[Peetwo]

KC & AMROBA clan latest newsletter: Volume 13 Issue 10 (October 1016)

1. Specialist or Specialised Maintenance?

Correctly worded regulations and standards are clear and concise, i.e. understandable. Sadly, what has been produced over the last decade has raised more confusion than clarity and one of the main reasons is the failure to adopt and use international terminology and definitions. Instead, we have poorly worded regulations and standards very unique to Australia. Internationally, maintenance not covered by the AME, can be classified as specialised maintenance, not specialist maintenance.


2. What is a "Certificate of Release to Service" (CRS)?

Does a "certificate of release to service" give the impression that the aircraft is airworthy and serviceable or is it, as EASA states, simply a release from maintenance?

AMROBA looks very closely at what CASA states is a "certificate of release to service" and how others will interpret this improper terminology.

EASA states clearly in their documentation that their CRS does not mean the aircraft is airworthy and/or serviceable, this will not be the interpretation of our Courts or even members of a Senate Committee. The words "certificate of release to service" will be interpreted as the aircraft is airworthy and serviceable to return to service.


3. The effect of bad terminology on the AME skills.

One reason why the aviation regulatory system relating to AME skilling and licencing is not easy to understand is because it fails to adopt international standards promulgated under the Convention and comply with Government Guidelines.

Instead of harmonising with EASR Parts M, 66 & 147, CASA changed the meaning of EASR wording in the CASRs so they applied a unique system, with different LAME privileges that impacts on international harmonisation.


4. Government Guidelines & Convention Article 37.

One reason why the aviation regulatory system is not easy to understand is because it fails to meet international standards promulgated under the Convention and comply with Government Guidelines. A close review of the government guidelines and Article 37 of the Convention could see a very different regulatory language being applied to the aviation system where regulations would be very minimal & standards adopted.

MTF...P2