Recommendation Date
Recipient Name
CAA
Text
Considers introducing a requirement that engine compartment main fuel supply hoses be subject to "Hard Time Maintenance", rather than "On-Condition Maintenance" procedures, leading to replacement of all such fuel hoses on a basis of accumulated time in service and/or at the end of a defined calendar period as appropriate.
Reply Text
The CAA has moved away from the requirement that had previously existed (to pressure test hoses at specific intervals) on the basis that the requirement was prescriptive and in some cases inappropriate. This is in line with regulatory philosophy that the new Rule is intended to establish an environment where responsible persons in industry would make decisions that were appropriate for each individual occasion.
It appears that, in some cases, this objective may not be being achieved.
Overall, the CAA perceives that this event has raised queries about a number of current practices or requirements. These include:
• whether it is appropriate to accept Part 43 Appendix C as an acceptable regime for maintenance if the manufacturer has promulgated a maintenance schedule or programme for the aircraft, particularly where the aircraft is used on air transport operations;
• clarification and reinforcement of just what is meant or required by "On condition" maintenance., This does NOT, as some seem to believe, mean use it until it fails and then replace it. It means inspect it and check and/or test it so that you are satisfied that it will perform its function at least until the next inspection is due; and
• any requirement applied to fuel hoses in the engine compartment should also consider whether it is appropriate to place similar requirements on other hoses in that compartment. It is suggested that at least the oil hoses and, for IFR operations, the vacuum hoses are just as vital for safe operations as the fuel hoses.
The CAA has recently conducted a review throughout the country of the standard of maintenance of aircraft below 5700 kg. This was partly triggered by the inflow of information that came about with the initial requirement for an Annual Review of Airworthiness (ARA) inspection of GA aircraft and the inflow of a number of other pieces of information . This information and the resultant findings support the positions expressed earlier.
A working group has been established with members from both CAA and industry to review maintenance of aircraft in this category and the Final Recommendation will be passed to them for review. The initial meeting of the Group is today.
The CAA adopts the recommendation. The initial forum for the consideration will be the joint working group described above. I will advise you further of the outcomes of that review.
It appears that, in some cases, this objective may not be being achieved.
Overall, the CAA perceives that this event has raised queries about a number of current practices or requirements. These include:
• whether it is appropriate to accept Part 43 Appendix C as an acceptable regime for maintenance if the manufacturer has promulgated a maintenance schedule or programme for the aircraft, particularly where the aircraft is used on air transport operations;
• clarification and reinforcement of just what is meant or required by "On condition" maintenance., This does NOT, as some seem to believe, mean use it until it fails and then replace it. It means inspect it and check and/or test it so that you are satisfied that it will perform its function at least until the next inspection is due; and
• any requirement applied to fuel hoses in the engine compartment should also consider whether it is appropriate to place similar requirements on other hoses in that compartment. It is suggested that at least the oil hoses and, for IFR operations, the vacuum hoses are just as vital for safe operations as the fuel hoses.
The CAA has recently conducted a review throughout the country of the standard of maintenance of aircraft below 5700 kg. This was partly triggered by the inflow of information that came about with the initial requirement for an Annual Review of Airworthiness (ARA) inspection of GA aircraft and the inflow of a number of other pieces of information . This information and the resultant findings support the positions expressed earlier.
A working group has been established with members from both CAA and industry to review maintenance of aircraft in this category and the Final Recommendation will be passed to them for review. The initial meeting of the Group is today.
The CAA adopts the recommendation. The initial forum for the consideration will be the joint working group described above. I will advise you further of the outcomes of that review.
Related Investigation(s)