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Keeping a maintenance shop on a short leash

Silvaire wrote:

its a little odd to consider normal N-register maintenance as somehow an exception.

No, that is not at all what I said or implied. What I have seen here in Switzerland was people trying to avoid having to comply with what the FOCA or LBA told them they have to do and therefore chose an authority who does not have an abundance of inspectors around. Clearly, this is different in the US and also not a motive for most, but some tried that and gave the whole Swiss or European N-reg community a mostly undeserved bad name. If the oversight is 5000 NM away, the mice are dancing. Apart, it was not only done with N-reg but also other flags of convenience.

Peter wrote:

Are you saying that you can take a 20 year old plane to a shop, ask them to “do an Annual”, and they are automatically constrained by law to perform only the standard Annual schedule in the MM, with no replacements of e.g. worn airframe parts like control linkages?

You take your xx-year old plane to a shop, sit down, agree on paper what is to be done and for what money and make sure you are told if something turns up which goes over a certain tolerance amount you can agree to. So if the offer sais, annual €xxx to € xxx, that is what they have to keep to and if they see that something turns up which is higher, they are obliged to call and tell you if the exceedence is greater than an agreed amount.

It’s all communications. Either it works and over the years you get to know each other and trust each other or you don’t. I am very happy with my CAMO and shop, but that trust built on a by now 12 year business relationship, not a drop and forget visit.

LSZH(work) LSZF (GA base), Switzerland

All comments on this thread should probably be prefaced with “this applies to N-reg” or “this applies to EASA-reg”.

Peter wrote:

Are you saying that you can take a 20 year old plane to a shop, ask them to “do an Annual”, and they are automatically constrained by law to perform only the standard Annual schedule in the MM, with no replacements of e.g. worn airframe parts like control linkages?

Not true for N-reg. There is no legal requirement to even perform according to the schedule in the MM. That is just a manufacturer recommendation. And the age of the plane is irrelevant as far as the regulations go. Part 43.13 and 43.15 provide the performance rules for inspections. Part 43 Appendix D lists the scope and details of items to be included in an annual inspection. It is generic and the word inspect is used exclusively. That is the minimum. Anything else (such as replacement of parts) is beyond the annual inspection itself and comes under the definition of maintenance. Maintenance should always be defined, communicated, and agreed with the owner in advance. This could be as part of a work order that includes the annual inspection, or subsequent to discovery during the inspection.

Last Edited by chflyer at 25 Jan 21:29
LSZK, Switzerland

All comments on this thread should probably be prefaced with “this applies to N-reg” or “this applies to EASA-reg”.

That would assume that the shop is constrained in what work they can perform under a generic instruction like “do an Annual” according to the maintenance regime (Part 91, Part M, etc) rather than being constrained by the local law.

I think the shop is constrained by the latter, not the former.

As a starting point, consider your local law covering car repairs.

Also consider the complexity of a judge understanding Part 91 v. Part M. No way…

Also, higher up the food chain, planes are done IAW the full MM, regardless of reg. For example the TBM/KA shop I was hangared in for 10 years did the full MM on any reg.

Obviously by the time legalities come into it, things have gone badly wrong.

Maintenance should always be defined, communicated, and agreed with the owner in advance.

Of course, but so often this communication doesn’t happen. And both the shop and the customer are to blame. One could argue that the shop has way more experience

Administrator
Shoreham EGKA, United Kingdom

The conversation above perfectly illustrates why we have moved ( with a very few exceptions) to working for commercial and insurance companies and away from private owners.

@ A_and_C , I can see your motives and would do same. Would I want to have private pilots for customers ? Not really, due to certain attitudes and “characters” there towards maintenance owners and their staff. I can imagine workshop/maintenance people often smell that sort of customers which will be likely troublemakers . Same goes for motorbike customers, to a lesser degree certainly and a lot less money involved. Thing is the pilots and all mostly lack the qualification for any judgements about these workshop jobs but pretend to have the competence about criticizing their work. . . .

Vic
Last Edited by vic at 26 Jan 02:24
vic
EDME

The trick is picking the right guy for a given job, and working with him closely, so that you never have to criticize his work. @Przemek knows the guy I’ve been doing Annuals and maintenance upgrades with here most recently (in the US) and I recognize a common philosophy between them. He’s a really great guy: pretty smart, works hard & efficiently, very respecting of others and customer oriented, runs a very tight low overhead operation and as a result makes money. He works in the real world, gets things done and people like him. You couldn’t not like him.

In my experience many of the people doing work on light planes do it because they love it. As a result they have studied it a lot and know things worth knowing. In the FAA A&P environment that might also mean they’ve evolved into making a good living elsewhere and planes are just for fun, getting involved with planes they like, and with people who respect them for what they can do. But that’s certainly not true for all of them so regardless of their business setup the process starts with avoiding half-smart pompous blowhards whose professional expertise is actually in sales, promotion and manipulation and who should be selling used cars instead. They’re out there at all levels and in all areas, looking for unwary, brainwashed Cirrus drivers and the like

I’ve never had a problem with any mechanic that’s ever helped me on my plane. Anybody who got anywhere near it has been good, I’ve learned from all of them and after over 20 years of maintaining my planes I’d call any of them a friend. There are probably a lot of others who wouldn’t like me or whatever acumen I may have developed one bit. I couldn’t care less about them.

Last Edited by Silvaire at 26 Jan 04:07

The conversation above perfectly illustrates why we have moved ( with a very few exceptions) to working for commercial and insurance companies and away from private owners.

Can one have a viable general maintenance and avionics business from insurance payouts? Airframe repairs, for sure.

I guess “commercial” means flying schools. IME, these often do minimal maintenance but yes, you get regular customers.

As noted above, the biggest issues are not in regular business but in cases where the plane is brought to a new shop for the first time. And often what will obviously be the only time – evident from the distance the customer has travelled. That Beech 18 example from the US, referenced earlier, was exactly such a case. A number of European cases were also all in that category. I can repeat this bit only so many times

Administrator
Shoreham EGKA, United Kingdom

chflyer wrote:

Maintenance should always be defined, communicated, and agreed with the owner in advance.

I mentioned this upthread, but the BGA tells owners (and reiterates it to inspectors on glider inspector courses. Glider maintainers are part-66. While this is UK, the rules are retained EU law):

Inspectors can be professional, or volunteers. Owners must establish via a BGA Maintenance work order what work they need before works starts (this is a legal requirement).

Note: This is a legal requirement!

A “BGA work order” is nothing special and not specific to gliding, it’s a form that the BGA has on its website. So I don’t understand how maintenance shops are getting away with doing all sorts of work without the owner’s knowledge since for part 21 aircraft a work order from the owner is required (at least under part ML, which again in the UK is retained EU law). The requirement for a signed work order is drummed into part 66 insperctors by the BGA on every refresher course. So for instance, when we do our annual maintenance, if I find for example the radio has gone kaput I can’t simply replace it. I have to have a work order to do it (and the owner may just opt to fly without a radio instead of having it replaced). Even if it’s something more serious, like a frayed rudder cable, I can’t touch it until I have a work order. Of course the glider is not going to be signed off as airworthy without that piece of work being done, but the owner MUST be aware ahead of time of what work is needed before it actually gets done.

I suppose one could sign a work order “Perform annual inspection and all maintenance required” or something like that, but you’d think the owner would realise while writing that out that they are writing a blank cheque for the maintenance organisation to fill in!

Last Edited by alioth at 26 Jan 10:08
Andreas IOM

The Annual and the ARC are quite distinct things in Europe. In effect, the Annual is a 100 hr service that you have to do at least once a year. So if the aircraft flies more than 100 hrs/year there is no Annual.

The ARC is an administrative thing. A new ARC is issued every year (every third year if the aircraft is under CAO/CAMO). The person issuing the ARC verifies that all paperwork is in order – in particular that the maintenance programme has been complied with (including e.g. that an Annual has been done if required). There is also a quite cursory inspection of the aircraft to check that e.g. all placards are in place and there are no obvious airworthiness defects.

That seems clear and logical @Airborne_Again and others have told me the same. Yet I read on page 5 of the ‘Annex VI to ED Decision 2020/002/R regarding the AMC & GM to Annex Vb (Part ML) to Commision Regulation (EU) No 1321/2014’ that an ARC may be issued:

By a maintenance organisation***
or independent certifying staff*** or by the CAMO/CAO(-CAM) (if contracted) or by the competent authority
: A CAMO/CAO(-CAM) is not required but the owner may decide to contract a CAMO/CAO(-CAM). *: in the limit of their privileges
*: together with the 100-h/annual inspection

So if I do not contract the services of a CAMO, the ARC can only be issued concurrently with a 100 h-/annual inspection, which is a problem if one flies 150 hrs a year, no?

EDIT: the EASA text does not copy as I intend, the last line should have three ‘stars’ and refer to the three stars above..

Last Edited by aart at 29 Jan 19:10
Private field, Mallorca, Spain

aart wrote:

So if I do not contract the services of a CAMO, the ARC can only be issued concurrently with a 100 h-/annual inspection, which is a problem if one flies 150 hrs a year, no?

The text you refer to is from a GM that summarises the various requirements. “Contract” in this context mean a contract to maintain the continuing airworthiness of the aircraft. Ref. ML.A.201(f). A CAMO/CAO can issue an ARC even if you don’t have a contract and then AFAIU it doesn’t have to be aligned with any 100 hr/annual inspections. Also, a Competent Authority can issue an ARC at any time. Ref. ML.A.901(b)(1) and (2).

Last Edited by Airborne_Again at 30 Jan 07:11
ESKC (Uppsala/Sundbro), Sweden
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