{"id":3147,"date":"2014-08-11T12:33:26","date_gmt":"2014-08-11T19:33:26","guid":{"rendered":"http:\/\/amumagazine.com\/?p=3147"},"modified":"2014-09-02T12:22:26","modified_gmt":"2014-09-02T19:22:26","slug":"composite-structure-and-the-house-of-commons","status":"publish","type":"post","link":"https:\/\/amumagazine.com\/?p=3147","title":{"rendered":"Composite Structure and the House of Commons"},"content":{"rendered":"

Preamble<\/strong>
\nI am providing this preamble to clarify the meanings of abbreviations that I use here. For those of you new to the aviation industry and\/or new to Canada, these abbreviations are all commonly used in the aviation industry and you may come upon them in your day-to-day work.<\/p>\n

AME: Aircraft Maintenance Engineer
\nAMO: Approved Maintenance Organization as approved by TC
\nATA: Air Transport Association
\nCAR: Canadian Aviation Regulation, which is a law of Canada
\nSMS: Safety Management System(s)
\nSTD: TC approved standard
\nTATC: Transportation Appeal Tribunal of Canada
\nTC: (or minister) indicates Transport Canada headquarters in Ottawa<\/p>\n

Below you will note that the BOLD denote a quotation. I do this in some cases because of the large amount of material that I quote. Please be aware of this as you read on.<\/strong><\/em><\/p>\n

On the subject of composites in aircraft structures, TC does have some specific documentation. Standard 573.02 AMO Certificates states:<\/p>\n

(8) Ratings in the Structure category are issued in respect of the repair or modification of structures of the following kinds:<\/strong>
\n(d) Composite\u2014A composite structure rating covers all repairs and modifications to composite structures, including any integral bonded metal members or fasteners. This rating also covers the repair of metal or wood sheathed laminated structures.<\/strong>
\nWork carried out under these ratings includes on-aircraft work where indicated in the appropriate limitations. Where on-aircraft work is authorized, the provisions of Subparts 571 and 573 of the CARs will apply to any person who is authorized to issue a maintenance release for work conducted on an aircraft.<\/strong><\/p>\n

That section of the standards goes on to define composites in TC\u2019s view:<\/p>\n

Information Note: The term \u201cComposite Structures\u201d means structures composed of plastic resin materials reinforced by non-metallic fibres. These include, but are not limited to graphite, aramid (kevlar), and glass fibre filaments. Metal-sheathed honeycomb is a sheet metal structure, whereas metal\/wood sandwich board is a wooden structure.<\/strong><\/p>\n

The TC sample AME Log Book with aircraft maintenance experience sample tasks includes the following:<\/p>\n

ATA:51 (Structures) – Composite repair.<\/strong>
\nSealing<\/strong>
\nPrepare metal\/wood\/composite surfaces for sealing<\/strong>
\nSelect\/mix and apply sealants to seams, joints and fasteners<\/strong>
\nComposite Structures – Composite Repairs<\/strong>
\nPerform sanding\/grinding routing of damaged area<\/strong>
\nPrepare damaged area by step\/taper standing<\/strong>
\nPerform fabrication of pattern for cutting cloth patches<\/strong>
\nPerform wetting-out of fabric with resin and cut out patches<\/strong>
\nPerform a lay-up repair ply\/plies using wet\/pre-preg cloth<\/strong>
\nPerform curing of repairs at room temperature<\/strong>
\nPerform curing of repairs with heat blankets\/oven<\/strong>
\nPerform check for delamination<\/strong>
\nPerform installation of inserts<\/strong>
\nPerform sanding\/priming and painting of repaired surface<\/strong>
\nComposite Fabrication<\/strong>
\nPerform fabrication of master model.<\/strong>
\nPerform removal of mould from master model.<\/strong>
\nPerform fabrication of cutting pattern for lay-up plies.<\/strong>
\nPrepare plies for wet\/pre-preg lay-up.<\/strong>
\nPrepare mould surface.<\/strong>
\nPerform curing of lay-up with heat blanket\/oven\/autoclave\/<\/strong>
\n\u00a0\u00a0\u00a0\u00a0 room temperature.<\/strong>
\nPerform check for improper bonding.<\/strong>
\nPerform trimming of excess from parts\/structure being<\/strong>
\n\u00a0\u00a0\u00a0\u00a0\u00a0 fabricated.<\/strong>
\nPerform sanding\/priming \/painting of fabricated parts.<\/strong><\/p>\n

For an AME applicant for the \u201cS\u201d Rating TC published their Study and Reference Guide \u2013 \u201cS\u201d Rating Technical Examinations. This guide lists the topics for the exam including the following:<\/p>\n

11.0 AIRCRAFT SHEET METAL, TUBULAR, WOOD AND COMPOSITE STRUCTURES<\/strong>
\n11.1 Sheet metal materials<\/strong>
\n11.2 Aircraft fabrics<\/strong>
\n11.3 Wood<\/strong>
\n11.4 Plastics, fiberglass and composite materials<\/strong>
\n16.0 COMPOSITE<\/strong>
\n16.1 Repairs and fabrication<\/strong>
\n16.2 Assessment methods, techniques and practices – Theory, application and inspection<\/strong>
\n16.3 Repair materials – Identification and application<\/strong><\/p>\n

TC also publishes advisory information in Airworthiness Notices (AN). Aircraft maintenance personnel need to be aware of these. AN AC012 addresses Aircraft Maintenance Training Programs for AMOs states:<\/p>\n

ACA should only be granted after the organization has confirmed that the licence holder has undergone appropriate training on the aircraft, engine or system types to be released. <\/strong>
\nAs well, AMO training policy should also include sufficient safeguards to ensure that individuals are properly trained in new technology where that is a factor affecting maintenance release privileges. Technology not previously experienced by the individual, such as … composite structures, need to be adequately addressed.<\/strong><\/p>\n

For those of you involved in design of composite repairs, TC Advisory Circular document AC 500-009 Composite Aircraft Structure will be of interest.<\/p>\n

Now for something completely different. AMU regular readers may have noticed that I may have taken the occasional opportunity to reproach the minister for TC\u2019s deficiencies and general malaise. In late May, I was asked to appear before a government of Canada committee and answer questions.\u00a0 No, it was not the RCMP or CSIS. It was an invitation to appear before the House of Commons Standing Committee on Transport, Infrastructure and Communities, on June 5. The topics to be addressed were the effects of SMS and aviation safety trends in Canada.
\nBeing your humble servant as I am, I was surprised.\u00a0 The committee allowed me 10 minutes to present my witness statement. They also allowed one and a half hours to answer questions from the members of parliament.\u00a0 To prepare, I condensed my opinions on SMS and on TC\u2019s approach to aviation safety into a 10-minute presentation. Here is the text of my presentation quoted from the Parliament of Canada web site:<\/p>\n

Thank you Chair, Honourable Members<\/strong>
\nMy name is Norman Chalmers, President of Pacific Airworthiness Consulting.<\/strong>
\nI have 47 years of experience in the business of aviation safety and aircraft airworthiness including 25 years in Transport Canada Civil Aviation (TCCA) in various positions including periods as acting Regional Manager.<\/strong><\/p>\n

Besides consulting I write a bi-monthly column for Air Maintenance Update Magazine, which is widely read in Canada and the United States of America. Today I limit my comments to Safety Management Systems (SMS) as implemented by Transport Canada Civil Aviation.<\/strong><\/p>\n

My position regarding Transport Canada SMS<\/strong>:<\/p>\n

SMS is a social engineering experiment on a huge scale with the Canadian aviation industry safety outcomes as the study objective and the travelling public as the victims. The long term consequences of these changes are unpredictable because Transport Canada SMS has no precedent or proven model.<\/strong>
\nSMS is a good idea, essentially the same as Total Quality Management.\u00a0 Safety Management Systems, if properly embraced by management and workers, can help companies improve themselves in many areas.<\/strong>
\nSMS is not a regulatory regime.\u00a0 It is essentially a philosophy invented by reductionist university professors who have studied and dissected disasters in the petrochemical industry (e.g. British Petroleum).\u00a0 (Reason, Hopkins, etc.)<\/strong>
\nSMS cannot successfully replace regulatory oversight.<\/strong>
\nSMS is a Transport Canada tactic to save money on employee costs including numbers and qualifications. <\/strong>
\nSMS is a Transport Canada tactic to avoid being sued in court for allowing unsafe aviation operations<\/strong>
\nSMS was sold to Canadians, you included, using scare tactics including using the widely distributed worldwide hull loss projections.<\/strong>
\nThe lawmakers of Canada have been negligent. They have ignored the warnings of Canada\u2019s best including Mr. Moshansky in this Committee\u2019s 2007 report.<\/strong>
\nCanada has one of the safest transportation systems in the world as a result of the corporate safety culture of companies and people working in the industry. It is also a result of effective regulatory requirements.<\/strong>
\nTransport Canada has started to dismantle those requirements.<\/strong>
\nSMS implementation by Transport Canada will do long term and enduring damage to aviation safety in Canada<\/strong>
\nIt will soon be too late to prevent that damage. Canada will face a very difficult time rebuilding the safety infrastructure that is now being destroyed.<\/strong>
\nPublic opinions regarding \u201csafe aviation\u201d and \u201csafety\u201d do not coincide with Transport Canada\u2019s definition and are not supported by Transport Canada actions.<\/strong><\/p>\n

SMS and PVI implementation<\/strong>:<\/p>\n

SMS is not an \u201cadditional layer\u201d as it was sold to your 2008 House of Commons Committee. It was never planned as an additional layer. At the same time as those individuals were telling that Commons Committee that SMS was an additional layer they were telling us inspectors to stop doing audits. Transport Canada leaders were not truthful.<\/strong>
\nSMS Assessments and Program Validation Inspections have almost totally replaced audits and inspections. I know of no regulatory audits in the last five years.<\/strong>
\nThe Aeronautics Act regarding SMS does not address all aspects of SMS as implemented and embeds a vague level of safety.<\/strong>
\nThe CAR 107 regarding SMS is vague and nebulous and at barely 300 words. This CAR leaves the requirements in the hands, and subject to whims, of the bureaucrats at all levels from senior mandarins to inspectors and encourages bullying. <\/strong>
\nTransport Canada Staff Instruction SUR-001 Revision 5 is the primary SMS compliance document. At about 33,000 words it defines and implements the \u201cintent\u201d of the Act. It is a third or fourth level document.<\/strong>
\nTo understand SMS you must be conversant with SI SUR001, which the vast majority of the aviation community is not familiar.<\/strong>
\nOther areas of Transport Canada infrastructure have been left without support.<\/strong>
\nNo credible organization supports the current directions of Transport Canada.<\/strong>
\nPVIs have totally replaced audits for non CAR705 SMS organizations.<\/strong>
\nSMS was implemented without any risk assessment or human resources planning.<\/strong>
\nSMS was designed and pushed into place by people with no experience in our civil aviation industry. <\/strong>
\nThere was no formal or recorded public consultation. The program bypassed the CARAC process of public consultation despite Transport Canada assurance regarding CARAC involvement. \u00a0<\/strong>
\nThe training for inspectors was and is poor. \u00a0<\/strong>
\nSMS is implemented but has little if any effect with the SMS companies under CAR 705. \u00a0<\/strong>
\nSMS implementation for the rest of the industry (non 705) has stalled or died.<\/strong><\/p>\n

Decaying Regulatory Infrastructure<\/strong>:<\/p>\n

Transport Canada\u2019s policy makers and Ottawa staff total focus on SMS has left other areas of aviation regulation to decay. Implementation and administration of SMS has been taking up almost all of the time and efforts of the whole staff strength of Transport Canada. \u00a0<\/strong>
\nTransportation Safety Board of Canada aviation Watch List contains 85 \u201copen\u201d safety recommendations; some with Transport Canada responses were found Unsatisfactory (A13-03)<\/strong>
\nThere are regulations and standards that have been technically wrong for years.<\/strong>
\nThe results of Transport Canada Civil Aviation overall attitudes and actions can be easily found in the reactions of public safety experts.<\/strong>
\nYou will also find further evidence in the Public Service Employee Survey Organizational Results. <\/strong>
\nExamine the numbers of lost work days due to TC employees absent on medical grounds with emphasis on \u201cstress leave\u201d.<\/strong>
\nThe long-term results on aviation safety of Transport Canada\u2019s new approach including the reliance on SMS will only be evident in the long term when Canada\u2019s aviation safety record changes in relation to the rest of the technologically developed world that currently shows improving safety.<\/strong>
\nIf the government is truly interested in aviation safety in Canada and in the effects of SMS implementation, please conduct two opinion surveys of:<\/strong>
\nTransport\u2019s own inspectors and\u00a0 Canadian aviation industry<\/strong><\/p>\n

Following the presentations of we three witnesses, the question and answer session began. One of our Canadian government members of parliament stated:<\/p>\n

I hardly know where to begin in the wake of the testimony. It\u2019s frankly unbelievable. It\u2019s shocking to hear what we\u2019re hearing from front-line inspectors, from folks with 30, 40, and 50 years … with 100 years of combined experience on the front lines\u2014former pilots\u2014because it flies in the face of everything we\u2019ve been hearing this week from the government, from the government\u2019s Transport Canada officials, and from the airlines.<\/strong><\/p>\n

So our politicians and parliament don\u2019t know the truth about SMS implementation and the major changes at TC.\u00a0 You may ask, \u201cWho is responsible for mandating the implementation of SMS?\u201d\u00a0 If you want to read the transcript of the full two-hour meeting go to this internet site:
\nhttp:\/\/www.parl.gc.ca\/HousePublications\/Publication.aspx?DocId=6648544&Language=E&Mode=1<\/span><\/a><\/span>
\nThere is an old saying \u201cPut up or shut up\u201d.\u00a0 I guess that was me doing my \u201cput up\u201d so now I need not shut up.<\/p>\n

Now back to the ongoing saga of Mr. B vs. TC.\u00a0 If you remember from my previous columns, TC appealed against the ruling of the TATC.\u00a0 That full Tribunal hearing was held in April but the decision is not available at the time of writing this.\u00a0 I suspect that I will have something on this to report next issue.
\nThat\u2019s all for now folks.\u00a0 Until next time be good and do right.<\/p>\n

Please be aware that I am not a lawyer or legal expert. What I write in my column is not legal advice or legal opinion. If you face a legal issue, you must get specific legal advice from a lawyer and preferably one with experience in the aviation matters in your own country\/state.<\/em><\/p>\n","protected":false},"excerpt":{"rendered":"

Preamble I am providing this preamble to clarify the meanings of abbreviations that I use here. For those of you new to the aviation industry and\/or new to Canada, these abbreviations are all commonly used in the aviation industry and […]<\/p>\n","protected":false},"author":5,"featured_media":3149,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[124,9,13,122],"tags":[],"class_list":["post-3147","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-13-02","category-features","category-the-regs","category-volume-13-issues"],"_links":{"self":[{"href":"https:\/\/amumagazine.com\/index.php?rest_route=\/wp\/v2\/posts\/3147","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/amumagazine.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/amumagazine.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/amumagazine.com\/index.php?rest_route=\/wp\/v2\/users\/5"}],"replies":[{"embeddable":true,"href":"https:\/\/amumagazine.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=3147"}],"version-history":[{"count":5,"href":"https:\/\/amumagazine.com\/index.php?rest_route=\/wp\/v2\/posts\/3147\/revisions"}],"predecessor-version":[{"id":3153,"href":"https:\/\/amumagazine.com\/index.php?rest_route=\/wp\/v2\/posts\/3147\/revisions\/3153"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/amumagazine.com\/index.php?rest_route=\/wp\/v2\/media\/3149"}],"wp:attachment":[{"href":"https:\/\/amumagazine.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=3147"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/amumagazine.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=3147"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/amumagazine.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=3147"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}