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26 September 2018
ADVISORY CIRCULAR
AC 005 / 2018
MANAGEMENT OF DEFECTS
MANAGEMENT OF DEFECTS
AC 005 / 18 Ver 1.0 26 September 2018
2
An Advisory Circular is issued by the Authority to promulgate important information to the Defence Aviation community, but does not mandate any action. This includes informing the community on aviation safety / airworthiness matters, information that enhances compliance understanding for existing regulation, or policy guidance for aviation issues not yet regulated that requires further understanding.
Audience
This Advisory Circular (AC) applies to all DASR regulated entities exercising roles or
responsibilities associated with Operational, Initial/Continued and Continuing
Airworthiness.
Purpose
This AC describes how the Defence Aviation Safety Regulation (DASR) supports
military aviation flexibility. This is important as the Government has expectations on the
ADF to satisfy preparedness requirements and also meet short notice tasking. This AC
will convey how DASR maintains close alignment with contemporary aviation safety
conventions, however, when reasonably practicable also provides flexibility within the
Defence Aviation Safety Framework to achieve necessary outcomes. This AC replaces
AC 005/2017.
For further information
For further information on this AC, contact ACPA DASA.
Status
Version Date Approved By Details
1 26 September 2018 DACPA Initial release
Unless specified otherwise, all regulation referenced in this AC are references to the Defence Aviation Safety Regulation (DASR).
MANAGEMENT OF DEFECTS
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1. Reference Material
1.1. Acronyms
AC Advisory Circular
AMC
AFHRS
ACRE
CAM
Acceptable Means of Compliance
Airframe Hours
Authorisation of non-standard Configuration, Role and Environment
Continuing Airworthiness Manager
CAMO
CASA
CDL
CoA
CRS
DASA
Continuing Airworthiness Management Organisation
Civil Aviation Safety Authority
Configuration Deviation List
Certificate of Airworthiness
Certificate of Release to Service
Defence Aviation Safety Authority
DASR
Defence AA
EASA
EMAR
Defence Aviation Safety Regulation
Defence Aviation Authority
European Aviation Safety Agency
European Military Airworthiness Requirements
GM
ICA
ICAO
MAO
MDOA
MEL
MMEL
MAO
MAO-AM
MPTF
MTCH
NMAA
OEM
PTF
SFARP
Guidance Material
Instructions for Continuing Airworthiness
International Civil Aviation Authority
Military Air Operator
Military Design Organisational Approval
Minimum Equipment List
Master Minimum Equipment List
Military Air Operator
Military Air Operator Accountable Manager
Military Permit to Fly
Military Type Certificate Holder
National Military Airworthiness Authority
Original Equipment Manufacturer
Permit to Fly
So Far As Reasonably Practicable
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SPA
SPO
U/S
WHS
Specific Approvals
System Program Office
Unserviceability
Work Health Safety
1.2. Definitions
1.2.1. Endanger Flight Safety. Refer to AMC1 to 145.A.50(a) which states: ‘Endanger flight safety means any instance where safe operation could not be assured or which could lead to an unsafe condition. It typically includes, but is not limited to, significant cracking, deformation, corrosion or failure of primary structure, any evidence of burning (including overheating), electrical arcing, significant hydraulic fluid or fuel leakage and any emergency system or total system failure. An AD overdue for compliance is also considered a hazard to flight safety.’
1.3. References
1.3.1. AAP 8000.011 Defence Aviation Safety Regulations
1.3.2. Advisory Circular AC003/2017 DASR Implementation of Military Permits to Fly
1.3.3. Work Health and Safety Act 2011 (WHS Act) and Work Health and Safety
Regulations 2011 (WHS Regulations).
1.3.4. AC 002/2016 – Aviation Command Responsibilities under DASR.
1.3.5. AAP 6734.001 – Defence Aviation Safety Manual.
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2. Responsible agencies or individuals
2.1. Remaining cognisant of the wide ranging audience of this AC, the MAO and
CAMO are the most likely proponents for the use of the processes described in this AC
for the management of defects. The MAO/CAMO should therefore establish in-service
procedures for the management of Defects in accordance with the applicable DASR
AMC that reflect the central role of the MAO/CAMO and authorised staff.
3. Background
3.1. The necessity to operate ADF aircraft with an existing defect is nothing new to
the ADF and has not changed with the introduction of DASR. This is particularly
relevant in situations where commanders are expected to operate Defence aircraft at
higher levels of risk to achieve directed mission objectives in support of Australia’s
national interests.
4. Scope
4.1. This AC brings together the requirements of several regulations. For example,
DASR M.A.301(a), where a CAMO is required to have a system for the management of
deferral of defects, DASR 21.A 701 MPTF and DASR SPA.10 where the MAO is
required to have a system for the management of Command Clearances. The focus of
this AC is for the management of defects where the aircraft has been released to 145
maintenance organisation and there is a defect that needs to be managed. This AC also
includes guidance on how Command Clearances may be used to manage defects in
these circumstances. Command Clearances can also be utilised for other purposes as
per DASR SPA.10. where the scope of this AC may not be applicable
4.2. Decisions made by the Aircraft Captain. DASA.ORO.55 Aircraft Captaincy,
details the responsibilities of the Aircraft Captain whilst in charge of the aircraft. These
are separate to the guidance provided by this AC, and the Command Clearance
requirements of DASR SPA.10.
5. Continuing Airworthiness Military Context – Flexibility Provisions
5.1. Deferred Defect effect on CoA. The premise of operating aircraft safely is
centred upon the concept that each individual in service airframe must be airworthy to
operate. Simplistically, individual aircraft are airworthy provided the Certificate of
Airworthiness (CoA) remains valid. A defect renders an aircraft’s CoA invalid and
therefore the airframe cannot fly until the CoA is revalidated. The CoA can be
revalidated by a number of methods including, rectifying the defect IAW Instructions for
Continuing Airworthiness (ICA), deferral of the defect or approval of a Command
Clearance.
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5.2. When an aircraft is appropriately ‘authorised’ to fly with the defect existing, it is
known as a Deferred Defect. Defects can be deferred via provisions of the DASR, such
as ICA, Minimum Equipment Lists (MELs) or Configuration Deviation Lists (CDLs).
MELs and CDLs allow the aircraft to be operated with defective equipment/item(s) and
uninstalled components respectively. Deferred Defects can be thought of as
supplementing the invalid CoA thereby restoring the original CoA. This process can also
be applied to platforms operating under a MPTF prior to the issuance of a Type
Certificate. Figure 1 below, depicts this analogy.
Figure 1: Military Flexibility – MEL and No MEL
5.3. Minimum Equipment List. In Figure 1 both defect #1 and #2, render the CoA
invalid. Due to constraints (normally time), an approved MEL for that aircraft type/tail
has been used to defer the defects. The CoA is now valid (assuming all defects cleared)
and the aircraft is considered serviceable. A MEL can be quite extensive and cover a
range of situations; however, a MEL can never cover every situation and is constrained
to known, predicted scenarios. Further, there will be occasions when the conditions of
the MEL to defer a defect cannot be satisfied.
5.4. No Minimum Equipment List or Not on MEL. When an aircraft within the ADF
does not have an approved MEL or the situation in question is not listed in the approved
MEL, defects that do not endanger flight safety as assessed by the 145 may be
deferred. In Figure 1 defect #3 has been assessed as not endangering flight safety and
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been recorded as a Deferred Defect. The CoA is now valid (assuming all defects
cleared) and the aircraft is considered serviceable.
Figure 2: Military Flexibility Solution – MEL, No MEL and MPTF
5.5. Military Permit to Fly. The DASR flexibility provision, as depicted in Figure 2,
allows the CoA to be supplemented by the use a MPTF. The MPTF does not replace
the CoA, rather the MPTF(s) supplement the CoA in a similar vein to the use of a
MEL/CDL thereby restoring/re-validating the CoA. The concept of MPTFs
supplementing the CoA does come with trade-offs and additional requirements1 which
are not covered within the scope of this AC.
5.6. Even with a DASR flexibility provision in place for MPTF/CoA management, there
will still be times when the Continuing Airworthiness framework does not provide the
necessary flexibility to meet National interests. For example, there may simply not be
enough time to achieve the issuance of a MPTF and the essential nature of the mission
requires the use of the aircraft.
5.7. Command Clearance. Defence has added flexibility to satisfy national interests.
DASR SPA.10 Command Clearance provides this flexibility as a provision of
Operational Airworthiness. Command Clearance is a flexibility provision used for
1 Advisory Circular AC003/2017 DASR Implementation of Military Permits to Fly – refer paragraph 11.4
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circumstances that have been deemed essential and is implemented in parallel with
continuing airworthiness processes where the expected duration of operation under a
Command Clearance would reasonably enable alternate continuing airworthiness
flexibility provision to be approved. Because time is a factor for invoking SPA.10,
engineering solutions may not necessarily have been exhausted. Command Clearances
still require compliance with WHS legislation in that the aviation safety risk must first be
eliminated so far as reasonably practicable (SFARP) and if not able to be eliminated
then minimised SFARP.
5.8. The issuance of a Command Clearance from the Military Air Operator –
Accountable Manager (MAO AM) or Delegate may occur for circumstances where the
Continuing Airworthiness framework cannot support military flexibility requirements. In
these cases, where a Command Clearance is issued, the CoA is not revalidated, rather,
after consideration of the mission requirements which dictate that the flight must occur,
the aircraft is permitted to fly with a known condition that could have the potential to
endanger flight safety. The essential nature of the mission that justifies the issuing of a
Command Clearance is proportionate with the assessed risk of operating with the
condition that may endanger flight safety. Figure 3 below depicts the provisions of
SPA.10 Command Clearance when used to manage a defect.
Figure 3: Military Flexibility – MEL, No MEL, MPTF and Command Clearance
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5.9. The key difference between the MPTF and Command Clearance is that the
MPTF is an Initial Airworthiness instrument subject to DASA approval and issue,
whereas a Command Clearance is an Operational Airworthiness approval via the
command chain. In both cases, MPTF and Command Clearance are valid approvals
and must contain conditions and limitations that ensure safety. For airworthiness
accountability and management, the MAO must ensure the appropriateness of all
MPTFs and Command Clearances.
6. Authorisation for the Management of Defects
6.1. Military Flexibility – What is the process? The flow chart at Enclosure 1 has
been developed to guide commanders and personnel working within the DASR
framework through various approaches, tools and options available to manage defects
to achieve ADF requirements.
6.2. Flexibility Provision 1 – MEL/CDL. Consult the MEL/CDL to identify if deferral
of the defect is permissible. The MEL/CDL may prescribe certain conditions to be
satisfied and if the MAO AM (or delegate) endorses the proposed deferral, the CAM (or
delegate) may approve the deferral. The deferred defect is documented in the aircraft
technical log, including deferment period and any associated limitations. The aircraft is
then able to be operated with a valid CoA.
6.3. Flexibility Provision 2 – No MEL/CDL. If no MEL/CDL exists, or the defect is
not covered by the MEL/CDL this provision provides the ability to defer the defect.
Flexibility Provision 2 requires an assessment to be carried out by an appropriately
authorised certifying staff, to determine if the defect does/does not ‘endanger flight
safety’2. There are no limitations on who may be consulted to make this determination,
including appropriate aircrew, technical or engineering staff. The broad requirements of
this assessment including some examples are within the definition at the beginning of
this AC. If further clarity is required for a specific FEG or aircraft, a CAM (or delegate)
may consider including this as part of the system implemented for the management of
defects.
6.4. If the assessment determines the defect does not endanger flight safety the
decision is then passed to the CAMO delegate for agreement to defer the defect. CAMO
agreement involves considering and accepting the potential logistics consequences
such as availability of spares and potential higher cost to rectify the defect at a later
date as well as obtaining operational endorsement of the deferral. The CAM may
choose to delegate the responsibility for logistical and operational decisions, noting
accountability cannot be delegated. Typically, appropriately experienced and authorised
2 An ‘endanger flight safety‘ assessment shall be conducted in accordance with AMC1 to 145.A.50(a)
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engineering and technical members within ADF squadrons would be expected to be
suitable candidates.
6.5. If the CAM (or delegate) agrees to the deferment, then the deferred defect is
documented in the aircraft technical log, including the deferment period and any
associated limitations.
6.6. The aircraft technical log must accurately record the CAM (or delegate) deferred
defect logistical decision/authorisation. Under this flexibility provision the CAM retains
accountability for the decision to defer the defect and the DASR 145 organisation is
accountable for the ‘endanger flight safety’ assessment and correctly annotating the
technical log to record the decision.
6.7. Flexibility Provision 3 – CAMO Management. If the outcome of the No
MEL/CDL assessment results in the DASR 145 authorised certifying staff determining
that the defect would/could possibly endanger flight safety, or if there is insufficient data
to inform the decision, the CAMO has the following options:
6.7.1. Additional Data provided. The CAMO may be able to provide additional data to
the DASR 145 to re-consider, on merit, the 'endanger flight safety' assessment. The
CAMO may have access to additional data (OEM, design, operational) not available to
the DASR 145. For example, the CAMO may be able to provide updated ICA, prior to
the scheduled publication amendment. The DASR 145 organisation can use any
credible data (referencing all data used) in determining the endanger flight safety
assessment but are always within their right after appropriate consideration of the data
to refer back to the CAMO i.e. make a ‘yes’ (does endanger flight safety), ‘unsure’ or
‘insufficient data’ determination. The No MEL/CDL flexibility provision can be re-entered
if the 145 organisation re-assessment determines the ‘issue /defect’ does not endanger
flight safety.
6.7.2. Rectify the defect. The CAMO may decide not to defer the defect and task a
DASR 145 maintenance organisation to rectify the defect. In these cases the CAMO
should notify/task an appropriate DASR 145 organisation to rectify the aircraft.
6.7.3. Approved repair. Seek an approved repair from a MDOA holder, who will issue
an approved repair, approval to operate with unrepaired damage and/or modified flight
conditions. The CAMO receives approval documentation (from an MDOA holder) and
issues/updates ICA that is provided to the 145 organisation to incorporate any repair
and record appropriately.
6.7.4. Life extension. If appropriate, a life extension may be provided by:
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6.7.4.1. Repackage life within Airworthiness Limitation, as required by DASR
M.A.301(a)(3).
6.7.4.2. Extension of a non-Airworthiness Limitation servicing by the CAMO based on
reliability data.
6.7.5. Military Permit to Fly (MPTF). Seek a MPTF IAW DASR 21.A.701. The MPTF is
issued, the decision is recorded appropriately and the aircraft technical log is updated.
Advisory Circular AC003/2017 should be consulted for detail on the MPTF process.
6.8. Command Clearance. If the issue cannot be solved utilising the continuing
airworthiness flexibility provisions, the CAMO may engage the MAO AM or delegate.
Not having sufficient time, is likely to be a common factor preventing one of the
continuing airworthiness flexibility provisions from being applied to resolve the issue.
The dotted red line at enclosure 1 signifies the departure from Continuing Airworthiness
regulation to Operational Airworthiness regulation for the specific issue only.
Importantly, the remainder of the aircraft has to remain compliant with Continuing
Airworthiness regulation. Provisions must be put in place to enable the aircraft to be
returned to management under Continuing Airworthiness provisions as soon as
practicable.
6.9. In ideal circumstances, conditions that require a MPTF would be managed via a
MPTF however, if all options available through continuing airworthiness flexibility
provisions have been exhausted, and where there is insufficient time to process a
MPTF application, and the essential nature of the mission has been established, a
Command Clearance as allowed by DASR SPA.10 may be exercised by the MAO AM
or delegate.
6.10. The process for a Command Clearance is modelled on the WHS requirements
with the ultimate goal of eliminating the hazard/risk SFARP and if not able to eliminate,
then to minimise the risk SFARP. Additionally, decisions are to be made at the most
appropriate level including whether the cost of eliminating or minimising the risk is
grossly disproportionate to the risk.3 The process contains the flowing steps:
6.10.1. Gaining reasonable knowledge of Hazard and Controls. All reasonable
knowledge of the issue should be obtained. There is no limitation placed on the MAO
AM or delegate in where to obtain or who may provide information. Ultimately the
Commander or delegate needs to be satisfied that all reasonable effort was made,
within context, to enable further assessment to eliminate the Hazard/Risk and, if not
able to eliminate, a risk assessment is conducted and controls applied to minimise the
risks SFARP.
3 WHS ACT 2011, Part 2, Division 1, Sections 17 and 18.
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6.10.2. Eliminate the Hazard / Risk. If the hazard/risk is eliminated through
operational controls or limitations instigated by the MAO AM delegate, then no risk need
be retained by the operator. The aircraft is permitted to fly with a known condition that
potentially ‘endanger flight safety’ after consideration of the essential nature of the
mission and the elimination controls / limitations have been documented in the aircraft
technical log.
6.10.3. Risk Assess the Hazard / Risk. Command Clearance allows for
operation at differing risk levels than those associated when complying with the DASR
Initial and Continuing Airworthiness requirements i.e. above the red line of enclosure 1.
In these circumstances the decision to ‘proceed knowing the level of risk’ should be an
informed one, and retained as appropriate through a risk management framework such
as AFSM and AVRM as per the DASM.
6.10.4. Mitigate the Risk. After completion of the risk assessment the controls
and limitations must be implemented to meet the requirements of minimising the risk
SFARP as per DASM (and the WHS Act). Any identified controls / limitations must be
appropriately documented in the aircraft log.
6.10.5. Command Clearance Issued. The Command Clearance may be issued
by the MAO AM or delegate subject to the aviation safety risk being eliminated SFARP
and if not able to eliminate then minimised SFARP.4
6.11. Where a Command Clearance is used to permit flight with a defect or other
configuration change, it should be documented in the aircraft technical log, including
deferment period and any associated limitations. The aircraft technical log must be
updated to record the Command Clearance decision/authorisation. In this case the
DASR 145 organisation is not taking accountability for the Command Clearance
decision itself, the DASR 145 organisation is still responsible for correctly annotating the
technical log to record the decision on behalf of the MAO/CAMO as tasked/directed.
6.12. Importantly, a Command Clearance is not a Deferred Defect. However,
MAO/CAMO use of the Defence deferred defect process to update the aircraft technical
log and provide robust recording and tracking mechanisms is considered effective when
the Command Clearance has been issued to manage a defect within the 145
maintenance organisation.
4 Regardless of elimination or minimisation, both require a Command Clearance as the controls and
limitations are authorised by the MAO AM or delegate.
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6.13. ADF implementation. To satisfy the requirements of DASR SPA.10, the MAO
must have a system in place that specifies appropriate procedures, delegations and
oversight for Command Clearances. Consideration needs to be applied to delegations,
compliance with the DASR.SMS, DASM and multiple applications of the continuing
airworthiness flexibility provisions and Command Clearance.
7. Reporting/Recording Actions
7.1. Reports required - Nil
7.2. Recording action – Nil
8. AC Currency
8.1. This AC will remain current until cancelled by DASA.
Original SignedSeptember 2018Director - ACPA, DASA
Enclosure
1. Management of Defects – Flow Chart
Enclosure 1 to AC 005/2018
26 September 2018
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