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Frequently asked questions - Part 43
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- Will CASA produce a plain English guide for Part 43 as they are doing for Part 91
Yes, that is the intent. We also like plain English.
- What insurance will be required for IAs and LAMEs working under Part 43?
While CASA does not provide advice on insurance requirements we are aware that this is an area of concern and interest to LAMEs working independently outside of an AMO/CAR 30. IAs and LAMEs will need to evaluate their own circumstances, business model and work arrangements, consulting with employers and insurance companies to determine the amount and type of cover required.
- As Part 142 operators are required to have a certificate, will this prevent a Part 142 aircraft being maintained under Part 43?
No. It is still treated as aerial work for the purpose of maintenance requirements.
- Currently a Class A aircraft operating commercially requires a MC and MCM. Under Part 43 a MC and MCM will not be required and the responsibilities of a MC will rest solely with the registered 0perator. Will there be requirement written into other parts of legislation such as Part 138 for a HAAMC or other title?
Yes, large aircraft and multi-engine turbine powered aircraft will need to have an approved inspection program. One of the requirements is that the inspection program must name the person responsible for ensuring compliance with the schedule.
- Will operations such as Royal Flying Doctor Service, Care flight, Air Ambulance etc be maintained under Part 43?
Continuing airworthiness requirements for Part 135 operations are currently under consideration.
- If an operator—holder of a Part 133 certificate—has a fleet of R22s (for example three aircraft) – used solely for mustering, and an R44 used for charter, is the operator required to send all machines to a Part 145 maintenance organisation, or can the R22s be maintained under the proposed Part 43 with the R44 maintained by a Part 145 maintenance organisation?
Only the R44 would be required to be maintained as a charter aircraft, the mustering-only aircraft could be maintained under Part 43.
- Large aeroplanes or multi-engine turbine powered aeroplanes will need an approved CASA inspection program. Will this be similar format to a SOM?
A SOM specifies maintenance requirements in addition to inspection requirements. Part 43 only specifies inspection schedules for the periodic inspections. However, a current SOM will meet or exceed the requirements in Part 43.
- If an aircraft is currently maintained to a SOM, how will this transition to Part 43?
Existing SOMs will be preserved under Part 43. No further application will be required to be made to CASA.
- What part of the CASR regulations will the Aircraft Inspection Program be approved under?
Future SOMs or other approved forms of inspection programs/schedules will be approved under a provision which will be incorporated into CASR Part 43 (derived from FAR 91.409).
- Will Industry Delegates be able to approve a SOM and inspection program for a Part 43 aircraft?
Yes. Provision will be made in the new CASR regulations.
- For an Air Tractor aeroplane or an AS350 Helicopter that has a 150-hour SOM or manufactures maintenance schedule, will this need to be reduced to 100 hours as per FAR 91.409?
No, we will preserve existing SOMs and the manufacturer’s maintenance schedule, with its inspection intervals is always accepted. FAR 91.409(c) 3 and 4 refer.
- Will the manufacturers’ maintenance schedule be pre-approved by CASA?
Yes, as it is now. The words used in the regulations are “acceptable to CASA”.
- When referring to major repairs and modifications to propellers or instruments, does this include overhaul?
Yes, an overhaul of a propeller is a major repair. Major repairs and modifications to a propeller must be carried out by an approved maintenance organisation (AMO). Repairs to instruments may be carried out by an AMO or an independent B2 LAME.
- When an aircraft has a progressive maintenance schedule, does the authorised inspector (IA) release the aircraft at the start/end of the progressive cycle, or after each stage of the progressive cycle?
At each stage – FAR 91.409 (d)(1) states that an inspection authorisation (IA) holder must supervise or perform the progressive inspection. CASA will adopt this requirement unchanged.
- Do the MM and ICA inspections need to be carried out in the timeframe recommended by the MM ICA, even on a private helicopter?
Not unless the registered operator elects to use the manufacturer’s schedule or is directed to do so by CASA.
- For VFR only aircraft will there be a need to test transponder /altimeters etc? Under 91.413 a VFR aircraft doesn’t need the transponder test/inspection carried out unless they intend to fly in controlled airspace and the test must be carried out within the previous 24 months to the flight?
That is correct, an aircraft that operates under VFR only and remains outside airspace for which a transponder is required to be carried will not be required to have the tests carried out. Any aircraft that flies under IFR or in airspace for which a transponder is required to be carried must have had the tests completed within the immediately preceding 24 months.
- The guidance material states AD/ENG/5 will remain unchanged in the short term. What will happen in relation to PT6A turbine engines in Air Tractors in relation to AD/ENG/5 Appendix B and on-condition engines?
Under 91.403 and 91.409 the RO is required to comply with approved life limitations. This means airworthiness limitations (AWL) and airworthiness directives (AD). AD/ENG/5 allows for certain turbine engines to be operated beyond Manufacturer’s TBO. This is acceptable policy for non-commercial aircraft under Part 43.
- After a repair or alteration, what are the W&B change record requirements?
The FAR just requires the RO to keep the records and update the flight manual or placarded loading system as required.
- Will the FAA form 337 concept be introduced?
No. In general terms, the Form 337 duplicates logbook certifications that are required under existing and proposed regulations, therefore its contribution to safety is considered to be minimal in comparison to the additional red tape impositions that would accompany a Form 337 requirement.
- Will AD/PROP/1 remain applicable?
The future of generic ADs is outside the scope of this project however CASA may consider removing the ADS in Part 43 maintenance.
- Can appliances manufactured after the 1980s be overhauled by a B1 LAME?
Under part 43, a B1 LAME may overhaul appliances and components for Pt 43 aircraft, excluding turbine engines, propellers and instruments, provided they have current data, tooling and appropriate facilities.
- The definitions of major and minor, that apply to Part 21 M, are different to the definitions used in Part 43. Will CASA be using standard definitions for these terms?
No. The definitions used in Pt 21 relate to the effect a change (design) may have on the aircraft or product type design. The definitions for major repairs or alterations used in Pt 43 relate to the type of change/repair being made to the system or aircraft.
- When carrying out maintenance on a part 43 aircraft in a CAR 30, does the LAME sign for and on behalf of the CAR 30 or on their own licence?
The LAME signs for and on behalf of the CAR 30 or Pt 145 organisation, provided the AMO is authorised to carry out the maintenance.
- What documentation for a part or component will be required to fit a part to a Pt 43 aircraft, including parts bought from distributers, parts bought from another Pt 43 or parts which have had maintenance performed on them under Pt 43?
Pt 43.13 requires “the use of materials of such quality that the aircraft worked on will be at least equal to its original or properly altered condition”. The LAME will need to ensure any part or material meets the specifications and has the traceability that demonstrates the part or material is equivalent to that used in the manufacture of the part or material. Evidence could include a Form 1, Serviceability tag, Component history record, component logbook, ect.
NOTE - components and appliances maintained under part 43 (i.e.by an independent LAME) are not eligible for a CASA Form 1.
- Will CASA have a method for sharing with industry what is and is not considered acceptable data?
An information sheet providing a list of acceptable data will be published, however it will be indicative only. The term “acceptable data” means any data that can be demonstrated as meeting the applicable airworthiness and regulatory requirements. For example, if a person uses a generic design to install a GoPro camera in or on the aircraft, the data would be acceptable if it can be shown that the installation did not have an adverse effect on the structural reliability or aerodynamic characteristics of the aircraft.
- What checks and balances will the regulator have in place to verify compliance if there is no entry control and ongoing auditing?
CASA is considering strategies for oversight of aircraft airworthiness and maintenance personnel under Pt 43. The oversight strategy will include ramp checks of aircraft and other random product type audits. CASA will retain the ability to audit a maintainer or maintenance company, however this will not be on a scheduled basis. In the absence of an AMO, CASA will rely upon the IA as the competent person in the system for determining airworthiness compliance.
- Will CAR 30 or Pt 145 AMOs need an IA for annual inspections?
No. The Part 145 AMO has approved processes for appointing people to carry out or supervise inspections. Similarly, a CAR 30 is required to have an appointed person qualified for the tasks, therefore no IA required.
- What is the pathway to move from CASA Schedule 5 to Part 43?
Schedule 5 will not exist in Part 43 however it could be used as the inspection checklist to comply with the annual inspection requirements.
- How will it be determined if an aircraft is using Part 43? Is it by the logbook statement?
Yes. That will be appropriate. Also, by the operational category being private ops or aerial work.
- CASA has previously stated at the general aviation maintenance industry briefings that “Instrument major repair/modification may also be carried out by B2 LAME”. Does the B2 LAME need to be an approved AMO?
No. The intent is to allow flexibility. A competent and licenced person using the performance rules under 43.13 (appropriate tools, facilities, data, equipment) can perform this maintenance and certify in a logbook entry the work performed.
- The guidance material refers to the authorised inspector (IA) carrying out or supervising the annual inspection. Is the IA required to physically conduct the annual inspection or major repair, or can a LAME certify for the physical inspection and major repair and the AI reviews the work carried out and then releases the aircraft to service?
Yes, this would be an acceptable means of compliance under Part 43.
- What are the responsibilities of an IA besides conducting the aircraft annual inspection? For example, what is required in an airworthiness review?
There is no airworthiness review, in the sense of Part 42, in Part 43. The IA does the annual release to service and conformity of major mods/repairs. The annual inspection combines a physical inspection of the aircraft and a documentation review, both of which are intended to determine the aircraft remains both airworthy and in conformity with its type certification as properly altered.
- How will a Part 145 release a Part 43 aircraft? Does the AMO need to follow procedures outlined in the Part 43 or Part 145 etc? Will the Part 145 still need an IA?
No, the Part 145 AMO will follow its procedures and an IA is not required, however the AMO will need to have a procedure for ensuring that the organisation is able to comply with the Part 43 requirements.
- What is the proposed inspection authorisation (IA) initial transition process?
CASA intends to provide an on-line course for IA applicants. Applicants who pass the examination and meet the licence and experience requirements will be issued with the IA. Applicants who hold an authorisation to issue certificates of airworthiness will not be required to pass an examination.
- FAR part 65.93 requires the IA holder in March of an odd year to present evidence they still meet currency requirements. Is CASA going to follow the same regulation/principle or not specify a fixed month and year?
No, CASA will issue an IA for two years from date of issue.
- Will defects found during the annual be listed in the logbook entry as well as given in a list to the RO?
- The IA guide says that, “if the aircraft is found to be in an unairworthy condition, an entry will be made in the maintenance records that the inspection was completed and a list of unairworthy items (discrepancy list) was provided to the owner”. The IA will only approve the aircraft for return to service if it is airworthy. If it is approved for return to service and is accompanied by a list of defects that are not required by the aircraft certification basis, then it is at the discretion of the RO whether or not they have the defects rectified or leave the inoperable equipment placarded.
If the aircraft is not approved for release to service, the IA will give the RO a list which includes those defects that must be rectified. The list will be signed and dated by the disapproving IA which will not allow for forgery. The LAME to whom the operator takes the aircraft for rectification will be alerted by the logbook entry that the aircraft was disapproved and that a list exists. If the LAME has any doubts, he or she can always contact the IA for clarification.
- What happens if limited numbers of LAMEs become IAs?
CASA intends to make the training and online exam requirements for becoming an IA as minimum burden to the industry as possible. During the transition period, existing AMOs (145’s and CAR 30) will continue to be able to release Pt 43 aircraft to service.
- As the IA will be required to ensure an aircraft meets type design, as properly altered, will CASA consider making all TCDSs available on the CASA website, as many are very hard to find?
No. The IA will be responsible for sourcing the data required to complete the annual inspection, including data to confirm compliance with type design and any modifications or repairs.
- If an aircraft is on a manufacturer’s system of maintenance will there be a need for an IA B1, B2 for major mods and repairs?
Yes, if the mod or repair is done outside an AMO. The requirement for needing the IA for conformity inspection of major mods, major repairs is regardless of the inspection program, SOM, inspection checklist that is used.
- If an aircraft is on a manufacturer’s system of maintenance, will there be a need for an IA to ensure conformity to type design, annual inspection or progressive inspection schedules?
Yes, for small aircraft (below 5700kg) maintained outside an AMO, the IA will be needed each 12 months for inspection of the aircraft against its type design and properly modified state. This is a key policy of the Part 43 system when there is no AMO performing the periodic inspections.
- Will IA’s be considered CASA delegates and therefore be covered under CAAP admin 1 noting that ATO’s became Flight Examiners under Part 61 and stayed covered under CAAP Admin 1 after some debate.
No. The IA is a LAME authorisation for making airworthiness determinations on small aircraft. They are not acting on behalf of CASA.
- Can an IA sign off an annual inspection if defects found during the annual have not been rectified?
Basically, there are two outcomes from the IA “sign off” of the annual inspection as being completed – it’s either AIRWORTHY or its UNAIRWORTHY. All the FAA guidance and FAR 43.11 (a)(5) are clear on this. The IA is required to give the RO a list of discrepancies if he/she determines that the aircraft is unairworthy and NOT approved for return to service. However, although not approved for return to service, the annual inspection has been COMPLETED with a statement in the aircraft records to say so. This is a new concept for our industry where we currently do not certify for completing the inspection until all the airworthiness defects are rectified.
- I currently hold a B1.1 and am not permitted to perform maintenance on a C150, will this change under Part 43?
Yes, but only for carrying out maintenance under Part 43. For more information, please refer to the Working as a B1 LAME under Part 43 information sheet.
- Under Part 43 will there be legislation that an equivalent to a CAR42ZC (6) approval to carry out maintenance will be issued by CASA?
Yes. The FARs make provision for a repairman certificate to be issued for a person other than an A&P mechanic to carry out maintenance. Under current regulation we call this a “Maintenance Authority” but in the Part 43 proposed policy we intend to issue these individuals with an AMT certificate to replace and be equivalent to CAR 42ZC(6) approvals.
- What will be required as evidence of “satisfactorily completed” a task for gaining license certification privileges?
Various methods of recording tasks could be used. Extracts, copies from Logbooks, task cards and worksheets will be considered. As well, a log kept by the LAME and signed by a supervisor will be acceptable evidence.
- Can a licensed aircraft maintenance aircraft (LAME) be held responsible for another LAME’s work if they have deemed competent at a particular task and later found not to be competent or they have made an error when carrying out that task?
No. A LAME should not be held responsible for another LAMEs return to service or certification of maintenance (signature).
- Can a copy of a work card or similar be used as proof of competency if it shows a LAME undertook the task in the role of an AME? Note this takes away any ability for the LAME who certified the task to verify competency and they may not have regarded the person signing as the AME as competent.
The LAME should make a statement to the effect the “AME” has satisfactorily completed the task. (we don’t want LAMEs to be required to make a competency determination). If a LAME has countersigned work by an AME, that would be acceptable evidence that the work was satisfactorily completed. If the supervising LAME was not satisfied with the work, he or she should not have signed off the task card. This will become more relevant under Part 43 and if an AME does an unsatisfactory job, the supervising LAME should put a line through the AMEs entry on the work sheet or task card to prevent it being used inappropriately at some later date.
- What is a qualified welder and how is a minor weld repair released to service as an IA is the only person who can release to service a major weld repair?
A LAME who releases a welded repair to service will be required to ensure that the work has been completed to an accepted industry standard. CASA will specify that an “accepted industry standard” means the standard that would be expected if the welding (or any other specialised work) were carried out by a trained and qualified person. CASA will state in guidance material that use of an aerospace welding qualified person is an acceptable means of compliance but not the sole means.
- Is it correct that Part 43 Appendix A sub-section C may remove the requirement to issue CAR42ZC(6) approvals Robinson Helicopters 50 hourly inspections and turbine engine desalination and power recovery washes for private/aerial work/flight training operations? If so, would it be the responsibility of the pilot to maintain a record of training and record that permission has been granted by the RO?
- That is correct. We will ensure that all pilot maintenance tasks for which CASA is required to issue an authorisation (and where such authorisations do not add value or safety), will be listed in the additional pilot maintenance privileges. It will be the ROs responsibility to ensure the pilot is trained and authorised by the RO to perform the maintenance. The pilot should also keep records of training and the ROs authorisation.
- Will pilot maintenance currently allowed under Schedule 8 remain valid for private and aerial work?
- Yes, the list will be more expansive than the current provisions. It will include all the preventive maintenance tasks listed in Appendix A to FAR Part 43, any additional tasks listed in Schedule 8 and a range of tasks that currently require CASA approval such as PWC PT6 compressor washes and R22 and R44 50-hour inspections.
- What will happen to CAR42ZC(6) approvals that have been issued (pilot related) as they currently allow for pilots to conduct specified maintenance in private, aerial work and charter?
proposal includes a provision for a listing of additional maintenance that pilots will be permitted to carry out if trained in the task and authorised to carry it out by the registered operator.