[Peetwo]

Latest AMROBA newsletter - Volume 13 Issue 7 July 2016

　
1. Progress is being made – now to reduce the time factor.

It has taken some time for CASA to restructure and this has held up progressing regulatory reform in the airworthiness and engineering sectors. The restructuring going on in the Federal Education Department regarding "Skill Councils" has not yet finished – this also affects the proposed AME trade training changes from being implemented quickly. However, two areas that can be progressed almost immediately is harmonising CASR 21 Subpart J and implementing changes to the foundations underpinning airworthiness standards. Performance based – less prescription.  

2. Regulatory Missing Airworthiness Elements.

The basis of any national aviation regulatory system is the responsibility of aircraft registered operators to maintain their aircraft in an "airworthy" condition, especially when a country opts to have an indefinite period of validity for certificates of airworthiness. ICAO Annex 8 clearly states that an indefinite period of validity must be supported by a "periodic inspection" & "on-going inspections" that attests the aircraft continues to meet (conformity) its design standards and is safe for flight. Not in CARs/CASRs.

3. US manufacturers’ trends increasing costs to ROs.

US manufacturers are making changes to their manuals to increase the manufacturers’ commercial profitability not safety. Because the FAA does not approve OEM manuals, they can include requirements to return items to them for maintenance. They can also repackage standard parts with a manufacturer part number under the guise of improved "quality control" and increase the price beyond belief. Also there is a trend for US manufacturers to then increase mandatory replacement items.

4. Part 145 Post Implementation Review next.

With CASA now committed to a Post Implementation Review of CASR Part 66, AME licensing, the next task must be the Post Implementation Review of CASR Part 145 to simplify and harmonise with best practices. Part 145 needs to have the ability to apply applicable standards for various levels and sizes of AMOs. The recently amended FAR Part 145, unlike the EASR Part 145, has addressed this issue. We need to enable management from "directly supervised organisations" to large corporate management structures without getting specific.

Performance based – less prescription.

MTF...P2