Part24: Approved Maintenance schedules

[Fairy Flycatcher]

Beek vol 2: Aviation Legislation of South Africa
Airworthiness: Non-type Certified Aircraft
Part 24.

Subpart 1 : General

24.01.1 (1)This Part applies to -

(a) Amateur-built aircraft

(b) Production built aircraft

(c) Veteran aircraft

(d) Ex-military aircraft

(e) Any other ....


(2) The aircraft refered to in subregulation (1) are classified in the following sub-groups -

(a) Aeroplanes, including microlight aeroplanes

(b) Helicopters

(c) Gyroplanes and gyrogliders

(d) Gliders, including powered-assisted gliders and touring gliders

(e) Manned captive and manned free balloons

(f) Airships

(g) Unmanned aerial vehicles

(h) Hang gliders, including powerd hang gliders

(i) Paragliders, including powered paragliders and paratrike

(j) ....

Maintenance and Inspection

24.01.5 (1) The owner of a non-type certificated aircraft for which an Authority to Fly is required in terms of these regulation shall -

(a) submit to the Commissioner or, if applicable: to the organization designated for the purpose in terms of Part 149 of the CAR, 1997, as teh case may be, for approval an Approved Maintenance Schedule or similar document for the aircraft;

(b) ensure that the non-type certificated aircraft is maintained in compliance with -

(i) its Approved Maintenance Schedule of similar document; and

(ii) to the extent applicable, the requirements of Part 43;

and furthermore -

(a) take such action as is necesary to ensure the continued airworthiness of the aircraft

(2) The format and minimum requirements fo the Approved Maintenance schedule shall be as prescribed in Regulations 24.03.1

Subpart 3: Maintenance


Approved Maintenance Schedule

24.03.1 (1) A non-type certificated aircraft, classified in the sub-groups (a) to (g) of Subregulation 24.01.1(2), shall be maintained in accordance with its Approved Maintenance Schedule in such a manner that it is airworthy at the commencement of any flight.

(2) The Approved Maintenance Schedule, reffered to in subregulation (1), shall -

(a) prescribe which Approved Person(s) with the appropriate repair rating, which licensed AME(s) and which approved AMO (s) may carry out maintenance on the aircraft;

(b) specify the conditions under which maintenance shall be carried out, including the environmental conditions and equipment and tools to be used; and

(c) be in the format as prescribed in Document SA-CATS-NTCA

(3) Any non-type certificated aircraft, other than those referred to in subregulation (1) above, shall be maintained by or on behalf of its owner in such a manner that it is airworty at the commencement of any flight. Where the aircraft manufacturer or any approved authority has issued maintenance instructions or guidelines, these instructions or guidelines shall be adhered to.

[Fairy Flycatcher]

As I understand it the above regulation means that:

1. As a microlight pilot you have to have an extensive maintenance schedule which you have to adhere to.

2. All maintenance will have to be in accordance with this (if Rotax tells you to mic the cylinders at 150 hours, you have to, plus crank, plus 'approved fuel filters' plus plus plus)

3. The maintenance schedule tells you very narrowly who may do any maintenance on the aircraft, and if you need maintenance in Cape Town, but your AME is in JHB, you have a problem?

What is your opinion on these? How can we change the wording of the above law to read what we want? What is it that we want? Can we support this with fact / solid reasons?

[skybound®]

Hmmm - this one requires some deep thinking. I have chatted to quite a few people and the response is diverse. Some believe following the schedule is a great idea, others believe a waste of time and money.

I think the aim should be to find a halfway between doing what is regarded as absolutely necessary maintenance and that which is more looked upon as being ridiculous.

For instance, many will say that spark plugs change at 25 hours is an overkill, but changing your pylon at say 500 hours should be mandatory. So question is - how do you word a regulation to force only a section of a maintenance manual?

Perhaps the only answer would be for the manufacturers to produce a maintenance schedule that makes sense and to include the items that they believe is not negotiable. The only problem that I can appreciate though is that essentially this will put themselves at risk by throwing the engine manufacturers recomendations into the bin.

Jury out on this one.

[lamercyfly]

Hi Skybound.

My experience is that almost all the wing maintenance and undercarriage maintenance is quite reasonable.............

I think the main issue at stake here is the UNREASONABLE requirement of a blanket 300hour TBO.........

I believe we have the answer to that. More about that later.........

But the point I hope to be making is : Allow owners and AP's to make the call wrt TBO's.........

Concerning your point that manufacturers would be loathe to recommend changes to the rotax manual, I dissagree.

Rainbow Aircraft override the Aeros Wing manual in many ways in their own Aero- trike manual. In my opinion, if manufacturers are prepared to over-ride wing specs, then I see no problem with engine specs. (I have NO fear of an engine failure, but I am shait scared of a wing failure )

I have also had a lovely chat with Aiden at Solo Wings, and he is happy to go along with a revised engine maintenance schedule.

It is beautiful to see the way things are working out.

It just takes darn communication, and things get done. Makes me mad that it had to come to this...............

Thanks for all your input.

Regards.

[LarryMcG]

Jora agent, phil bristow, and Rainier, are in the process of re-writing the full maintenance schedule, including ratex 582, for Jora aircraft.

LM

[lamercyfly]

Thanks for that info Larry.

Rainier, are you on this forum.

Please comment?

Thanks.

[RudiGreyling]

Try this one on for size, maye it should read something in the line with...

Aircraft that want to by used as Part 96 – which deals with. Commercial Operation of Non-. Type Certificated Aircraft. should follow strict maintenance schedules to protect the general paying public that use that services.

NTCA Aircraft that does NOT form part of part 96 should not be and can be flown "On airworthy Condition" and annual inspection and recommendation from AP. i.e. if your AP feels comfortable to allow you fly for the next year then it is OK cuase you fly "On Condition" not for money, no risk to public.

[skybound®]

I still have mixed thoughts about this.

The one reason that keeps coming to back to me is that accident at Kei Mouth a few years back where it was thought that a pylon long past it's usefull life was the cause.

Now if that pylon had been replaced at it's recomended time, pilot and pax would be still with us.

My understanding was that the pilot kept looking for an AP that would sign out his aircraft in the condition it was. So leaving it totally subjective does have a risk. Whereas if the AP knows that it requires replacing at 500 hours (for example) he cannot use discretion. In this case it may have saved 2 lives.

It does however assume that the manufacturer's schedule for lifing parts is reasonable.

[lamercyfly]

Hi Sky.

I investigated that accident, so speak from experience.......

I am in favour, as stated in my previous reply, to almost all undercarriage and wing maintenance requirements.

The serious issue, which is going to floor our sport, is the Rotax engine maintenance schedule.

The fact that that windlass pylon got through an inspections......Aish!

But hopefully the future sees a better qualilfied AP, and constantly changing and growing instruction techniques, addressing Human Performance as the serious issue that it is............

Later,

[KFA]

I agree, wing and undercarriage is not negotiable. On the engine side, I think that the pilot and AP should have discretion here. Not all engines work at the same rate and will therefore age at dif times.

[DieselFan]

Hi Sky.

The serious issue, which is going to floor our sport, is the Rotax engine maintenance schedule.

Later,

I must be honest, I'm beginning to have a change of heart and think the Rotax 300hr is fine. Why? Well when a car starts leaking oil it's worked a hard life and is close to the end of it's days IMO.

My rotax started leaking or seeping, was told it's a 582 "feature" and only more pronounced as I have a "boot" under my engine which catches it nicely. I was also told even with new seals it would start to leak again. Not to mention the exhaust gaskets...

Now I don't have much exposure to 912's but I doubt they have the same issues? How many 912's leak before 300 hours? I know out of the cars I've owned not ONE leaked around the seals or exhaust side below 250 000km.

Or perhaps on the 582 not all parts are made to last as long or as good quality as others?

Just my observation.

[skybound®]

Ok - looks like some progress here.

My suggestion at this stage would be to say - airframe maintenance as per manufacturer. Seems we all agree there.

The engine side, perhaps we as a community could develop a generic, acceptable schedule for engine maintenace. Basically start of with the current schedule and with some carefull and motivated thought, delete the bits that we believe are excessive. For instance the plug replacement could come out or be changed to double the recomendation.

Also then the other parts to indicate replacement 'on condition'.

If we could have the backing from the engine suppliers, perhaps we could be successfull with such an exercise. Also thinking that the AP section of Aero Club should support it too and perhaps even be the 'applicant' of the change.

[RudiGreyling]

Ok - looks like some progress here.

My suggestion at this stage would be to say - airframe maintenance as per manufacturer. Seems we all agree there.

<SNIP>

Also then the other parts to indicate replacement 'on condition'.

<SNIP>

Hi Skybound,

Sorry I disagree, all of it should be "On Condition" including airframe, wing and engine! The Manufacturers can make recommendations, but if we NTCA are flying for own purpose (NOT PART 96 commercial) it ALL should be "on condition"

A trike that stands outside, will deteriorate quicker than one under a afdak, quicker than one in a shed, quicker than one in a fully enclosed metal hangar.

A 582 3 axis airplane on the highveld will work much harder than single seater 582 microlight trike.

Why treat the worst and the best case the same? We don't have to, we are NOT CERTIFIED or COMMERCIAL hence "on condition" with a recommendation from manufacturer. As owner pilot If you err on the very conservative you can follow recommendations 100%, If not and you look after your goodies you can inspect thoroughly and postpone replacement.

Don't change it, keep it all "on Condition"!

Kind Regards
Rudi

[skybound®]

Hi Rudi

Exactly why I said the jury was out to begin with.

There does appear to be very much a split camp on this single issue, almost to a 50/50 split. From APs, to pilots, to Aero Club reps, to non Aero Club reps - some are in favour and some against.

Question is what will be the best fit for the majority. On condition is too subjective and replacing components because time says so may not be the correct answer either. Where is the mid ground?

Thinking cap back on

[RudiGreyling]

Hi Rudi

Exactly why I said the jury was out to begin with.

There does appear to be very much a split camp on this single issue, almost to a 50/50 split. From APs, to pilots, to Aero Club reps, to non Aero Club reps - some are in favour and some against.

Question is what will be the best fit for the majority. On condition is too subjective and replacing components because time says so may not be the correct answer either. Where is the mid ground?

Thinking cap back on

Hi Skybound,

OK My thinking cap is back on, and this is what I have done in my logbook with personal inspections on Timex of critical components. How about this for a try...

Manufacturers make "Replacement" and "Major Overhaul" Recommendations for Engine, Airframe and Wing.

When that time arrives for that component or it will arrive in next years flight, get your AP to check that component out very carefully during annual, if OK allow you to fly it for the next year "On Condition" write accordingly in Logbook. If he is not happy or think it needs to be replaced within the next year he tells you so and writes the same.

i.e. Flying Wire Timex 500h: Thorough Flying wire inspection done on 500 hours, Condition Good for extension until next annual inspection.

OR

i.e. Wing Sail Timex 5 Years: Thorough wing sail inspection done, Condition good for extension until next Annual.

This will draw your attention to that component, and this will put much more responsibility on AP though. I don't know if they will sign out extending against manufacturers recommendations though...Well in the past they have done it declaring it airworthy at time of inspection no matter what the time on components, as long as they were happy. So maybe they wont have a problem with that...I'm not an AP ;-(

A BIG Problem arise in parts and areas you can't visually inspect i.e. Condition of Crank and or Engine internals. You can do a compression test but that tells you very little. Short of opening the motor and measuring tolerances how do you justify your opinion or condition?

Regards
Rudi
PS: lots of smileys added since my post can be read that I am arguing... :D and I am not, just trying to give input.