Blog posts tagged in Maintenance

Steve Bentley MD of SAS (www.sassofia.com) discusses the various areas where the Maintenance Planning Process was able to become a precursor contributing to potential maintenance.

EASA commissioned a “Study on the need of a common worksheet/work card system” to evaluate the impact of maintenance documentation on the Human Factor concern.

(Specifications N°: EASA/2006/OP/25 On demand of the European Aviation Safety Agency (EASA), BUREAU VERITAS conducted a “Study on the need of a common worksheet/work card system” from January to November 2007. The present document presents the results of this study.)

The study aimed at providing further insights on the use of documentation, the common practices in place between operators and maintenance organisations and to assess whether current rules and practices may still contribute to incidents/accidents.

Among other results, the study produced a list of incidents/accidents related to the use of maintenance documentation.

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Introduction

Whilst currently (October 2018) EASA does not mandate the obligation to ensure CAMO & Maintenance Planning Staff receive HF training, the reality is that the potential for Human Factor Error knows no bounds and it is just as likely that a Human Factor (HF) error could originate from an exposure within the Maintenance Planning Environment as anywhere else within the “Aviation System”.

Currently some 80% of aircraft accidents are attributable to human error, however this is a situation where it is possible to manage and or address by managing the exposure.

Human Error is recognised as rectifiable through the process of raising awareness, implementation of effective process and procedure and effective communication within the workplace.

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Preparation for Entry Into the Fuel Tank

It is most important to ensure that all persons who are engaged in the process of Fuel Tank Entry are fully trained on all aspects of the following information to ensure that all precautions are taken and all risks minimised.

Steps which must be taken include the following:

a) Ensure the aircraft is electrically grounded

b) Ensure that Fire Extinguishers are available (typically CO2 would be used for a Fuel Fire

c) Deactivate all Electrical Systems on the Aircraft and suitable placard

d) Defuel the aircraft using the Aircraft Maintenance Manual Procedures

e) Deliver a safe atmosphere for maintenance personnel by ensuring the following:

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The Elements of Aircraft Maintenance – Part 4

An article by our Guest Blogger and SAS Instructor and Consultant Kevin Rookes

Welcome to the final part of a four-part series that explains what constitutes maintenance from an FAA perspective and what are the differences between the elements that make up maintenance.

In this article we look at what is not a maintenance activity.

ACTIVITIES WHICH ARE NOT MAINTENANCE

It is mistakenly believed that if something has the potential to cause harm to the aircraft or its operation, the activity should be covered as a maintenance activity. That perception probably has ties to the language that is used in the definition of a “major repair” in § 1.1: “Major repair means a repair: (1) That, if improperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness…” This has led people to improperly classify some activities that could affect the airworthiness of the aircraft, if done improperly, as maintenance. These activities include:

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The Elements of Aircraft Maintenance – Part 3

An article by our Guest Blogger and SAS Instructor and Consultant Kevin Rookes

Welcome to the third part of a four-part series that explains what constitutes maintenance from an FAA perspective and what are the differences between the elements that make up maintenance?

This article provides an overview

REPLACEMENT OF PARTS

The replacement of parts is the removal and/or installation of parts on a product or article, and therefore, logically a maintenance task. However, there are some specific tasks that require further explanation.

Removing and Reinstalling the Same Part

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Sofema Aviation Services www.sassofia.com looks at typical performance indicators within an Integrated Operation

Flight Operation

Ground Operations

Maintenance

The following list serves as an introduction to a range of indicators which may be employed within your organisation to support the development of Key Indicators and to facilitate the measurement of Safety Performance across the business.

Using Data derived from the Compliance Quality Audit Program to support the Performance Metrics of the Safety Management System

1/ Internal audits/compliance monitoring: all non-compliances

a) Total number of findings per audit planning cycle & trend

b) % of findings which have a safety significance

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The Elements of Aircraft Maintenance – Part 2

An article by our Guest Blogger and SAS Instructor and Consultant Kevin Rookes

Welcome to the second part of a four-part series that explains what constitutes maintenance from an FAA perspective and what are the differences between the elements that make up maintenance?This article considers what makes up overhaul, repair and preservation.

OVERHAUL

An overhaul includes several separate maintenance activities to restore a product or article to a condition that will give a reasonable assurance of operation for a specified amount of time. The term “overhaul” is mentioned in several places in the FAR’s but this article uses the definition in 14 CFR section 43.2(a), which states that an overhaul consists of disassembly, cleaning, inspection, repaired as necessary, reassembly, and testing.

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The Elements of Aircraft Maintenance – Part 1

An article by our Guest Blogger and SAS Instructor and Consultant Kevin Rookes

This is the first part of a four-part series that explains what constitutes maintenance from an FAA perspective and what are the differences between the elements that make up maintenance. 

The term “maintenance” is defined in Title 14 of the Code of Federal Regulations (14 CFR) part 1, §1.1 as “inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.”
While this definition has been around for a long time, differences between the five elements that make up maintenance (i.e., inspection, overhaul, repair, preservation, and the replacement of parts) is not always clearly understood. The definition of maintenance does not include the terms “rebuild” or “rebuilt”. Those functions are limited to the Design Approval Holder (DAH) (i.e., manufacturer) with Production Certificate (PC) approval using its approved design data.

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Sofema Aviation Services www.sassofia.com considers an EASA Compliant Maintenance Planning Process. 

Maintenance has come a long way since the early days when maintenance programs owed more to the perception of the maintenance needs, as opposed to the analyzed and justified needs. In addition the role of the regulator was also minimal, and in part developed as a result of events, incidents and accidents. 

During the end of the first half of the 20th century regulations began to strengthen and the aircraft manufacturer was seen as the appropriate source of the maintenance program development. The early attempts at effective maintenance (in the 1960’s) saw time limits developed which resulted in aircraft being progressively dismantled, in what became know as Hard Time primary maintenance.

All hard time components were then routed through an overhaul process and after an appropriate restoration process were considered as zero timed. (Means they were considered as zero life and good to go again) - Following investigations into the effectiveness of the Aircraft Maintenance Process, by both the FAA and several airlines, a number of determinations were made.

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Bridging Checks Introduction

Why would we want to carry out a Bridging Check?

Typically because we have recently acquired a “new to our organisation” aircraft and it is on a different maintenance schedule.

A bridging check is normally required to address tasks which have either not been done by the previous operator (maybe they are not applicable for a particular operator) or alternatively the tasks may have been done at different intervals when directly compared with your existing Maintenance Programme or Schedule.

A ‘bridging check’ is not in itself a maintenance package; rather it is the result of a detailed analysis of the pre and post transfer tasks to identify any differences which need to be addressed during the transfer bridging check.

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It is not uncommon for the operator to require the CAMO to maintain the reliability program to essentially demonstrate the minimum compliance of the regulatory requirements. Missing the opportunity to foster a genuine desire to engage with a serious investigate process related to the understanding of negative trends and take efficient corrective measures.

Possibly a major reason for this behaviour is related to a lack of understanding by the operator regarding the philosophical reasons related to the effective implementation of a fully active statistical process control. Unfortunately, the focus is on “living and surviving from day to day” solving problems without spending sufficient time on dealing with the underlying causes.

The benefit of a fully integrated Reliability program is that it does not over react to single events rather the focus moves to trends and system related problems.

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Posted by on in Regulatory

Whilst the Operators CAMO is responsible for the delivery of an effective and viable maintenance planning process, it is the EASA part 145 Aircraft Maintenance Organisation (AMO) which has the responsibility to perform the maintenance in accordance with the work package.

EASA AMP Obligations

EASA requires Operator Reviews of Validity and Effectiveness of the AMP  - EASA Annex I – Part M - Subpart C - M.A. 302 Aircraft Maintenance Programme - (g) … The aircraft maintenance programme shall be subject to periodic reviews and amended accordingly when necessary. These reviews shall ensure that the programme continues to be valid in light of the operating experience.

Operators are able to strongly influence the success of a continuous development of scheduled maintenance program data but providing a virtuous circle of feedback to the Type Certificate Holder (TCH), A continuous review of TCH and Original Equipment Manufacturer (OEM) service bulletins, reliability data, service letters, airworthiness directives provides source material for optimisations.

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When a maintenance program is developed, it includes tasks that satisfy the criteria for both applicability and effectiveness.

The applicability of a task is determined by the characteristics of the component or equipment to be maintained.

The effectiveness is stated in terms of the consequences that the task is designed to prevent. The basics types of tasks that are performed by maintenance personnel are each applicable under a unique set of conditions.

Tasks may be directed at preventing functional failures or preventing a failure event consisting of the sequential occurrence of two or more independent failures which may have consequences that would not be produced by any of the failures occurring separately.

Maintenance Program task types include:

(1) Inspections of an item to find and correct any potential failures;

(2) Rework/remanufacture/overhaul of an item at or before some specified time or age limit;

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A Supplemental Type Certificate (STC) is an FAA  or EASA approved major modification or repair to an existing type certified aircraft, engine or propeller. As it adds to the existing type certificate, it is deemed 'supplemental'. As its name suggests, an STC is a certificate. It defines the product design change, states how the modification affects the existing type design, and lists serial number effectively. It also identifies the certification basis, listing specific regulatory compliance for the design change.

An STC being a supplemental type design approval for a major alteration and specific to a make and model or even a specific serial number as a one “off” STC

The STC Holder – STCH remains ultimately responsible for the certification of the modification.  An STC is a design approval, however it doesn’t allow the holder to produce anything. (typically created by Part 21 /FAR 21 Subpart J Organisation Design Approval Holder (DAH) Design Organisation Approval (DOA)).

Note - The STC, which incorporates by reference the related Type Certificate (TC), approves not only the modification, but how the modification affects the original design.

The application must be made in the form and manner prescribed by the FAA  or EASA.

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Whilst we all recognise the importance of safety in particular within “our” Maintenance Environment we face as an industry the problem of (Some say) Chronic under reporting of safety incidents.  Please consider when was the last time YOU filed a safety internal report?

What is the reason?

Is it the fear of reprisals or is it a case of fundamental disconnection from the responsibility to accept a personal obligation to report?

Whatever the reason the reality is that there is without doubt insufficient occurrence reporting, which results in “open” not closed loops ineffective closure and a reduced ability to deliver proactive safety improvements. (If at all !)

EASA has introduced a new EU Occurrence Reporting Regulation which is one key step in this direction as it sets a new framework to encourage and protect safety reporting by aviation professionals.

The Regulation (EU Reg. 376/2014 became applicable as of 15 Nov 2015, and requires aviation organisations in the EU to both adopt and maintain a proactive Just Culture to facilitate the collection of key safety data and information and to protect the reports as well as the information.

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EASAOnline (www.easaonline.com) considers the process to obtain your Maintenance Engineers Licence. Considering the Application Process for an EASA Part 66 Aircraft Maintenance Engineers Licence (AMEL)

An application for an aircraft maintenance License or change to such License shall be made on an EASA Form 19 (Form 19 is adopted and issued by each regulatory authority)

Applications process

The application are normally made under the jurisdiction of the Competent Authority of any European Member State. 

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Introduction

As a career starting in Aviation or Airport Services Aircraft Maintenance either Base or Line may be just the job for you!

Line maintenance is very satisfying and rewarding with the opportunity to progress to higher positions either within the organisation or in other organisations. 

Aircraft technicians and Engineers typically specialise as either B1 Airframe Engine & Electrical or B2 Avionic plus Electrical.  B1 Engineers who service engines, airframes and hydraulic and pneumatic systems, and the associated electrical systems and B2 avionic Engineers who service and overhaul the electronic systems, instruments, flight control, navigation and communication systems of aircraft as well as Aircraft Electrical Systems (task shared with B1)

Line maintenance essentially is maintenance that is performed on aircraft while they still remain operational, (carrying out routine maintenance of the aircraft on the ground during the turnaround between flights) whereas for Base Maintenance the level of maintenance is somewhat deeper. (Carrying out full servicing of the aircraft within the hangar at regular intervals typically at C check level) 

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Since August 2008 EASA has required Aircraft Inspectors to be trained in accordance with the provision to be found in AMC20-22

Aircraft inspection is normally performed by competent staff and such Inspectors are typically licensed aircraft engineers. Once qualified, they will gain the organization's approval and will be allowed also to certify General Visual Inspections, Detailed Inspections and EWIS Inspections.

What is a General Visual Inspection (GVI)?

The term GVI, when associated with Electrical Wiring Interconnect Systems, is a visual examination of an interior or exterior area, installation, or assembly to detect obvious damage, failure or irregularity based on a non-compliance or non-conformity with the standard configuration.

It is acknowledged that one of the weak areas in the maintenance chain is the effectiveness of the Inspection Process and the mitigation for this weakness will be found in the development of training programs.

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The purpose of a reliability program is to enable the gathering of data so we can look in detail at required procedures, responsibilities and tasks to ensure that the aircraft maintenance program tasks are effective and their periodicity is adequate.

Aircraft operability is the aircraft’s ability to meet the operational requirements in terms of operational reliability (i.e. the percentage of scheduled flights that depart and arrive without incurring a chargeable technical/operational interruption).

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Compliance audits are designed to give assurance that activities have been performed properly. It should be understood of course that Compliance Audits are of course reactive (means we have to review evidence which is either post an event or concurrent with an event).

As we know certain areas of our Aviation Business, (And it is fair to say in aviation there are many) can be described as high risk. For these area, among the many mitigation techniques which are available Quality Audits can play a supporting role, by establishing ongoing conformity with company processes and procedures.

When we consider compliance audits whilst it may be satisfactory the reality is that it is an unknown if the compliance will be satisfactory next week or next month. The compliance audit typically requires a lower level of auditor competence and is presented typically as a completed checklist of observed conditions at the time of the audit.

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