Hi,
In relation to the question posed by Peter as to how manufacturers recommendations (SB’s, MSB’s, SI’s and MM recommendations) can be handled on EASA reg aircraft, I too was curious and I asked my engineer. He is on the CAA technical advisory committee and is well tuned in. This flared up after the seat belt debacle once the Cessna Aging Aircraft inspections came up. The CAA came out and said because its not an Airworthiness Limitation then it is at the discretion of the operator. The caveat was you needed a reason/declaration that you didn’t feel it was necessary and you didn’t need to perform the inspection. Typically this was that most of the inspections were carried on on a proper LAMP annual anyways. This then opened the gates to engineers and owners to follow suit on other items that were recommended but not an airworthiness limitation. I don’t recommend you throw caution to the wind and ignore all recommendations but now we do have flexibility akin to part 91 n-reg. I do consider the content of all recommendations and consider them against the hrs flown/condition of the relevant part/assembly.
William
can be handled on EASA reg aircraft, I too was curious and I asked my engineer. He is on the CAA technical advisory committee and is well tuned in.
It is important to note that on condition maintenance is currently not EASA controlled, but CAA controlled, it therefore depends on the state or register / national CAA. This is also why SID inspections for example are mandatory in some countries, while in others it is not.
It was something to do with proposing a custom maintenance programme to the UK CAA. Then I read something that this was possible in theory but in practice almost nobody succeeded.
As it is national controlled you should apply for an alternative means of compliance, for example “design” specific inspection procedures, and apply for those in a maintenance program.
That is amazing news, WilliamF. Can you confirm you are speaking of G-reg or EI-reg?
you should apply for an alternative means of compliance, for example “design” specific inspection procedures, and apply for those in a maintenance program.
If that is how on-condition maintenance is implemented on European reg planes, not many owners will be doing it – because very few people will know how do draft the proposal, and it is not in the maintenance company’s interest to lose income on the supply of parts.
If that is how on-condition maintenance is implemented on European reg planes, not many owners will be doing it – because very few people will know how do draft the proposal, and it is not in the maintenance company’s interest to lose income on the supply of parts.
You are to negative here. Most maintenance shops and CAMO’s have on maintenance programs for on condition maintenance which they have available. Yes they will like you charge you for it, as with any design they have to put effort into finding an alternative which is acceptable for the national CAA.
In general, I think – especially small companies who are into aviation for more than 40 hours, because they love aviation – don’t like to see aviation becoming more and more expensive. Most would be willing to keep their customers flying and happy.
In avionics the same is true, no avionics installers would love the major changes and would try to avoid them, manufacturers also try to avoid them by making AML STC, to keep their products more affordable and be able to actually sell a product which a customers wants, not a pile of paperwork for thousends, which nobody likes.
Hi Peter,
I was referring to a G-Reg in this case as I have a uk reg aircraft and a uk based engineer. There is really no reason why a uk registered aircraft should cost drastically more to maintain than an N reg. The CS prop is the only outlier here but if you shop around that’s £1900/6 years for a 3 blader. For the hassle of the 411/413 checks, the vat issue, the trust costs I find the savings on the n reg have me scratching my head if you were sitting on the fence with regard to the registry of choice. As an aside there was a very good reason put forward that MSB’s did not apply to aircraft certified to CAR3 and not FAR23 over on the Cessna pilots association forum, that’s the sort of nugget a clever owner would want to dig into.
My engineer will do a custom made maintenance program for about £800 pounds btw.
William
Peter
Parts are not a major revenue stream for most maintenance companies as the booking in and out of these parts and the cost of keeping two separate stores eats into anything you might make.
The mark up on a £4000 radio is good but the Proffit margin on a 25 cent rubber O ring is not and the labour cost of booking the items in and out of a bonded store system is almost identical.
William, the cost of your ‘maintenance program’ created by your mechanic would have paid for my A&P to sign off annual inspections on my (n-registered) plane for the last six years.
Which is all well and good if your aircraft is on the N reg and do your own maintenance, but few people in Europe are in that situation.
That’s a lot of money for five sigbatures I think.
It depends on the detailed circumstances and who knows who and how well.
Here in the UK an IA (needed for a ICAO CofA Annual signoff) will charge c. £200 for the signoff, but only if he worked on the plane himself.
If he didn’t work on the plane, he leaves himself vulnerable to the obvious, and yes it does happen. I personally know of an IA who got banned twice, once for 6m and the 2nd time for life. It happened when the plane(s) got sold and some stuff was found which made it obvious that the work wasn’t actually done. It wasn’t his fault “morally” but he was strictly liable because he signed off something where somebody else didn’t do the work but pretended otherwise. So a signoff will never be done without a detailed inspection, which is at least 1 day’s work. Or the IA trusting the A&P who did the work, intimately.
IME, in the UK CAA G-reg world, the CAA doesn’t take action unless somebody gets killed (which tends to be helicopter fatals, because fixed wing fatals are rarely directly maintenance related so proving it is hard) but the FAA will summarily ban an IA on a substantiated discrepancy report.
But then I would not fly my own plane unless I did a post-Annual inspection, all inspection covers off… not everybody used to like that all that much 
Which is why nowadays I do the work with my A&P/IA colleague, even though just dumping the plane at some company would be less hassle.
