Opening address - Aircraft Airworthiness & Sustainment Conference 2015
Director of Aviation Safety, Mark Skidmore
Aircraft Airworthiness & Sustainment Conference 2015
Brisbane – 21 July 2015
Thank you Richard for the introduction. I would like to welcome all of you to this conference. We are very pleased to once again be associated with and sponsor this year’s Aircraft Airworthiness and Sustainment Conference. As I understand it, this conference has become a regular event and an important contributor to the continued discussions and exchanges on the subject of optimising the management of Australia’s ageing aircraft fleet-something that remains an increasingly significant challenge as time passes.
CASA’s engagement with the aviation community forms a significant part in performing our duties as Australia’s aviation regulator. It is important that we recognise the value of maintaining a meaningful, co-operative and mutually respectful relationship with the individuals and organisations that make up the Australian aviation community.
We also need to recognise the importance of positive engagement with the aviation community to develop and implement the best possible safety standards, deliver effective safety education and get the right operational outcomes.
To that end, I believe the aviation community and CASA need to work on building a closer working relationship based on mutual interest in achieving the best safety outcomes.
Forming Safety Partnership across the industry
I feel it is important that I elaborate my thoughts a bit more on building a ‘safety partnership’ in the context of industry consultations on safety policies and standards development. We cannot do this in any effective manner without industry’s participation in, and support of, our efforts.
I believe in a regulatory approach that gives due consideration to non-regulatory alternatives such as training and education, before moving to introduce new and additional regulation.
I also believe in regulating aviation activities based on risk, taking into account the costs and benefits of regulation, and making decisions based on where CASA’s and the aviation community’s safety resources are best directed. This is an important area where we can collectively work together to ensure that we are getting the biggest safety return from our aviation safety investments.
Effective industry consultation is essential and this is why I’m standing in front of you today. Industry input is invaluable to CASA, both in terms of identifying hazards and evaluating risks, and in advising CASA of any safety issues that should be taken into account.
Therefore, building an appropriate ‘safety partnership’ based on respect and trust is fundamental to get things right in the best interests of aviation safety.
CASA’s commitment to safe operation of ageing aircraft
CASA has no major concerns regarding ageing aircraft management at the higher end of the aviation spectrum – that is Australia’s Transport Category aircraft. The maintenance programs developed for most large commercial aircraft in Australia have extensive involvement with the aircraft’s manufacturer. This also extends to the incorporation of manufacturer sponsored ageing aircraft programs and initiatives.
However, the introduction of new and exciting aircraft types and technologies in Australia will bring about new challenges and ways of doing business which we are yet to encounter. We will of course have to remain ever vigilant in our oversight and adapt accordingly to these new challenges.
On the other hand, the situation at the other end of the scale – General Aviation – is very different. General Aviation has few of the resources and manufacturer’s support arrangements enjoyed by the ‘top end of the town’.
Many General Aviation aircraft:
- are 40 or more years of age
- are being operated for decades beyond their notional design lives
- have modest or otherwise no manufacturer’s support arrangements
- were not designed with fatigue considerations in mind
- were manufactured with minimal corrosion protection in place
- receive no more than a yearly/100 hourly inspection that is generic in nature and in most cases non-intrusive .
This scenario applies to up to 10,000 aircraft of the 15,000 on the Australian Register. This represents a significant concern to CASA.
CASA’s educational effort
While CASA will always continue to monitor operations at the high end-in terms of aircraft maintenance-enhanced focus is definitely necessary on the General Aviation sector. We continue to consider a range of initiatives as to how to optimise the collective health of the VH registered fleet, starting first and foremost with safety education.
Communication and consultation on ageing initiatives and best practices will always be my preferred approach to enhancing the safety of our skies. Only where this clearly isn’t working will I need to turn to regulation.
CASA continues to provide the industry with ageing aircraft related literature, seminars, on-line and e-learning opportunities which the CASA people present at this conference will be able to provide more information.
Instructions for continuing airworthiness
CASA is also considering several options in regard to the minimum levels of maintenance that are appropriate for aircraft operated many decades beyond their originally intended use-by date.
As an aircraft ages, the nature and intrusiveness of scheduled inspections may need to increase-much the same as we humans. Generally, the older a person gets the more frequent and intrusive medical tests and procedures become to ensure the continued health and wellbeing of that person. As we well know, every person is different and has made different lifestyle and health choices during their lives (i.e. drink, smokes, level of fitness, eating your vegies etc.) – much the same way an individual aircraft has been operated, stored and maintained during its operational life.
Obviously, no two aircraft are going to age in exactly the same way, in the same way that no two humans will age (or degrade) in an identical manner.
A healthy prognosis from the Doctor-while welcomed-still takes effort and costs money (just like for aircraft). However, there is much evidence to show us that this is not occurring in relation to the General Aviation aircraft fleet.
With the legacy fleet of piston engine aircraft having an average age of 40 years, a maintenance regime that does not adapt to take into account the ageing process does not bode well for the long-term, particularly in the absence of any manufacturer’s input such as Instructions for Continued Airworthiness. Where such manufacturer’s input does exist, it should be incorporated wherever possible as is the requirement under CAR 42V.
One example of where manufacturer’s Instructions for Continued Airworthiness do exists is Cessna-known as Supplemental Inspection Documents or SIDs programs.
The SIDs programs developed by Cessna for its piston engine aircraft fleets provide an inspection regime to maintain the structural integrity of the airframe. These supplemental inspections can be more intrusive and complement those inspections undertaken during existing scheduled maintenance activities.
By mid-next year, up to 3,600 Cessna aircraft on the Australian register should have complied with the SIDs inspections.
CASA is aware that there are costs to industry in complying with the Cessna SIDs. There is a cost for basic inspections. Then there is additional cost associated with the rectification or repair of whatever damage may have been discovered as a result of undertaking the inspection. This rectification cost, which can be significant, will vary between individual aircraft depending on how well the aircraft has been maintained over its life.
By way of example, the New Zealand Civil Aviation Authority has already required the incorporation of all Cessna SIDs. CASA has received feedback from the NZ CAA indicating that up to 80% of those aircraft inspected have required remedial action of some sort. In 20% of these cases the remedial action was considered major, representing a significant threat to safety that would have otherwise have gone undetected.
To date, in Australia, CASA has received well over 130 defect reports found as a result of undertaking the SIDs inspections, with the majority of the 100 series aircraft (which make up the bulk of the Cessna fleet in Australia) yet to be initiated.
Please note that the development of the SIDs is not as a result of Cessna being in any way an inferior product to any other competitor aircraft. Ageing issues such as fatigue and corrosion damage threaten every aircraft equally. However, in this instance the Original Equipment Manufacturer (OEM) has taken steps to continue to support its products well beyond any statutory obligatory period. In this light, they are to be commended for doing so. I understand that Beechcraft are also in the process of developing SIDs for its Bonanza products – another welcome sign of an OEM standing by its products.
I want to thank you for the opportunity to open this important conference.
The feedback I get from my people is that this is an excellent forum. Please make the most of it by engaging with all CASA staff attending.
In addition, some of you may have the opportunity to engage with our Continuing Airworthiness Team at national ageing aircraft awareness workshops around the country later this year and early next year. That team will be working together with industry in reviewing the system settings around current maintenance schedules to identify more reasonable and cost effective ways to manage the continuing airworthiness of the General Aviation fleet.
Lastly, I commend you Richard, for your continued tenacity in hosting this important national conference each year to a very high professional standard at your own initiative – well done!
I look forward to working with you to achieve our common vision of safe aviation in this great nation of ours.