Thursday, 15 April 1999
Allan Frew
South Queensland Area Manager
Civil Aviation Safety Authority
C/- PO Box 13
Archerfield 4108
QLD
FAX: 3335 2632
RE: Recording of Maintenance Release times
Dear Allan
For many years I have been trying to get CASA to act on a perennial problem which is prevalent in many sectors of the industry, in particular private and aerial work operations.
Maintenance release times are not being recorded correctly, if at all.
Many entries are fraudulent
This practice is rife in aerial work – helicopter mustering and fixed wing ag.
Often quoted is a figure of 2 or 3 for 1 – meaning 100 hours is recorded for 2 or 3 hundred flown.
Most CASA FOI’s are aware of it – some think it is the CASA airworthiness officers function to carry out surveillance – others quote CASA as only being interested in Charter ops. In general, I am told that it’s in the too hard basket to do anything about as charter prevails.
From the lack of response, I also presume that most CASA FOI’s do not really appreciate the effect non recording has on finite life components, the legal aspect of airworthiness by non compliance with Certificate of Airworthiness certification requirements and the requirement to ground aircraft as unairworthy and to fit replacement parts when finite life times cannot be accurately determined.
My concern is that one day some innocent person will be killed through structural failure in an aircraft and one of the reasons will be that a culture has been allowed to develop in CASA and industry, through lack of education and enforcement, whereby very few people understand the engineering reasons for and vital importance of recording finite life times.
In accordance with CASA’s six point plan – Justice, Rules and Regulations, Enforcement (uniform, fair, consistent), Education and as the local CASA area manger, I would respectfully request that you please address this problem of non compliance ASAP, not only in SEQ but in all of Australia.
As an aside, one of my concerns is that, under freedom of information, there are now documents released which show that CASA know of this problem, are concerned about it, but have not acted. One document even states that when a number of aircraft were found without recording devices, they were unairworthy but it was too "“political" to ground an operator’s fleet.
These documents are in the hands of people who may rightfully use them for their own purpose in civil litigation cases. If CASA act now on recording of M/Release times before the public becomes aware, then surely it will have a feather in its cap which will play down any negative media.
I am available at any time convenient to you to discuss these matters further and to explain how the situation has developed to such a terrible state of affairs as at present.
Thank you for your consideration
Best regards
Tony Carmody
Associate Director
XXXXInternationalSafetyCollege
Caloundra Qld 4551