TP 13158
Operators who submit Service Difficulty Reports (SDR) are not satisfied with the feedback they receive from Transport Canada. Typically, they receive only a notice that the SDR has been received with no indication of how often this SDR has been submitted or the action being taken by Transport Canada. Conversely, operators are not submitting SDRs for each occurrence, especially if they are experiencing continued difficulty with a specific part and manufacturer.
This may be as a result of the operators losing faith in the SDR system. For the system to work properly, the SDRs to be tracked and the service difficulty rectified, operators must submit an SDR for each occurrence and Transport Canada must follow up on the SDR and provide feedback to the operator. Commercial aircraft operators and Approved Maintenance Organizations (AMO) are subject to the mandatory SDR program required by Canadian Aviation Regulation (CAR) 591. Due to the number of changes brought about by the CARs, some operators or AMOs may be unaware of this requirement. Operators may not be aware that the data collected by the SDR program is available from regional and district Transport Canada offices or on the SDR Bulletin Board Service.
SR 1 - Recommend Transport Canada provide air operators with feedback about the status and action taken when an SDR is submitted.
IA 1 - Recommend air operators request follow-up of SDRs from their Transport Canada regional or district office.
SR 2 - Recommend Transport Canada verify that all air operators and Approved Maintenance Organizations are complying with the mandatory SDR program required by CAR 591.
IA 2 - Recommend air operators review their Maintenance Manuals to ensure compliance with CAR 591.
Aircraft Maintenance Engineers (AME) work long hours and often work shifts or at night when the aircraft are available. There are currently no limits to the amount of time an AME can work, unless the AME is also working as a pilot for an air operator. In that case, time spent conducting maintenance duties must be considered in the flight duty time limitations. Individuals who are fatigued can commit errors of omission that can have a negative impact on the airworthiness of the aircraft. These errors of omission have often been cited as a factor in the "chain of events" that led to an accident or incident. Regulation of AME duty times has been considered by Transport Canada in the past but it was decided that regulation could in some cases increase the risk of errors of omission. However, in response to the comments received, the Task Force believes it is timely for this issue to be the subject.
SR 3 - Recommend Transport Canada provide AMEs and air operators with information about fatigue, the effects of fatigue, and fatigue countermeasures.
IA 3 - Recommend air operators provide AMEs and apprentices with information about fatigue, the effects of fatigue and fatigue countermeasures and consider the negative effects of fatigue when assigning work and planning work schedules.
SR 4 - Recommend Transport Canada initiate a Canadian Aviation Regulation Advisory Council (CARAC) review to determine if AME duty times should be regulated, and if so, determine appropriate limitations.
IA 4 - Recommend air operators, air operator associations, AMEs and AME associations participate in or provide input to the CARAC AME duty time working group.
Currently there is no standard for initial or recurrent training required for Aircraft Maintenance Engineers nor a requirement for recording or reporting if training has occurred. An AME can work on an aircraft that he has had no experience on as long as his licence is valid for that class of aircraft.
SR 5 - Recommend Transport Canada develop a standard for initial and recurrent aircraft type training for Aircraft Maintenance Engineers.
Safety related information can be misinterpreted if it is difficult to understand. Notices to Aircraft Maintenance Engineers such as Service Bulletins (SB), Airworthiness Directives (AD) and all associated diagrams should be written simply and clearly.
SR 6 - Recommend Transport Canada ensure Service Bulletins (SB), Airworthiness Directives (AD) and associated diagrams are clearly written and understandable.
IA 6 - Recommend air operators submit an SDR to Transport Canada when they identify problems related to the legibility of SBs, ADs or associated diagrams.
Air operators find that Transport Canada's certification process for aircraft parts and supplemental type certificates (STC) is extremely lengthy. This delay in service is costly for operators who are waiting for the certification.
SR 7 - Recommend Transport Canada review its policies for certification of parts and STCs to reduce the length of time required for processing the approval.