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AMROBA October Newsletter -

Via amroba.org:

To all members,

Our October Newsletter addresses:-

• ICAO’s Classification of Activities includes civil aviation manufacturing, Aviation Training, Maintenance and Overhaul and Regulatory Functions in addition to Operations activities.
  

CASA is Australia’s Regulatory Authority responsible for setting qualifications and training to meet the ICAO standards.

IMO – the International Maritime Organization– is the United Nations specialized agency with responsibility for the safety and security of shipping and the prevention of marine and atmospheric pollution by ships. IMO's work supports the UN SDGs.

• AMSA is Australia’s regulatory authority responsible for setting  to meet the IMO standards.
  
• The difference is that AMSA authorises the actual courses to attain a qualification to hold an AMSA licence/authorisation.
  

When compared, it is easy to see why the maritime system is stable and meets global standards – total reverse to civil aviation.

• ICAO’s minimum Classifications of Operations provides more pathways than our regulatory system.
  
• Why hasn’t Australia adopted the ICAO Commercial Air Transport “Air Taxi” system
  

ICAO Annex 6, Parts I, II & III details the  standards for approval and operations – in some cases, less onerous than Australia’s red tape systems.

• In some cases, an operator only has to meet the standards specified to provide the operations service. Less red tape than what is applied in Australia.
  

• Without doubt, the current system has resulted in a shortage of pilots, maintenance engineers, small businesses in both the engineering and operational sectors.
  

• When Flying Clubs were popular, we had many small businesses throughout the aviation system with much less red tape.
  

• We have harped on it for some time, full adoption of EASR Parts 66/147 A & B regulations would have removed the issues we have today.
  

Government needs to re-think the regulatory reform, from an engineering viewpoint, from an internal domestic system to a globally harmonised system with government to government nd CASA to other Nations Safety Regulator that enables Australian engineering businesses to participate globally.

This is a pipe dream at present because the government’s Authorised Release Certificate, Form 1, is not globally accepted.

The size of the industry is dependent on the regulatory system and the amount of red tape.

Ken Cannane
Executive Director
AMROBA
Phone: (02) 97592715
Mobile: 0408029329
www.amroba.org.au
Safety All Around.

On somewhat related matters but in another hemisphere, the FAA backs down on adopting (and therefore enforcing) the Moss Interpretation on maintenance supervision, via AvWeb:

FAA Puts Maintenance Supervision Guidance On Hold
Industry groups’ protest led to reconsidering the interpretation

Mark Phelps

Updated Oct 18, 2024 6:01 AM EDT

Image: ATS Apprentice Program

In a one-paragraph letter, the FAA legal team reported this week it is placing the so-called Moss Interpretation of maintenance supervision requirements on indefinite, but not permanent, hold. Industry groups and specifically Mike Busch of Savvy Aviation had protested that the interpretation would do irreparable harm to enabling apprenticeships and aircraft owner maintenance in general aviation maintenance.

Busch told AVweb today that the FAA had placed the interpretation on hold, and that he and industry advocacy groups have requested an FAA/Industry meeting before the FAA issues a clarification on the interpretation. Busch explained that the rule, as written, has been in place for 60 years and certificated maintenance personnel, Airframe & Powerplant (A&P) mechanics and those with Inspection Authorization (IA) status could use their judgment in supervising the work of apprentices and other non-rated individuals. He said that form of surveillance could range from simply inspecting the work after it is completed and signing it off in the logbook to direct in-person consultation on more demanding and critical procedures—and everything in between.

But under the language of the  Moss Interpretation, that discretion is removed and the apprentice must be under constant in-person supervision. He said that was not the intent of the original rule and would cripple the GA maintenance industry at a time when mechanics are sorely needed. At press time, Busch had not heard whether the request for an FAA/Industry meeting had been approved by the FAA.

When I queried KC about what all this meant he replied:
 

P2

Both were wrong in their interpretation.

“to the extent necessary” has been the most important part of the rule, always has in the US.

We sent an input to our counterpart, AARSA, to back their submission.

Ken

When I further queried what was AMROBA's input KC came back with the following...

P2

We inputted the following to ARSA based on the FAA proposal.
It is like CASA determining how much supervision is required.
It is up to the LAME and the supervised employee.
How long have you supervised him/her?
How well trained is the individual?
Apprentice to experienced AME?
 
Etc, etc,
 
Main sentence of our input.
 
Only the AMT can determine the amount of supervision required based on skills and experience of the person being supervised. If the FAA can prove there was insufficient supervision because the work was not performed correctly, then they could carry out enforcement. To assume the result before return to service is beyond the wording of the regulation that, in our opinion, allows the AMT to determine the amount of supervision required, not the FAA.

US Associations sent a combined letter to the FAA

US Association Submission re Supervision

Ken

KC perfectly highlights why it is so important for the Australian aviation industry to be engaged with our international counterparts to benefit trade and harmonisation of international safety standards IE the ICAO SARPs...

MTF...P2