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Regulatory requirements for manufacturers’ supplemental inspections

Issue number: AO-2011-115-SI-02
Who it affects: All registration holders of class B aircraft
Issue owner: Civil Aviation Safety Authority
Operation affected: Aviation: General aviation
Background: Investigation Report AO-2011-115
Date: 16 August 2013

Safety issue description

The Civil Aviation Regulations 1988 lack clarity regarding the requirement for aircraft manufacturers’ supplemental inspections, where available, to be carried out when an aircraft is being maintained in accordance with the CASA maintenance schedule.

Proactive Action

Action organisation: Civil Aviation Safety Authority
Action number: AO-2011-115-NSA-055
Date: 16 August 2013
Action status: Closed

In reference to the abovementioned safety issue, CASA provided the following comment:

While the CAR 42V regulatory requirement currently exists for Registered Operators to ensure maintenance is carried out in accordance with the applicable provisions of the aircraft’s approved maintenance data, CASA agrees that additional information may assist industry understanding of their regulatory obligations, mainly in conjunction with the use of CAR 42B CASA Maintenance Schedule. To this end CASA published a series of Discussion Papers in December last year (2012) setting out a range of options for developing updated continuing airworthiness regulations for all aircraft not used in RPT operations.

The discussion paper covering maintenance programs set out the items for consideration and options for the reform of the maintenance program requirements for non-RPT aircraft to bring the regulations up to date with modern technology and current international practices. Considerations that were addressed in this discussion paper included dealing with instructions for continuing airworthiness; assessment of ICA is considered a necessary continuing airworthiness management requirement for all aircraft that are adequately supported by a type certificate holder or national aviation authority.

ATSB response:

The ATSB acknowledges the actions taken by CASA to date and notes its actions regarding regulatory reform in relation to maintenance programs for general aviation operations. However, given the currently unresolved outcomes from the discussion paper, including the circumstances where the CASA maintenance schedule would continue to be used, the ATSB remains concerned that this safety issue may not be adequately addressed and has therefore issued the following recommendation.

Recommendation

Action organisation: Civil Aviation Safety Authority
Action number: AO-2011-115-SR-049
Date: 16 August 2013
Action status: Released

The Australian Transport Safety Bureau recommends that CASA proceed with its program of regulatory reform to ensure that the provisions of CAR Schedule 5 are clarified in relation to the incorporation of all relevant supplemental inspections specified for the aircraft type.

Correspondence

Date received: 11 November 2013
Response from: Civil Aviation Safety Authority
Action status: Closed
Response text:

Given the currently unresolved outcomes from the discussion paper, including the circumstances where the CASA maintenance schedule would continue to be used, you remain concerned that this safety issue may not be adequately addressed and have therefore issued the recommendation that CASA proceed with our program of regulatory reform to ensure that the provisions of CAR Schedule 5 are clarified in relation to incorporation of all relevant supplemental inspections specified for the aircraft type.

I accept this recommendation and CASA will address this issue, work has commenced and it will certainly involve continued consultation with industry and may come to involve a risk assessment, a cost-benefit analysis and the preparation of a regulatory impact statement.

ATSB response:

The ATSB recognises the acceptance of the recommendation by CASA. The ATSB will continue to monitor the ongoing work by CASA until the issue has been satisfactorily addressed.

Date received: 19 May 2015
Response from: Civil Aviation Safety Authority
Action status: Closed
Response text:

CASA released Aviation Ruling 01/2014 and Airworthiness Bulletin 02-048 in April 2014 to clarify when manufacturer's supplemental inspection documents, however described, including Cessna Supplemental Inspection Documents (SIDs), issued as instructions for continuing airworthiness of an aircraft or the aircraft's aeronautical products, are required to be complied with.

In relation to  the outstanding safety issue, the Aviation Ruling states that "if the registered  operator has elected to use the CAR 42B CASA Maintenance Schedule...compliance with SIDs and other manufacturer's supplemental or structural inspection documents is mandatory".

ATSB response:

The ATSB is satisfied that this action taken by CASA effectively addresses the safety issue.

   
Current issue status: Adequately addressed
Status justification:

CASA released Aviation Ruling 01/2014 and Airworthiness Bulletin 02-048 in April 2014 to clarify when manufacturer's supplemental inspection documents, however described, including Cessna Supplemental Inspection Documents (SIDs), issued as instructions for continuing airworthiness of an aircraft or the aircraft's aeronautical products, are required to be complied with. In relation to the outstanding safety issue, the Aviation Ruling states that "if the registered operator has elected to use the CAR 42B CASA Maintenance Schedule...compliance with SIDs and other manufacturer's supplemental or structural inspection documents is mandatory".The ATSB therefore considers the safety issue to be adequately addressed.
 

 
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Last update 11 August 2015