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On the other side of the 337. what your client does when he gets a mod and how we can produce better mods to help him. John Aplin – Chief Engineer. A simple quiz. On receiving a mod, will your client : Curse that it has taken so long to approve? Tear his hair out at the size of the bill?
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On the other side of the 337 what your client does when he gets a mod and how we can produce better mods to help him John Aplin – Chief Engineer
A simple quiz On receiving a mod, will your client : • Curse that it has taken so long to approve? • Tear his hair out at the size of the bill? • Throw it in a nearby cupboard? • Follow the correct embodiment process?
How I got where I am • Just started Techair – Jan 2004 • Desperate for work! • Visiting client to prepare a mod • Client needed help to: • Update operations manual • Develop maintenance procedures for mods • Agreed to take on jobs
On the receiving end • What did I find? • Variable quality and quantity • Maintenance instructions • Flight Manual Supplements • Role equipment installation instructions • Reviewed CARs – determined applicable rules
Maintenance data 21.505 Form CAA 337 – approval of technical data …an applicant for the approval of technical data must… provide (4) for a product, component, or appliance to be changed in accordance with the data— (ii) adequate maintenance and operating data to ensure the product, component, or appliance can be properly maintained and operated…
Pilot maintenance - 1 43.51 Persons to perform maintenance (b) A person who holds a pilot licence with an appropriate type rating issued under Part 61 may perform the maintenance listed in Appendix A if the licence holder is— • appropriately trained; and • authorised by the owner or operator of the aircraft.
Pilot maintenance - 2 Appendix A — Pilot Maintenance Maintenance on aircraft by a person authorised in accordance with 43.51(b) may include (12) installation and removal of seats, doors, and role equipment provided— (i) the configuration of the aircraft with the particular equipment installed or removed has been approved; and (ii) the aircraft flight manual incorporates the necessary information for the safe operation of the aircraft with the equipment installed or removed, including weight and balance data for each configuration; and (iii) the applicable information for the installation and removal of the equipment is immediately available; and (iv) no special tooling, special equipment, or subsequent inspection is required:
Embodiment process Permanent modification • Mod installed • Conformity certified by IA - 337 box 7 signed • Aircraft log book Section 3 completed • Flight Manual Supplement inserted into AFM/RFM • ARA plus Annual/100-hr inspection
43.153 Review requirements (a) … each person performing an annual review of airworthiness for an aircraft shall, before certifying that the review has been carried out (2) ensure that any modifications and repairs conform to the applicable technical data listed in Appendix D to Part 21 Appendix C C.2 Inspections (b) The following items shall be inspected using the following criteria (10) each installed miscellaneous item that is not otherwise covered by this listing for improper installation and improper operation. ARA and inspections
Embodiment Summary • All OK for a permanent mod • (Provided there are maintenance instructions) • Now see how it works (or doesn’t) for role equipment • Use example of agricultural spray system
Installation – role equipment Three separate stages • Installation of fixed provisions by AME • Mechanical, electrical, pneumatic • Initial rigging and adjustment by AME • May be part of manufacturing process • Installation and removal by pilot • Instructions immediately available • Beware “removal is the reverse of installation”
Inspection – role equipment Typical ARA • Mod recorded in aircraft log book • System not installed – finding? • Is this an approved configuration? • How is system maintained? • How does IA know it has been maintained?
Observations • Helicopter operators will increasingly use role equipment to earn a living • Role equipment has special features in terms of: • Fixed provisions and removable items • Instructions for installation by pilots • Approved configurations • Availability of maintenance instructions • Evidence of conduct of maintenance
Conclusions • Remember who will read your data package • AME for mod installation • IA for conformity • Pilot for role equipment installation • Maintenance Controller for scheduling maintenance • AME for performing maintenance • IA for ARA, 100hr/annual • Imagine yourself on the other side of the 337