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Transport Canada - Aviation Safety Letter Maintenance And Certification - ISSUE 4/2009

Maintenance And Certification - ISSUE 4/2009

The Authorized Release Certificate Goes Under the Microscope

by Brad Taylor, Civil Aviation Safety Inspector, Maintenance and Manufacturing, Standards, Civil Aviation, Transport Canada

This article focuses on the recent changes to the Canadian Authorized Release Certificate (hereinafter referred to as the “certificate”), formerly known as form number 24-0078, and recently reborn as FORM ONE. Canadian Aviation Regulation (CAR) Standard 571, Appendix J, was published on December 30, 2008, resulting in the first major change to the certificate in years. While the changes seem significant at first glance—and some of them are—the general use and purpose of the document have changed very little. The scope of this article will be limited to use of the certificate under CAR 571 to keep the discussion focused on issues related to maintenance release.

What is driving the change?
Aviation business has become “globalized,” with manufacturers and operators crossing physical, political, regulatory and cultural barriers in order to meet their customers’ expectations. As the aviation industry grows, it becomes more apparent that in order for businesses to function, they need to establish standards to facilitate communication and commerce. Transport Canada Civil Aviation (TCCA), the U.S. Federal Aviation Administration (FAA) and the European Aviation Safety Agency (EASA) have identified the need to establish standards at key intersections between the three regulatory systems. The common goal for all has become to standardize certain areas of their regulations and harmonize their goals and objectives to allow for improved safety and future prosperity of the aviation industry. The certificate was identified as one of the key areas for improvement to ease the movement of new and repaired parts between countries and regulatory systems.

What does the certificate represent?
The certificate conforms to a standardized, internationally recognized format for the release of both new and used (maintained) aeronautical products (also referred to as “items” or “parts”). Proper and appropriate use of the document—be it a 24-0078 form, FAA 8130-3 form, EASA Form 1 or Canada’s new FORM ONE—sends a message to aviation professionals throughout the industry. It is a clear indication that the part or parts have been maintained in accordance with standard industry practices. A properly completed document will give the installer a comprehensive picture of the condition of the part and the work that has been performed on it.

What has changed?
The new Appendix J has changed the certificate from an official Transport Canada form to a template, allowing more flexibility while establishing the mandatory elements to meet CAR Standard 571.10. There have also been some changes in the data blocks in terms of content, terminology and persons authorized to sign. Let’s take a closer look at these changes.

Block 9 “eligibility” has been eliminated.

Block 9 was removed, as it was determined to serve no useful purpose and was cause for concern to some when their specific aircraft type was not listed. Some operators felt that the certificate represented an authority to install the part on their aircraft when they should have been referring to their type certificate, illustrated parts catalogue, or other instructions for continued airworthiness (ICA) issued by the manufacturer. Removing this feature from the certificate reduces the possibility of error by the installer, and reinforces best practices by encouraging use of the manufacturer’s ICA.

Block 11 status/work terminology has changed.

Terminology was changed in an effort to standardize with EASA’s terms and definitions. The only term that changed was “inspected/tested.” It is important to note that the intent of the new term is NOT to insist that if an inspection is certified, it must also be supported with a test. The new term allows for certification of an inspection, a test, or both. The details should appear in Block 12. The complete term “inspected/tested” must be used even if one of the actions was not carried out. Remember that inspections of aeronautical parts must always be carried out and certified in accordance with approved or acceptable data of some kind. Attesting that a general receiving inspection was conducted would not be subject to a maintenance release and, as such, could not be certified with an authorized release certificate.

Block 14b requirements have changed.

CAR Standard 571, Appendix J, states, “Only persons specifically authorized by the certificate holder in accordance with CAR 573 are permitted to sign this block.” This means that you must be working under the authority of an approved maintenance organization (AMO) to make a maintenance release on the new FORM ONE. This is a significant change from the previous requirement!

What has not changed?
What is referred to as the “look and feel” of the certificate has not changed. This means that it should not be a challenge for industry to adapt, and global acceptance should be unchanged from form number 24-0078. While the certificate has seen some minor changes, some unacceptable issues still exist.

Use of the term “overhaul” has not changed with the release of the new CAR, yet use of it remains an issue in certain areas of the business. It is generally accepted that if an AMO performs all the functions stated in the CARs definition of “overhaul,” they are within their rights to state that the product was “overhauled.” Technically this may be correct, but problems arise when we are working on products for which no overhaul criteria exists. An AMO may be tempted to release a product as “overhauled,” and in doing so they enhance the value of the product in the eyes of the industry. The product is really only repaired and tested, as no overhaul criteria has been published by the manufacturer. The solution to the problem is to only use the term “overhaul” if the product has been reworked and tested in accordance with the manufacturer’s overhaul instructions. If no such documentation exists, the product cannot be overhauled!

What about over-tagging?
There have been numerous questions and concerns submitted from industry regarding over-tagging a certificate—what is it and why is it unacceptable? Over-tagging occurs when someone receives a repaired part with a completed certificate and proceeds to write a new certificate under their company name. There are various justifications given for this activity, including internal process and document flow, as well as hesitance to reveal one’s sources. Regardless of the reason for the activity, it does not conform to the regulations. The organization responsible for performing the maintenance activity needs to be the one responsible and accountable for the certification of the work. How can an organization be responsible if they had no control over the process and quality control involved with the activity? If a second organization takes responsibility for the work, they break the traceability between the installer and the repairer of the part.

authorized-release-form
Sample form taken from CAR Standard 571, Appendix J
Click on image to open PDF

Bumps on the road of change
Everyone agrees that change is necessary, but managing change such that all parties involved are well informed and prepared remains the greatest challenge in any organization.

Originally, the certificate was an official form (24-0078). The 24-0078 form was internationally recognized by foreign regulatory authorities in agreements such as the EASA Administrative Arrangement on Maintenance (AAM). These arrangements allowed for acceptance of the 24-0078 form by foreign operators, and provided them with guidance material for its acceptance and use.

With the release of the new Appendix J, Transport Canada is harmonizing the new Canadian FORM ONE template with that of the other regulatory authorities. Canadian organizations have the opportunity to make the transition from the 24-0078 form to the new FORM ONE template, but problems have occurred when Canadian AMOs have sent the new FORM ONE to EASA customers. The issue is a result of the AAM not being revised to recognize the new FORM ONE at the same time as Transport Canada published the new Appendix J. Until such time as the AAM is revised, the 24-0078 form remains the means for Canadian AMOs to certify and ship products to EASA customers.

This brings us to the question currently occupying the thoughts of many Canadian AMOs. How can we continue to use the old form 24-0078 when the CARs Standard has been revised, and the expectation is that we should be adopting the new FORM ONE? The answer lies in the CARs themselves.

  1. CAR 571.10 establishes the requirements for a maintenance release to be further detailed in the standard.

  2. CAR Standard 571.10 details the key elements that must be contained in any maintenance release, and it suggests that the requirements could be met with the use of the template found in Appendix J.

  3. Appendix J gets into the specifics regarding the FORM ONE template and its use.

It seems simple when you follow the progression, but what if you want to use the 24-0078 form to certify parts intended for EASA customers? There is some flexibility built into the Standard, as long as an AMO meets the intent of the regulation while ensuring that all the elements of a maintenance release are met. CAR Standard 571.10(2)(d) states:

“Where a maintenance release is made using an ‘Authorized Release Certificate’ (Form One), Appendix J would normally apply.”

The key word in the Standard quoted above is “normally.” If an AMO determines that they are going to make a maintenance release using the 24-0078 form, they are not restricted from doing so as long as the elements stated in the Standard are met and the guidance material to use the document is followed.

Note: Instructions for use of the 24-0078 form are still available on the Web by clicking on the “previous version” link located just below the title:

Appendix J
Authorized Release Certificate

(Refer to section 571.10 of this standard)
(amended 2008/12/30; previous version)

If an AMO determines that adopting the new FORM ONE is the correct option for its business, it can do so by following the guidance material found in the new version of Appendix J, and as long as it has updated its maintenance policy manual (MPM) to recognize the new process.

In closing
By the time this article is published, many changes may have taken place. The one axiom you can count on when moving aeronautical products between different regulatory systems is that you must meet the requirements of the importing country if you expect to have a successful transaction. It is your responsibility to research and understand these requirements before you ship.

Note: On June 30, 2009, TCCA received a letter from EASA stating that as an interim measure EASA considers that the updated TCCA FORM ONE template can be deemed to meet the requirements for the previous form 24-0078. This will allow CAR Part V, Subpart 73 approved manintenance organizations, who also hold an EASA 145 approval, to transition to the new TCCA authorized release certificate template. EASA has also committed to inform their stakeholders of their acceptance, which should ensure the acceptance of the new TCCA FORM ONE template when used as part of an EASA 145 approval.



Inspection and Maintenance of Flush-Mounted Fuel Caps

The following is a Safety Information Letter from the Transportation Safety Board of Canada (TSB).

On September 17, 2008, a privately operated Beechcraft Baron 58 departed Medicine Hat, Alta., on a VFR flight to Fort St. John, B.C. Immediately after takeoff, the right engine (Teledyne Continental IO-520-C) surged and lost power. Power could not be restored and the engine was subsequently secured. The aircraft was unable to maintain level flight with the left engine operating at full power, and it descended and crashed into the South Saskatchewan River several miles from the airport at 19:25 Mountain Daylight Time (MDT). (See Photo 1.) The pilot and two passengers sustained minor injuries; two additional passengers sustained serious injuries. The aircraft was substantially damaged.

insp_maint-beech-58-baron
Photo 1: This Beech 58 Baron forced landed in
South Saskatchewan River after the right engine lost power.

The right engine was removed and successfully run on a test stand. Subsequent visual inspection and flow check of the related fuel injection components, and detailed examination of the airframe fuel system, did not reveal any system abnormalities that would have precluded normal function. While the reason for the loss of power was not identified during the assessment of the occurrence, indications of water contamination within the fuel system were noted.

Prior to the engine test run, a small amount of water was recovered from the right-engine-driven fuel pump. The water sample was compared to water from the South Saskatchewan River and the properties were found to be different. Journey logbook records indicated the right engine experienced a power loss during a flight in November 2006—approximately 79 hr prior to the accident—due to water in the fuel system.

One potential pathway for free water, in the form of rain or wash water, to enter aircraft fuel tanks is through fuel caps that do not seal properly. The aircraft was fitted with two standard, flush-mounted fuel caps manufactured by Shaw Aero Devices1 (see Photos 2 and 3.) This type of fuel cap is installed in numerous models of small aircraft. The cap seals consist of two O-rings, one around the outer circumference of the cap and one on the shaft of the locking mechanism axle. Water leakage was detected post-accident during in situ testing of the fuel caps, with the fuel caps secured in the filler openings. The handle bearing plates also showed excessive wear and the caps had parts missing.

insp_maint-fuelcap-top
Photo 2: Top view of flush-mounted fuel cap
insp_maint-fuelcap-bottomPhoto 3: Bottom view of flush-mounted fuel cap

The fuel caps were forwarded to the manufacturer, where they were tested in accordance with Shaw Aero Devices standard acceptance test procedures for fluid filler caps and adapters. The procedure required the fuel caps to be mounted in a test fixture and 5 to 25 psi pressure to be applied to the underside. No leakage is permitted. At 0.5 psi, both caps leaked past the axle and handle assemblies. (See Photo 4.) The caps were disassembled and inspected. The O-rings on the axle shafts in both caps were cracked and broken, and both axle shafts were corroded sufficiently to indicate long-term exposure to moisture. (See Photo 5.)

insp_maint-fuelcap-leak
Photo 4: Fuel caps on test potnote air bubbles above cap
in middle of picture that indicate leakage.
insp_maint-o-ring
Photo 5: Note deteriorated O-ring and corrosion on axle shaft

Neither the cap manufacturer, nor the aircraft manufacturer provides written guidelines for inspection and maintenance of this type of fuel cap. At least one other small aircraft manufacturer has developed detailed guidelines for inspection and maintenance of flush-mounted fuel caps. The Federal Aviation Administration’s (FAA) Advisory Circular AC 43.13-1B, titled Acceptable Methods, Techniques and Practice—Aircraft Inspection and Repair, is a primary maintenance reference to be used when manufacturers do not supply repair or maintenance instructions. AC 43.13-1B simply states that fuel cap O-rings are to be inspected to determine that they are in good condition. Furthermore, Shaw Aero Devices considers the fuel caps to be a “return to vendor” item if repair, including O-ring replacement, or overhaul is required.

As shown by this occurrence, the lack of specific original equipment manufacturer inspection and maintenance guidelines for flush-mounted fuel caps can result in discrepancies such as deteriorated cap seals (O-rings) to remain undetected, thereby increasing the risk of water entering aircraft fuel cells, which can ultimately contribute to loss of engine power. 

1Shaw Aero Devices, Inc. was acquired by Parker Hannifin Corporation in November 2007.



Locked Carbon Disc Brake Due to Moisture Absorption and Freezing Lead to Tire Failure

On January 28, 2008, following an extended period of heavy rain, a Bombardier BD700 Global Express departed Van Nuys, Calif., at 2240 UTC from a dry runway for a long-range flight to London Luton Airport, U.K. The flight was without incident and the aircraft arrived at Luton at 0808 UTC on the following day, January 29, 2008.

Shortly after a normal touchdown on Runway 26, the crew became aware of a rumbling noise, which they identified as a burst tire. The aircraft captain applied normal braking and 15 s after touchdown, the No. 2 and No. 3 hydraulic system low-pressure engine indication and crew alerting system (EICAS) messages displayed. The pilot brought the aircraft to a stop on the runway using normal brakes and, as fire vehicles approached, shut down both engines.

During the landing roll, the left inboard main landing gear tire suffered a failure resulting from an initially locked wheel. This tire failure caused extensive damage to the flight control system. The Air Accidents Investigation Branch of the United Kingdom (AAIB) investigated this occurrence and issued AAIB Bulletin 12/2008, which is available at www.aaib.gov.uk/sites/aaib/cms_resources/Bombardier%20BD700%20Global%20Express,%20VP-CRC%2012-08.pdf (English only).

Water absorption by carbon brakes
Prior to departure, the airplane was exposed to a significant amount of rainfall and the carbon disc brakes were soaked by water. The brake manufacturers confirmed that the materials of the rotors and stators, both being carbon-type structures, are porous and slightly absorbent. After extensive water soaking, they require a prolonged period of exposure to dry, warm conditions to ensure that full drying takes place.

Alternatively, significant braking action must be deliberately applied during taxiing before departure to ensure brake drying. It is important to be aware that, on this type, rainfall can cause wetting of the brakes even in light wind conditions when the brakes would normally be assumed to be sheltered by the wing structure. It is also important to be aware that the brakes remain saturated with water for a lengthy period after rainfall ceases and runways and taxiways become dry.

The flight data recorder (FDR) showed that only a brief and light application of the relevant brake took place during taxiing (at a speed of approximately 3 kt). Automatic brake application on the type then occurs for four seconds during retraction. The AAIB concluded that the contact faces of the brake stators and rotors of the brake unit in question remained both wet and in close proximity as the aircraft climbed and the temperature in the wheel bay cooled to a sub-zero level. The cruise took place at ambient temperatures below -25°C, which is presumed to have caused stationary and moving components to become firmly frozen together, leading to wheel locking and tire failure on landing. Application of sustained torque to the locked wheel, or some effect of the tire rupture process, presumably caused failure of the ice bond, allowing the wheel to rotate and the damaged tire section to flail and destroy areas of structure and critical aircraft systems.

Actions by the manufacturer
Following the occurrence, the manufacturer issued Advisory Wire AW700-32-0244 on March 19, 2008, containing operational and maintenance information to counter the problem of freezing of wet carbon brakes. The manufacturer later issued Advisory Wire AW700-32-0244, Revision 1, which includes additional information to the original Advisory Wire.

AAIB
AAIB Bulletin 12/2008 contained four aviation safety recommendations, one of which was addressed to Transport Canada:

Safety Recommendation 2008-073
It is recommended that the U.S. Federal Aviation Administration (FAA), the European Aviation Safety Agency (EASA) and Transport Canada (TC) raise awareness of the vulnerability of carbon brakes to freezing in flight following exposure to moisture on the ground, emphasising the significance of the slow drying rate of saturated brakes even in warm, low humidity conditions.

In addition to publishing this article in the Aviation Safety Letter, TC has issued Service Difficulty Advisory (SDA) AV 2008-08, dated December 2, 2008, in response to AAIB Safety Recommendation 2008-073. The purpose of this SDA is to inform Canadian operators and flight crews operating airplanes equipped with carbon disc brakes of the possibility of moisture absorption and subsequent freezing during flight, resulting in tire failure and damage to the airplane on landing due to a locked wheel brake. The full SDA can be found at: www.tc.gc.ca/CivilAviation/certification/continuing/Advisory/2008-08.htm



Fatigue Risk Management System for the Canadian Aviation Industry: Developing and Implementing a Fatigue Risk Management System (TP 14575E)

This is the fourth of a seven-part series highlighting the work of the Fatigue Risk Management System (FRMS) Working Group and the various components of the FRMS toolbox. This article briefly introduces TP 14575E, Developing and Implementing a Fatigue Risk Management System. Intended for managers, this comprehensive guide explains how to manage the risks associated with fatigue at the organizational level within a safety management system (SMS) framework. The complete FRMS toolbox can be found at www.tc.gc.ca/civilaviation/SMS/FRMS/menu.htm. —Ed.

The Aim of This Guide
This guide is designed for individuals who are responsible for managing fatigue risk at an operational level. You should already have completed the Fatigue Management Strategies for Employees (TP 14573E) workbook or equivalent, which provided information about the causes and consequences of fatigue, and included practical strategies for managing the impact of fatigue. Fatigue Management Strategies for Employees focused on reducing fatigue risk at the individual level. You should now be familiar with the risks associated with fatigue and the major contributors to increased fatigue levels (i.e., inadequate quality and/or quantity of sleep, time of day, and length of time awake). This guide explains how the risks associated with fatigue can be managed at the organizational level within a safety management system framework. You will learn how to implement fatigue risk management controls systematically within your organization.

Your Role
As an individual in a managerial or supervisory role you are accountable not only for managing your own fatigue levels but also the fatigue risk of employees within your organization and/or work unit. The tools and strategies presented in this guide have been developed to help you manage fatigue risk at various levels, ranging from ensuring compliance with legal and regulatory requirements to investigating and learning from accidents and incidents in the workplace. Managing fatigue-related risk in the organization is achieved using a fatigue risk management system (FRMS).

How to Use This Guide
This guide describes how an FRMS is best employed within an organization’s safety management system. This allows the risks associated with fatigue to be managed in a way similar to other hazards such as dangerous goods. An FRMS should be based on an internal risk assessment of the organization. This ensures that any fatigue management strategies being implemented are measured, appropriate, and targeted. There are several Canadian national standards for risk assessment, all of which clearly outline acceptable guidelines for risk management (e.g., CAN/CSA-Q850-971, CAN/CSAQ634-912).

The fatigue risk management system described in this guide provides your company and employees with a recognized process based on likelihood and consequence and the need to identify, understand, and control the workplace hazard. The resources and time required for implementing a fatigue risk management system will be determined by the relative risk identified during your risk assessment process.

There are six major aspects to an FRMS:

  1. Policies and Procedures:
    • Outline the commitment of organizational management to manage fatigue-related risk;
    • Detail the required procedures for managing fatigue at the operational level.
       
  2. Responsibilities:
    • List personnel responsible for FRMS design, implementation, and maintenance;
    • Document responsibilities of individual employees and work groups.
       
  3. Risk Assessment/Management:
    • Scheduled versus actual hours of work;
    • Individual sleep patterns;
    • Symptom checklists;
    • Error/incident reporting.
       
  4. Training:
    • Promote knowledge in the workplace about risks, causes, and consequences of fatigue;
    • Ensure employees understand and can apply fatigue management strategies.
       
  5. Controls and Action Plans:
    • Toolbox of methods used within the FRMS, including error reduction techniques (“fatigue proofing”);
    • Clear decision trees for managers and employees to use when fatigue has been identified as a risk.
       
  6. Audit and Review:
    • Documentation and data collection at regular intervals of how the FRMS works;
    • Review of the FRMS based on audit results.
       

We conclude this overview of TP 14575E by encouraging our readers to view the entire document on-line. Find it at www.tc.gc.ca/CivilAviation/SMS/pdf/14575e.pdf

 

This article was published by Transport Canada in TP 185E -. Reprinted with permission

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