the trend lines started diverging, you would pull it. But not before.

GE isn't the only manufacture doing this type of preactice, so is Rolls, and p&w. We do checks on engine and replace them when they reach certain time limits. Now during the duty cycle, or in other words while the engine on a specifict time cycle, if there a failure the manufacture of the engine would absorb the cost!!