“Everyone” knew about a re-weighing being needed, and control surface rebalance, but this covers any paintwork.
I’m loving it!
One can see how somebody is thinking. You can see the braincells talking to each other. This is a normal process; we all suffer from it occassionally!
Continued Airworthiness is the modern-corporate-BS term for “maintenance”. This was explained at a conference I went to, where the presenter was from a firm (De Havilland?) which took over a load of old type certificates.
And a certified aircraft needs to have Instructions for Continued Airworthiness. Every component must have an ICA. Well maybe not screws; not sure where the line is drawn. That is how The System works. Reminds me of The Prisoner 
So it is completely logical that a paint job needs an ICA.
It is just BS in most scenarios, but it is completely logical BS.
For airliners, this is a design change indeed, but most of us can benefit from a concession in CS-STAN:
Standard Change CS-SC085a
EXCHANGE OF AN AIRCRAFT LIVERY PAINT AND DECORATIVE STICKER SCHEME
Purpose
This SC is for a full or partial exchange of the design of the external livery of an aircraft.
1. Applicability/Eligibility
This SC applies to aeroplanes and to rotorcraft that are not complex motor-powered aircraft, and to any ELA2 aircraft.
<…>
Furthermore, painting may be covered in the maintenance manual for the type in question.
That’s great, but who doesn’t EASA tell that straight, in a flyer with a picture of a GA plane in it?
The average mechanic might be able to read that leaflet but certainly won’t know about CS-STAN, let alone where to find it
Peter wrote:
The average mechanic might be able to read that leaflet but certainly won’t know about CS-STAN
I think it’s more likely that the average mechanic know about CS-STAN that reading a random leaflet from EASA. We have at least one CS-STAN change on our aircraft every year (e.g. battery replacement). We use mechanics from at least four companies, two of which are not part 145 and there has never even been a discussion.
The main concern is that whichever shop does the painting has got the paperwork so they can certify the work done is in accordance with the above mentioned order. Apparently some people got in trouble after they found out that some shops in the East employed paint shops which do cars for a living to do their plane work and simply signed it off only to find that it was not done according to how planes are usually painted… since then, the local CAA’s appear to be very careful with who does what particularly if foreign registered airplanes are concerned.
It also has to do with how it’s done. Quite a few of those cheap paint jobs were done with i.e. the control surfaces in place rather than having them taken off to be done properly, which may cause damage or improper sealing e.t.c.
Given that a total respray of an airplane can cost easily 30k or more, it certainly is interesting to find that some shops can offer it for 4-5k. Clearly there must be a difference in what they do which is more than just the fact that labour costs are a sight cheaper.
particularly if foreign registered airplanes are concerned.
They should be outside the local CAA’s jurisdiction, no?
Quite a few of those cheap paint jobs were done with i.e. the control surfaces in place rather than having them taken off to be done properly, which may cause damage or improper sealing e.t.c.
Sure, but this has been done quite a lot (control surfaces attached, etc). I could not understand how… A big thing is paint stripping around rivets; this can take a huge amount of time. “Threads possibly related to this one” below have good stuff in them. But I don’t think this is a regulatory issue; the CAA doesn’t care if the job is crap so long as the paperwork is right (IF paperwork is needed!).
I suspect this reg will be misapplied and will cause lots of people lots of hassle, particularly if changing maintenance companies which is where stuff tends to be picked up (same principle as changing AMEs – always suspicious 
).
Mooney_Driver wrote:
Given that a total respray of an airplane can cost easily 30k or more, it certainly is interesting to find that some shops can offer it for 4-5k. Clearly there must be a difference in what they do which is more than just the fact that labour costs are a sight cheaper.
asked google about the average salary for Switzerland and Poland. It’s respectively 78k and 20k CHF per annum
therefore If a paint job in Switzerland costs 30k than the same process with the same materials done in Poland should be what? 10K?
Bottom line is that doing something in “the east” will be a lot cheaper than in “the west” not because it’s of inferior quality but because of the above mentioned difference
Well….. Maybe this did not originate in English: “Changes to Type Certificate” are what the type certificate holder (but no one else) may request of the authority to define a changed type design. So… “Changes to a type design” are what could be undertaken by the design approval holder by Type Certificate change, or anyone else by application for an STC.
Could an “External livery change” be a change to the type design? Well… if the change is outside the approved – and defined – design of the aircraft, than yes. Otherwise, no.
If an airplane type design specifies a placard or marking, maintaining it airworthy, including replacing it if required, is not a change to the type design, unless you change what it says, which yes, would require a design approval. If you put the same words back where they are required, what you did is called “maintenance”, even if it’s after a new paint job!
If you’re introducing a corrosion initiator to an aircraft, you’re dumb, and it’s still not a change to the type design, it’s just a dumb thing to do to a plane!
If a composite airplane has specific external coating limitations, requirements, colours, than yes, repainting to the contrary would be a change to the type design, which requires approval. But, if you follow the aircraft manufacturer’s recommended practice for painting/decalling, it’s not a design change. If a colour is not specified, you can paint it any colour you like (but yes, some airplane manufacturers do specify a colour, so you di have to use that colour). That said, there is a requirement for colour contrast for registration markings, but that’s contrast, not specific colour limitation. If the airplane has adhesive film, and it corrodes underneath, the resolution of that is “maintenance”.
If you’re painting an airplane, and you have affected the static port, you have introduced a maintenance defect (unless you deliberately changed the static port – why?). A maintenance defect is not a design change, it’s just a defect which requires rectification. If you make a change which reduces the inspectability of the airplane, yes, I could argue that up to needing an STC, but why!?!, just undo the error in thinking on that, and make sure inspection and defected detection is at least as easy as it was before…
This advisory material is weak and misleading, which is unusual for EASA, they usually think things out better than that!
