[Peetwo]

KC does a chalk and cheese review of Annex 8; & Airworthiness bilateral agreements - 

Via the AP email chains:

To all members,

The February Newsletter is now on the AMROBA’s website.

We wonder why Australia has to do business in a dated regulatory system that has not kept pace with the rest of the world?

Well, the answer is government departments/agencies have totally lost their expertise of pre agency times, who kept Australia current with ICAO ANNEX SARPs.

AMROBA did some comparisons and we simply do not deserve to be classed as a top 10 ICAO States of chief importan
ce in air transport.

1. Differences with ICAO Annex 8 comparisons makes interesting reading.
a. No wonder civil manufacturers are forced to move their businesses to the USA and EU nations.
b. Brazil, with no Annex 8 differences, is world’s best practice.
                                                               i.      Followed by China, Canada, Japan, USA & UK.

                                                             ii.      The USA system addresses older/vintage aircraft (needed in  Australia) better than others.

c. Australia also lodges more differences to other comparable nations.

Root Cause:       Australia “monitors” Annexes but have no programs to maintain currency.

2. We looked at the benefits to industry with harmonised Standards.
a. ICAO is very clear in the reasons for harmonised Standards.
b. We reviewed the Singapore/USA Bilateral that includes a Maintenance Agreement
 c. We reviewed the Singapore/EASA agreement that includes a Maintenance Agreement
d. We reviewed the UK/USA agreement that includes a Maintenance Agreement.
e. We reviewed Australia/USA agreement that does not include a Maintenance Agreement.

Root Cause:       Government does not have an aviation foreign office dedicated to negotiating agreements (FTA)

3. We look back at the problem with maintaining older aircraft maintenance where there is little to no approved maintenance data how to do maintenance because manufacturers passed that responsibility to the LAME.
a. The preamble to these manufacturers MM usually includes a statement that states this MM is a guide to the A&P mechanic and does not override the responsibility of the mechanic.
b. It wasn’t till the introduction of the ATA format in the 70s/80s that more detailed maintenance instructions appeared.
c. CAR 2A has always been based on the ATA formatted manuals but also excludes instructions issued by NAAs.
d. The FAA has both approved maintenance data and acceptable maintenance design for all US made aircraft.
e. Older/ageing aircraft safety is in the hands of experienced LAMEs which have kept safety levels acceptable.
f. However, we do get, mainly airline/military, from time to time, AWIs that expect what they are used to in modern aircraft MMs to be available to the GA LAME.
g. AMROBA has again raised this issue with CASA.

Root Cause:       Awaiting regulatory changeto adopt the FAA system that will introduce the approved/acceptable FAA ATA system.

4. Why LAME skills are so important to Safety.
a. The FAA Aircraft Maintenance Technician (our LAME) is honoured in the USA by having a national day – May 24th
b. The history of this is really no different to the Australian LAME.
c. A day in the life of an AMT/LAME is no different the world over.
d. A GA LAME has no Tech Services to support them, they are their own TS and access manufacturers more often.

Root Cause:       The (N)VET trade training system has failed to adjust to modular training supporting multi trade pathways in the avionic and mechanical trade streams of the past.

Ken Cannane

Executive Director

AMROBA

Phone: (02) 97592715

Mobile: 0408029329

www.amroba.org.au

Safety All Around.

Via the Newsletter:









MTF...P2