An esteemed colleague drew my attention this morning to a very interesting FAA document. It is:
A Report from the 14 CFR Part 23 Reorganization Aviation Rulemaking Committee
to the Federal Aviation Administration
Recommendations for increasing the safety of small
general aviation airplanes certificated to 14 CFR part 23
It is found here:
http://www.faa.gov/regulations_policies ... Report.pdf
Interesting in the document is the following passage (Page 332):
"The accident rate data from the Canadian Owner Maintenance Category covers over a decade of experience with a statistically significant fleet size. It indicates that both in terms on accident rate and cause, owner maintenance category aircraft are as safe, or safer than standard category aircraft. Nether the Owner Maintenance Program, nor the use of non certified components has contributed to an accident in the Canadian O-M fleet in the last decade.
It is significant that in many of the years looked at the O-M aircraft actually had a better (safer) accident rate than the standard category aircraft. Likely this is not due directly to the O-M program, but as an indirect effect. It is likely that because of the lower costs and greater involvement of the aircraft owners, usage rater improved, which contributed towards pilot currency. In addition, owners may have replaced components more frequently due to the lower cost, thus improving the overall maintenance of the aircraft. Further, it is also likely that many of the aircraft are equipped with improved avionics systems, allowing safer flight, than comparable standard category aircraft because of the less burdensome approval process and lower cost.
Therefore it is safe to conclude that the Canadian O-M system has not detrimentally impacted safety, and it is likely that it actually indirectly improved safety."
Supporting information to this is found on page 331.
The report is very much more wide ranging in scope than just that, and I have not read it all.
However, the forgoing passage is a clear pointer that O-M is safe, and the higher level of regulatory oversight on this group of aircraft is not at all contributing to greater safety than O-M. Canada needs to adopt this simplified maintenance model for a very much greater portion of the fleet, and, greatly simplify the modification approval process for those aircraft ("commercial") for which retaining an approval process would still be prudent.
The Canadian GA industry needs to stand up for itself to TC, and convincingly present an argument for simplified aircraft maintenance and modification standards. We took the first step nearly 20 years ago with the first O-M category, and I participated in the CARAC meetings. It's time for round two. If this report, and the foregoing passage, are not a good, objective stepping stone to that, I can't imagine what would be!
FAA and Owner Maintenance
Moderators: lilfssister, North Shore, sky's the limit, sepia, Sulako, I WAS Birddog
Re: FAA and Owner Maintenance
Looking forward to hearing from Avcanada's a AME community on this one, particularly the more paperwork-oriented members of same.
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Big Pistons Forever
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Re: FAA and Owner Maintenance
At the lower end of GA I think many AME's actually like OM. Many if not most OM aircraft owners still use AME's for the more complex/specialized jobs. The AME's can do the work and get paid without all the paperwork associated with working on a normal catagory certified aircraft.
In any case owner maintenence on certified aircraft happens all the time. Nothing get put in the logbook and life goes on. The increasing regulatory burden on maintenence providers, with absolutely no credible justified evidence based safety case is rapidly driving more and more maintenence underground.
A perfect example involved a seat on a FTU C 172. One of the tubes on the seat frame had a crack. Until 2 years or so, the fix would have been to take it to the local industrial welding shop who would have done a weld repair. Then a local AME's who had a weld inspection authorization would look at it, approve the weld and the seat would be fixed with an appropriate log book entry as the maintenence release.
Now anythng to do with welding is specialized work with all sorts of onerous requirements involving training, publications, testing gear, etc etc. That AME gave up his certification because it was not practical to keep it anymore.
To get the seat fixed in accordence with the regs would have meant sending it to a large AMO who required manufactures drawings, metal specifications, an approved repair scheme etc etc and would have resulted in a multi thousand dollar invoice. All of these extra requirements are not evidence based as there has never been a siginicant issue with improper welds in GA aircraft, it is just regulation for the sake of regulations.
You can guess how the seat ended up getting repaired.....
Good job TC ! Lets drive all maintenence underground, that will really improve flight safety.
In any case owner maintenence on certified aircraft happens all the time. Nothing get put in the logbook and life goes on. The increasing regulatory burden on maintenence providers, with absolutely no credible justified evidence based safety case is rapidly driving more and more maintenence underground.
A perfect example involved a seat on a FTU C 172. One of the tubes on the seat frame had a crack. Until 2 years or so, the fix would have been to take it to the local industrial welding shop who would have done a weld repair. Then a local AME's who had a weld inspection authorization would look at it, approve the weld and the seat would be fixed with an appropriate log book entry as the maintenence release.
Now anythng to do with welding is specialized work with all sorts of onerous requirements involving training, publications, testing gear, etc etc. That AME gave up his certification because it was not practical to keep it anymore.
To get the seat fixed in accordence with the regs would have meant sending it to a large AMO who required manufactures drawings, metal specifications, an approved repair scheme etc etc and would have resulted in a multi thousand dollar invoice. All of these extra requirements are not evidence based as there has never been a siginicant issue with improper welds in GA aircraft, it is just regulation for the sake of regulations.
You can guess how the seat ended up getting repaired.....
Good job TC ! Lets drive all maintenence underground, that will really improve flight safety.
Re: FAA and Owner Maintenance
The fact O-M was not allowed in US skies is one reason, I (as a simple private owner) haven't considered it ... But, after 5 years of flying, I haven't been to the US yet! So maybe the costs savings of O-M would be worth it, since apparently, flying in the US is not that big a deal for me ...
The other is that honestly, I haven't heard much about it and what exactly it means ... I mean, the name says a lot, but I'm reading here that it also means I no longer need to use certified parts! Wow, I didn't know that ... Man, now it's really interesting.
My AME actually suggested it to me once, since I happen to do everything "owner assisted" already anyways ...
The other is that honestly, I haven't heard much about it and what exactly it means ... I mean, the name says a lot, but I'm reading here that it also means I no longer need to use certified parts! Wow, I didn't know that ... Man, now it's really interesting.
My AME actually suggested it to me once, since I happen to do everything "owner assisted" already anyways ...
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iflyforpie
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Re: FAA and Owner Maintenance
I have zero issues with O-M aircraft. As BPF says, most owners of O-M aircraft are happy to use an AME to do things like jug changes or structural repairs that require tooling and knowledge beyond what's available to the backyard mechanic.
The idea is that it is the owner putting his ass into the aircraft... so the desire for quality workmanship should be paramount. Also, not having to pay AMEs for BS stuff leaves more money for critical stuff and more money for flying. Lots of uncertified parts are the same or better than the certified ones for less money.... an 8130 usually just means that your 1960s technology is guaranteed to suck for a specific period of time on average.
I think when you compare O-M to homebuilts, the accident rates on homebuilts will be higher again not because of maintenance, but because of design flaws and construction errors, plus the odd configurations and high performance aspects of many homebuilts.
The idea is that it is the owner putting his ass into the aircraft... so the desire for quality workmanship should be paramount. Also, not having to pay AMEs for BS stuff leaves more money for critical stuff and more money for flying. Lots of uncertified parts are the same or better than the certified ones for less money.... an 8130 usually just means that your 1960s technology is guaranteed to suck for a specific period of time on average.
I think when you compare O-M to homebuilts, the accident rates on homebuilts will be higher again not because of maintenance, but because of design flaws and construction errors, plus the odd configurations and high performance aspects of many homebuilts.
Re: FAA and Owner Maintenance
Searching the CCAR, I hit the limit of 500 results ... so there's quite a few airplanes under that category hmmm ...
Re: FAA and Owner Maintenance
iflyforpie: I agree ... In many ways, taking an A/C that met all the certification requirements, and then making it "experimental" seems in some ways like the best of both worlds.
You know the design met certain standards and can rely on that ... but 20-40-60 years later, you can give yourself the liberty to use some non certified parts, etc. as needed, or stick to something certified!
And I can still use a perfectly qualified AME, or not!
It seems there's a balance that can be struck that's not there in the fully certified world, where things are a little extreme, needed certification and expensive hardwaree for the simplest things ... with O-M, one can find a sweet spot and balance that might make more sense ...
I may chose to stick to a certified engine, but put Dynon avionics, for instance ...
You know the design met certain standards and can rely on that ... but 20-40-60 years later, you can give yourself the liberty to use some non certified parts, etc. as needed, or stick to something certified!
And I can still use a perfectly qualified AME, or not!
It seems there's a balance that can be struck that's not there in the fully certified world, where things are a little extreme, needed certification and expensive hardwaree for the simplest things ... with O-M, one can find a sweet spot and balance that might make more sense ...
I may chose to stick to a certified engine, but put Dynon avionics, for instance ...
Re: FAA and Owner Maintenance
Oh those are great statistics, unrealistic but great. I would hazard a guess that a large portion of O-M aircraft don't fly that much (under 25hrs a year) or even at all, what are the accident rates per hour flown? And you can't tell me that there hasn't been incidents where the wrong parts or improper process was a causal factor as that happens statistically with aircraft in all other categories. Not to mention the resale value plummets. There is a place for OM and I'm sure there are some really slick OM a/c that are nicer than any commercial version but as we know, it takes all kinds and you can bet your life that there are some real cheap ass GA owners who are in the OM category so that they don't have to do maintenance and save a few bucks. I'm all for making GA more affordable and accessible to the masses but thinking that you can just go to OM and do what you want and not enter any more info into the logbook is just ridiculous and dangerous.
Re: FAA and Owner Maintenance
That put the FAA in their place. Silly, ridiculous, people.
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Colonel Sanders
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Re: FAA and Owner Maintenance
Yes, because it would the same as a homebuilt!thinking that you can just go to OM and do what you want and not enter any more info into the logbook is just ridiculous and dangerous
PS Sometime you should read up on FAA
experimental/exhibition ... on the subject of
willy-nilly modifications to certified aircraft.
Everyone down south does it.
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Justjohn
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Re: FAA and Owner Maintenance
I'm all for making GA more affordable and accessible to the masses but thinking that you can just go to OM and do what you want and not enter any more info into the logbook is just ridiculous and dangerous.[/quote]
Actually, all that info still gets recorded in the logbook. In fact that is a pretty important part of the O/M legislation. You have strong opinions about something you are not really informed about.
My Tri-Pacer is in the O/M category. The uncertified parts that I have used are a Ford Truck door handle (as Piper orig used), and a square, flat piece of Plexiglass cut to size, for a side window. All documented as required in the Logs. My AME does the work but doesn't sign for it. He wouldn't be avail if he did have to sign the logs. There is not a local AMO avail.
At about 50 hrs a year, my little airplane is BY FAR one of the most active recreational aircraft in our little corner of the world.
My day job as a 705 Captain pays for it all, and keeps me very risk adverse. With nearly 10 000 hours I think I am well enough informed to know what I do, and more importantly, what I don't know.
The Owner Maint category is certainly not a cure all. But for some situations it is an effective means of safely flying airplanes that would not otherwise be airworthy.
Actually, all that info still gets recorded in the logbook. In fact that is a pretty important part of the O/M legislation. You have strong opinions about something you are not really informed about.
My Tri-Pacer is in the O/M category. The uncertified parts that I have used are a Ford Truck door handle (as Piper orig used), and a square, flat piece of Plexiglass cut to size, for a side window. All documented as required in the Logs. My AME does the work but doesn't sign for it. He wouldn't be avail if he did have to sign the logs. There is not a local AMO avail.
At about 50 hrs a year, my little airplane is BY FAR one of the most active recreational aircraft in our little corner of the world.
My day job as a 705 Captain pays for it all, and keeps me very risk adverse. With nearly 10 000 hours I think I am well enough informed to know what I do, and more importantly, what I don't know.
The Owner Maint category is certainly not a cure all. But for some situations it is an effective means of safely flying airplanes that would not otherwise be airworthy.
Re: FAA and Owner Maintenance
I know what the regs are, but most don't, nor would care to follow them.
We aren't talking about experimental/exhibition, light sport, vla or homebuilt a/c here CS there are categories for almost anything, the OM cat was created for antiques with little or no data available to keep the legacy going, not to cheap out on proper maintenance.
As I said before, I'm all for the OM cat but you have to accept the good with the bad.
Before anyone gets delusions of grandeur and tries opening a commercial air service in the OM category please read the following CAR's:
6) Special Certificate of Airworthiness - Owner-maintenance
(amended 2002/03/01; no previous version)
(a) A Special C of A in the owner-maintenance classification is issued for recreational purposes only.
(amended 2002/03/01; no previous version)
Information Note:
Aircraft eligible for a Special Certificate of Airworthiness - Owner-maintenance are listed in Appendix H of this Standard.
(b) Each aircraft in respect of which a Special C of A - Owner-maintenance is in effect, is marked on the side of the fuselage, in a position that is readily visible to persons entering the aircraft, in letters at least 10 mm (3/8 in.) high and of a colour contrasting with the background, with a placard containing the following statement:
(amended 2002/03/01; no previous version)
WARNING
SPECIAL CERTIFICATE OF AIRWORTHINESS - OWNER-MAINTENANCE
THIS AIRCRAFT DOES NOT COMPLY WITH INTERNATIONALLY RECOGNIZED AIRWORTHINESS STANDARDS
AVIS
CERTIFICAT SPÉCIAL DE NAVIGABILITÉ - MAINTENANCE PAR LE PROPRIÉTAIRE
CET AÉRONEF N’EST PAS CONFORME AUX NORMES DE NAVIGABILITÉ
INTERNATIONALES RECONNUES
(c) Each aircraft in respect of which a Special C of A - Owner-maintenance is in effect, and each engine, propeller and life-limited part installed on such an aircraft, has the letter “X”; permanently etched, engraved or stamped at the end of the model designation and serial number on the identification plate required by >CAR 201.01.
(amended 2002/03/01; no previous version)
(d) A person may have an aircraft type added to the list of aircraft eligible for a Special C of A - Owner-maintenance, by submitting a written request to the Minister, certifying that the aircraft type and model meet the requirements outlined in paragraph (6)(e).
(amended 2002/03/01; no previous version)
Information Note:
A written request must be submitted to the Director, Aircraft Maintenance and Manufacturing, Ottawa, Canada, certifying that the aircraft type and model meet the requirements outlined in paragraph (6)(e).
(e) An aircraft type and model may be included in Appendix H of this Standard, Aircraft eligible for a Special Certificate of Airworthiness - Owner-maintenance”, where:
(amended 2002/03/01; no previous version)
(i) the aircraft is of a type certified in accordance with Chapters 522 or 523 of the Airworthiness Manual, or an equivalent foreign standard;
(ii) the aircraft type certificate does not authorize more than four occupants;
(iii) the maximum certificated take-off weight (MCTOW) of the aircraft does not exceed 1,814 kg (4,000 pounds);
(iv) the aircraft is of a type and model that has not been manufactured during the 60 months preceding the date of application;
(v) fewer than 10% of Canadian aircraft of the type and model concerned are operating in Canadian commercial air service at the time of application;
(vi) the aircraft type and model is powered by a single, normally aspirated, piston engine, and is unpressurized; and
(vii) except for gliders, powered gliders or aircraft with airframes of wooden construction, the aircraft type and model has a fixed landing gear and a fixed pitch propeller.
We aren't talking about experimental/exhibition, light sport, vla or homebuilt a/c here CS there are categories for almost anything, the OM cat was created for antiques with little or no data available to keep the legacy going, not to cheap out on proper maintenance.
As I said before, I'm all for the OM cat but you have to accept the good with the bad.
And why would you need an AMO? Any licensed AME can sign it and if you go OM then why would you still need the services of an AME? All this talk about low wages, poor shop rates and so on and you think that AME's across canada are going to be willing to just "help out" a guy in the OM cat.Justjohn wrote:My AME does the work but doesn't sign for it. He wouldn't be avail if he did have to sign the logs. There is not a local AMO avail.
Before anyone gets delusions of grandeur and tries opening a commercial air service in the OM category please read the following CAR's:
6) Special Certificate of Airworthiness - Owner-maintenance
(amended 2002/03/01; no previous version)
(a) A Special C of A in the owner-maintenance classification is issued for recreational purposes only.
(amended 2002/03/01; no previous version)
Information Note:
Aircraft eligible for a Special Certificate of Airworthiness - Owner-maintenance are listed in Appendix H of this Standard.
(b) Each aircraft in respect of which a Special C of A - Owner-maintenance is in effect, is marked on the side of the fuselage, in a position that is readily visible to persons entering the aircraft, in letters at least 10 mm (3/8 in.) high and of a colour contrasting with the background, with a placard containing the following statement:
(amended 2002/03/01; no previous version)
WARNING
SPECIAL CERTIFICATE OF AIRWORTHINESS - OWNER-MAINTENANCE
THIS AIRCRAFT DOES NOT COMPLY WITH INTERNATIONALLY RECOGNIZED AIRWORTHINESS STANDARDS
AVIS
CERTIFICAT SPÉCIAL DE NAVIGABILITÉ - MAINTENANCE PAR LE PROPRIÉTAIRE
CET AÉRONEF N’EST PAS CONFORME AUX NORMES DE NAVIGABILITÉ
INTERNATIONALES RECONNUES
(c) Each aircraft in respect of which a Special C of A - Owner-maintenance is in effect, and each engine, propeller and life-limited part installed on such an aircraft, has the letter “X”; permanently etched, engraved or stamped at the end of the model designation and serial number on the identification plate required by >CAR 201.01.
(amended 2002/03/01; no previous version)
(d) A person may have an aircraft type added to the list of aircraft eligible for a Special C of A - Owner-maintenance, by submitting a written request to the Minister, certifying that the aircraft type and model meet the requirements outlined in paragraph (6)(e).
(amended 2002/03/01; no previous version)
Information Note:
A written request must be submitted to the Director, Aircraft Maintenance and Manufacturing, Ottawa, Canada, certifying that the aircraft type and model meet the requirements outlined in paragraph (6)(e).
(e) An aircraft type and model may be included in Appendix H of this Standard, Aircraft eligible for a Special Certificate of Airworthiness - Owner-maintenance”, where:
(amended 2002/03/01; no previous version)
(i) the aircraft is of a type certified in accordance with Chapters 522 or 523 of the Airworthiness Manual, or an equivalent foreign standard;
(ii) the aircraft type certificate does not authorize more than four occupants;
(iii) the maximum certificated take-off weight (MCTOW) of the aircraft does not exceed 1,814 kg (4,000 pounds);
(iv) the aircraft is of a type and model that has not been manufactured during the 60 months preceding the date of application;
(v) fewer than 10% of Canadian aircraft of the type and model concerned are operating in Canadian commercial air service at the time of application;
(vi) the aircraft type and model is powered by a single, normally aspirated, piston engine, and is unpressurized; and
(vii) except for gliders, powered gliders or aircraft with airframes of wooden construction, the aircraft type and model has a fixed landing gear and a fixed pitch propeller.
Re: FAA and Owner Maintenance
Thanks for sharing.
I've been tempted on occasion to put my Piper Tomahawk into the O-M category but I really enjoy flying in the USA and don't want to kill the resale value of the aircraft. Not that it has much at this point anyways.
I was at the Arlington Fly In this year and there was an absolutely gorgeous award winning Stinson 108 there. The plane had the O-M placard on the side. The FAA was at the Arlington fly in as there was an incident with a Cessna 172 departing the runway without flying. Some said they wandered the entire flight line looking at various aircraft however I'm pretty sure the Stinson flew home. They obviously weren't really looking for trouble as this guy would've had to truck his plane home if they were.
There is a memo / bulletin that was sent to all FSDO's strictly forbidding ferry permits being issued to any TC O-M aircraft.
I have to wonder if the FAA's fear of the owner maintenance category doesn't have more to do with job preservation than safety.
I still don't understand why an experimental/homebuilt in Canada can be maintained by the owner (incl annual insp's) but the same category a/c in the USA requires an A&P to sign a "condition inspection". Essentially an A&P can sign an annual on a homebuilt but can't do an inspection on a Cessna 172 without being an IA. A lot of things don't make sense in aviation.
I've been tempted on occasion to put my Piper Tomahawk into the O-M category but I really enjoy flying in the USA and don't want to kill the resale value of the aircraft. Not that it has much at this point anyways.
I was at the Arlington Fly In this year and there was an absolutely gorgeous award winning Stinson 108 there. The plane had the O-M placard on the side. The FAA was at the Arlington fly in as there was an incident with a Cessna 172 departing the runway without flying. Some said they wandered the entire flight line looking at various aircraft however I'm pretty sure the Stinson flew home. They obviously weren't really looking for trouble as this guy would've had to truck his plane home if they were.
There is a memo / bulletin that was sent to all FSDO's strictly forbidding ferry permits being issued to any TC O-M aircraft.
I have to wonder if the FAA's fear of the owner maintenance category doesn't have more to do with job preservation than safety.
I still don't understand why an experimental/homebuilt in Canada can be maintained by the owner (incl annual insp's) but the same category a/c in the USA requires an A&P to sign a "condition inspection". Essentially an A&P can sign an annual on a homebuilt but can't do an inspection on a Cessna 172 without being an IA. A lot of things don't make sense in aviation.
Re: FAA and Owner Maintenance
I find this guys ad for a local plane sort of funny.
http://classifieds.castanet.net/details ... p/1647898/
If the plane is professionally maintained then why is it O-M ?
http://classifieds.castanet.net/details ... p/1647898/
If the plane is professionally maintained then why is it O-M ?
Re: FAA and Owner Maintenance
Some of you seem to be confusing what O-M can offer with what people actually do.
An O-M aircraft can be maintained to the same standards as a certified aircraft should one so desire. Of course, I'm not sure what the point would be ... less paperwork, but that's about it.
More importantly, it offers flexibility when and where one feels its appropriate. Hard to get parts, small parts that are just too expensive, some stuff that actually contributes to safety but is kept priced out of certified installations, and more.
That new Bendix/King AOA indicator for the experimentals? I'd love to throw that on ... a Dynon EFIS, or Garmin G3X with weather and so on, for a tenth of the price of certified avionics? yes please!
I'd probably keep using my AME anyways, but at least the constant fear of the 1000$ small fix via STC (because the original certified parts no longer exist) would be lifted off my shoulders ... (Like the shimmy dampener on my PA-28 ... man i hope mine keeps on lasting ...)
I personally at least wouldn't look at it as a license to do shoddy work, just as a way to gain more freedom, have more options.
An O-M aircraft can be maintained to the same standards as a certified aircraft should one so desire. Of course, I'm not sure what the point would be ... less paperwork, but that's about it.
More importantly, it offers flexibility when and where one feels its appropriate. Hard to get parts, small parts that are just too expensive, some stuff that actually contributes to safety but is kept priced out of certified installations, and more.
That new Bendix/King AOA indicator for the experimentals? I'd love to throw that on ... a Dynon EFIS, or Garmin G3X with weather and so on, for a tenth of the price of certified avionics? yes please!
I'd probably keep using my AME anyways, but at least the constant fear of the 1000$ small fix via STC (because the original certified parts no longer exist) would be lifted off my shoulders ... (Like the shimmy dampener on my PA-28 ... man i hope mine keeps on lasting ...)
I personally at least wouldn't look at it as a license to do shoddy work, just as a way to gain more freedom, have more options.
Re: FAA and Owner Maintenance
The discussion about the merits of O-M has been great. I'll quote myself in order to shilt the focus a bit more back to my original theme,
The FAA is going to take the theme of our great program, and use it as the basis for their next great program, which will much more broad and enabling than ours, and we're going to look across the boarder with envy, then wish TC would expand our O-M to capture a much greater portion of our fleet.
Congratulations to the FAA for their initiative, while thousands of the GA aircraft in Canada are left by the side of the road, and remain in an overly burdensome regulatory system. What you will see will be a greater choice of "new" products available in the US, which will be aimed at this new class of aircraft, and they will not be eligible for use on nearly all Canadian aircraft - and we inspired this!
It's time to group together and go to TC, and ask that TC keep regulatory pace with the FAA on this, so Canadian owners of most private GA aircraft can benefit from the theme of the program we started, at least as well as the US owners!
The FAA has used Canadian data to conclude that O-M is a safe, and indeed safer model for operation of private GA aircraft. That is huge! Here in Canada, a few hundred owners take advantage of a hard won initiative, and operate their aircraft with a reduced regulatory oversight, and therefore cost - and they are doing it with greater safety! And the FAA has figured this out!the forgoing passage is a clear pointer that O-M is safe, and the higher level of regulatory oversight on this group of aircraft is not at all contributing to greater safety than O-M. Canada needs to adopt this simplified maintenance model for a very much greater portion of the fleet,
The FAA is going to take the theme of our great program, and use it as the basis for their next great program, which will much more broad and enabling than ours, and we're going to look across the boarder with envy, then wish TC would expand our O-M to capture a much greater portion of our fleet.
Congratulations to the FAA for their initiative, while thousands of the GA aircraft in Canada are left by the side of the road, and remain in an overly burdensome regulatory system. What you will see will be a greater choice of "new" products available in the US, which will be aimed at this new class of aircraft, and they will not be eligible for use on nearly all Canadian aircraft - and we inspired this!
It's time to group together and go to TC, and ask that TC keep regulatory pace with the FAA on this, so Canadian owners of most private GA aircraft can benefit from the theme of the program we started, at least as well as the US owners!
Re: FAA and Owner Maintenance
Meanwhile COPA is too busy with sacking its own board members.
But aren't we looking just a bit too far ahead about what the FAA might or might not do?
But aren't we looking just a bit too far ahead about what the FAA might or might not do?
Re: FAA and Owner Maintenance
Yes, COPA is a shadow of its former self. COPA of old deserves a lot of credit for many initiatives, including O-M, a jewel in COPA's now tarnished crown.
In the mean time, it's not possible to look too far ahead when it comes to regulatory change. Advanced thinking, and being prepared will keep us in step with the FAA, who are now positioned to pass us on our own initiative.
Each advancement starts with something, other than sitting on our hands, 'cause it's too early to promote change. COPA is not going to help with this, their too busy pointing fingers within the organization. I have emailed TC to remind them of the effect on our industry should we loose pace with the FAA on this. I did this just as I petitioned against the requirements for noise compliance, and limits to fixed wing external loads, but it's going to take more than just a few voices....
In the mean time, it's not possible to look too far ahead when it comes to regulatory change. Advanced thinking, and being prepared will keep us in step with the FAA, who are now positioned to pass us on our own initiative.
Each advancement starts with something, other than sitting on our hands, 'cause it's too early to promote change. COPA is not going to help with this, their too busy pointing fingers within the organization. I have emailed TC to remind them of the effect on our industry should we loose pace with the FAA on this. I did this just as I petitioned against the requirements for noise compliance, and limits to fixed wing external loads, but it's going to take more than just a few voices....
Re: FAA and Owner Maintenance
Absolutely!May I suggest we form AvCanadOPA?
Where shall we begin? Ask Mods for a new forum....?
Re: FAA and Owner Maintenance
"The FAA has used Canadian data to conclude that O-M is a safe, and indeed safer model for operation of private GA aircraft. That is huge! Here in Canada, a few hundred owners take advantage of a hard won initiative, and operate their aircraft with a reduced regulatory oversight, and therefore cost - and they are doing it with greater safety! And the FAA has figured this out!"
Indeed! I've got the document open at home, the references to the "canadian owner maintenance category" are quite numerous ... Good TC and COPA and everyone else that took some risks and got this category created, and created the opportunity to get data on this model in the first place.
Now I'm curious about putting my plane in O-M, but maybe I'd wait for the Part 23 revisions to be complete, see what the FAA comes up with. The FAA has until Dec 2015 IIRC, and who knows how long from TC to follow up and match what the FAA does, if they do it at all ... but since this is a rather global effort, I'd hope TC will be in step with the FAA.
The FAA does mention that they would bring some improvements to the Canadian model of O-M ... I haven't yet found whether they detail what those improvements might be in the document, gonna keep reading ...
"This section will summarize the ARC’s recommendation to implement a Primary Non‐Commercial
Category (See Appendix G for complete paper) that is similar to the Canadian Owner Maintenance
Category, but with some significant safety enhancements to address some concerns with that program."
Indeed! I've got the document open at home, the references to the "canadian owner maintenance category" are quite numerous ... Good TC and COPA and everyone else that took some risks and got this category created, and created the opportunity to get data on this model in the first place.
Now I'm curious about putting my plane in O-M, but maybe I'd wait for the Part 23 revisions to be complete, see what the FAA comes up with. The FAA has until Dec 2015 IIRC, and who knows how long from TC to follow up and match what the FAA does, if they do it at all ... but since this is a rather global effort, I'd hope TC will be in step with the FAA.
The FAA does mention that they would bring some improvements to the Canadian model of O-M ... I haven't yet found whether they detail what those improvements might be in the document, gonna keep reading ...
"This section will summarize the ARC’s recommendation to implement a Primary Non‐Commercial
Category (See Appendix G for complete paper) that is similar to the Canadian Owner Maintenance
Category, but with some significant safety enhancements to address some concerns with that program."
Re: FAA and Owner Maintenance
3.3.5.1 Primary Non‐Commercial Category Recommendation
Applicability
The owner of a fixed wing, non‐ turbine powered part 23 aircraft or part 23 glider, 20 years or older,
may elect to redesignate their aircraft as a Primary Non‐Commercial.
Privileges
1. Aircraft in this category can be maintained by the owner with a repairperson’s certificate, similar
to currently established procedures for LSA aircraft repairpersons.
2. Replacement or alteration parts should be appropriate for aircraft use; however, such parts
need not be PMA/TSO authorized.
3. Owners can alter their own aircraft without the requirement for FAA approved data; however,
some alterations may require “phase 1” flight testing similar to Experimental Amateur Built
(EAB) requirements.
Limitations
1. Primary Non‐Commercial Category Aircraft are required to observe the FAA Approved Aircraft
Flight Manual Operational Limitations and/or required placard limitations established for the
Standard Category.
2. Aircraft cannot be used to carry persons for hire, this includes aircraft rental, but allows an
owner to receive flight instruction in their own aircraft.
3. Airworthiness Directives are only applicable as currently allowed for EAB.
4. Aircraft owners must maintain a list in the aircraft logbook of all applicable ADs and their
compliance status. This list will be used to highlight the owners’ awareness of the ADs existence
and document their choice of compliance. This list will also be used to facilitate the conversion
of the aircraft back to normal category.
5. Aircraft owners must maintain a list in the aircraft logbook of all alterations performed that are
not FAA approved and all non PMA/TSO parts installed. This list will be used to facilitate the
aircraft conversion back to normal category.
6. Incomplete or fraudulent maintenance logbook entries result in the revocation of the aircraft’s
standard airworthiness certificate.
Requirements
1. Before original conversion, the aircraft must have a current annual inspection – all applicable
ADs must be complied with at the current annual inspection.
2. Airplane owners must either add the prefix of “NC” to the aircraft registration number or affix a
“Non‐Commercial” placard readily visible to all passengers.
3. The aircraft must have a yearly condition inspection by an A&P mechanic certifying that the
aircraft is “in condition for safe operation.”
4. Upon transfer of aircraft ownership, the Non‐Commercial Airworthiness Certificate must be
reissued in the new owner’s name.
Conversion Back to Normal Category
1. Aircraft operated in the Non‐Commercial type certification class would be dual certificated in
both the Normal and Non‐Commercial categories, as is commonplace for Restricted Category
aircraft.
2. Aircraft in the Non‐Commercial TC category can be operated in the Standard Category, provided
the aircraft meets it type design data including compliance with all ADs, removal of all Non‐
PMA/TSO parts and replacement with certified units and the removal of all non‐certified
alterations.
3. The conversion can be accomplished by an Inspection Authority (IA) mechanic with a complete
and thorough annual inspection and logbook audit. Upon successful completion, the aircraft
could be operated under its Standard Airworthiness Certificate. The procedure is very common
with Restricted Category aircraft and proven to be safe and successful.
Applicability
The owner of a fixed wing, non‐ turbine powered part 23 aircraft or part 23 glider, 20 years or older,
may elect to redesignate their aircraft as a Primary Non‐Commercial.
Privileges
1. Aircraft in this category can be maintained by the owner with a repairperson’s certificate, similar
to currently established procedures for LSA aircraft repairpersons.
2. Replacement or alteration parts should be appropriate for aircraft use; however, such parts
need not be PMA/TSO authorized.
3. Owners can alter their own aircraft without the requirement for FAA approved data; however,
some alterations may require “phase 1” flight testing similar to Experimental Amateur Built
(EAB) requirements.
Limitations
1. Primary Non‐Commercial Category Aircraft are required to observe the FAA Approved Aircraft
Flight Manual Operational Limitations and/or required placard limitations established for the
Standard Category.
2. Aircraft cannot be used to carry persons for hire, this includes aircraft rental, but allows an
owner to receive flight instruction in their own aircraft.
3. Airworthiness Directives are only applicable as currently allowed for EAB.
4. Aircraft owners must maintain a list in the aircraft logbook of all applicable ADs and their
compliance status. This list will be used to highlight the owners’ awareness of the ADs existence
and document their choice of compliance. This list will also be used to facilitate the conversion
of the aircraft back to normal category.
5. Aircraft owners must maintain a list in the aircraft logbook of all alterations performed that are
not FAA approved and all non PMA/TSO parts installed. This list will be used to facilitate the
aircraft conversion back to normal category.
6. Incomplete or fraudulent maintenance logbook entries result in the revocation of the aircraft’s
standard airworthiness certificate.
Requirements
1. Before original conversion, the aircraft must have a current annual inspection – all applicable
ADs must be complied with at the current annual inspection.
2. Airplane owners must either add the prefix of “NC” to the aircraft registration number or affix a
“Non‐Commercial” placard readily visible to all passengers.
3. The aircraft must have a yearly condition inspection by an A&P mechanic certifying that the
aircraft is “in condition for safe operation.”
4. Upon transfer of aircraft ownership, the Non‐Commercial Airworthiness Certificate must be
reissued in the new owner’s name.
Conversion Back to Normal Category
1. Aircraft operated in the Non‐Commercial type certification class would be dual certificated in
both the Normal and Non‐Commercial categories, as is commonplace for Restricted Category
aircraft.
2. Aircraft in the Non‐Commercial TC category can be operated in the Standard Category, provided
the aircraft meets it type design data including compliance with all ADs, removal of all Non‐
PMA/TSO parts and replacement with certified units and the removal of all non‐certified
alterations.
3. The conversion can be accomplished by an Inspection Authority (IA) mechanic with a complete
and thorough annual inspection and logbook audit. Upon successful completion, the aircraft
could be operated under its Standard Airworthiness Certificate. The procedure is very common
with Restricted Category aircraft and proven to be safe and successful.
Re: FAA and Owner Maintenance
I wish they would remove this part
"3. The aircraft must have a yearly condition inspection by an A&P mechanic certifying that the
aircraft is “in condition for safe operation.”
I also hope that this means that Canadian O-M aircraft will be permitted to fly into the USA.
"3. The aircraft must have a yearly condition inspection by an A&P mechanic certifying that the
aircraft is “in condition for safe operation.”
I also hope that this means that Canadian O-M aircraft will be permitted to fly into the USA.
Re: FAA and Owner Maintenance
I agree on both counts!
I suspect this condition inspection would be pretty lightweight compared to a typical certified annual however, and note an A&P can do it instead of an IA ...
I suspect this condition inspection would be pretty lightweight compared to a typical certified annual however, and note an A&P can do it instead of an IA ...
-
The Weasel
- Rank 3
- Posts: 100
- Joined: Wed Oct 21, 2009 9:53 pm
Re: FAA and Owner Maintenance
I don't quite understand this notion in aviation to cheap out on maintenance and avoid paperwork as much as possible. I guess some people think of airplanes as mere pickup trucks that happen to fly in the air. Maybe they've never seen an accident or seen the costs involved in litigation, and so they think "it'll never happen to me". I know people who's boat maintenance records are more comprehensive than some aircraft records, but I guess there's also boats that cost a heck of a lot more than your average GA Cessna.Big Pistons Forever wrote: In any case owner maintenence on certified aircraft happens all the time. Nothing get put in the logbook and life goes on. The increasing regulatory burden on maintenence providers, with absolutely no credible justified evidence based safety case is rapidly driving more and more maintenence underground.
I'd also wonder about this apparent safety record of OM aircraft. I suspect there's far less risky flying going on, like pushing weather limits, flying in mountains, float ops, low-level utility ops, etc, that probably helps the safety numbers.
