This EASA AD was updated on 14.09.12 to AD 2012-0142R1 making it possible for the owner to check the applicability of the Airworthiness Directive and if it is found to be 'not applicable' enter that into the logbook as described. Full details can be found by going to Easy News update 15.09.12 AD2012-0142R1.
There has been a fair amount of panic and confusion concerning the issue and actions required relating to the EASA AD 2012-0142 part of which needs some clarification from the CAA. Unfortunately everyone I tried to get hold of in the CAA appears to be on holiday or has been ‘temporarily transferred’ and Graham Hallett of the BBAC had gone into hiding following a melt-down of his phone. Then our phone melted as well! There is fanny-all point contacting EASA for an answer because all you’d get from them would be a luke-warm Euro-shrug. We all know that balloons and balloonists should never have been included in this idiotic bureaucracy which made the suggestion of shelling the EASA building very tempting. Right, having had me EASA rant the need for an AD system is essential if the excellent level of safety that exists in the world of aviation is to be maintained. Having now had a long chat with Graham Hallett chief chap of the BBAC CAMO, further discussion is definitely required.
What to do ONLY IN THE CASE OF THE BALLOON NOT BEING AFFECTED, is to complete the ‘Mandatory Requirements not applicable to this aircraft’ and ‘Mods SBs and ADs’ sections found in the back of the logbook. In the case of some older logbooks you should have pre-prepared sheets glued or stapled in with space for further entries.
Under ‘Mandatory Requirements n/a’ should be an entry AD2012-0142, Reason-Affected part not fitted, name and Company-could be the Quality Manager of an AOC or the owner, plus the date.
Under ‘Mods SBs and ADs’ enter in ‘Mandatory column’-AD2012-0142, Subject-Lindstrand female connectors, date and hours at compliance – pretty obvious, Method of Compliance-affected part not fitted n/a. The one-time column gets ticked and the Signature/Co/date completed.
If the balloon is affected then obviously the ‘Mandatory Requirements not applicable to this aircraft’ doesn’t get filled in but the Mods SBs and ADs Method of Compliance bit needs ‘Inspected and repaired in accordance with LBL SB12’, or possibly, ‘New connector fitted’ along with the release to service (along with proper EASA wording) in the logbook proper signed off by an inspector from a Part F organisation. If the balloon is in a CAMO then photocopies of all those entries should also go to the CAMO. All the private balloons we look after are not in a CAMO so no need to send anything anywhere.
So, as you may have spotted, my argument would be that to comply, providing of course the thing hasn’t actually a got a faulty Lindstrand fitting, completing the Mandatory requirements and the Mods, AD & SB declaration bits in the back of the logbook should be sufficient. The AD, if you read it closely, only requires inspection if the part is, or has, been fitted. The CAA answer at the moment requires a release to service entry but if the balloon was never affected then it wasn’t withdrawn from service so doesn’t require being released back to service. Got that so far? You normally don’t withdraw an aircraft from service when checking the logbook. We’ll have to wait and see.
Unfortunately the CAMO system is designed for aircraft where the Maintenance Organisation usually holds the logbook and all the records so it would normally never be a problem. If a CAMO contracts to undertake looking after the Continued Airworthiness of an Aircraft, a legal requirement in the case of Ride Operators, then this is exactly what they have to do so when ADs and SBs (amongst other things) crop up they have to be dealt with. The CAMO must ensure that to the best of its ability the Directive is complied with. If it isn’t then the CAMO is honour bound to advise the owner/operator that the balloon may not be legally airworthy and must be grounded until the matter is resolved. Therefore if your balloon is in a CAMO and you don’t send photocopies of the required entries then the CAMO has no idea that the balloon is airworthy. If it isn’t then the CAMO must inform the CAA that the owner/operator is in breach of their contract. That is what the customer is paying for. If your balloon is not operating under a CAMO then it is the owners responsibility to ensure that it complies and remains legally airworthy.
It would seem to me we are somewhat in a loop here when it comes to understanding the need to issue an Airworthiness Directive. They are not issued lightly. Specifically in the case of these Connectors a known number were obviously manufactured and supplied between given dates and some may be faulty. Traceability through a Form 1 should make this straightforward to locate the missing ones. This must have been deemed ‘not possible’ as it is most likely that some went out without a Form 1. I don’t think I have ever heard anyone comment what good value for money a Form 1 is however in situations like this it could possibly have saved an AD being issued. Technically the component must be released on a Form 1 (or equivalent) if it going to attached to an Annex I EASA type aircraft, however, a Form 1 is not automatically issued by the manufacturers when they supply parts as we continually have to point out to people that turn up with a Caminbolt spigot mangle nut that they want us to fit to their Darstedly Mk2 burner without a Form 1. So it is simple, if parts are sold without Form1’s then they cannot currently be traced. It isn’t the manufacturers’ responsibility to issue a Form 1 it is the owner’s or customer’s responsibility to request one which then ensures the component is in compliance and itself in an airworthy condition. How many owners buy Cameron supplied O-rings for the Rego fittings and don’t bother getting a Form1 which would add £8.00 to the bill? It will be interesting to see what happens if there is ever a faulty batch of them! As much as I hate to show them any kindness it won’t be EASA’s fault that is certain (but we can still moan about them).
It has been said by a few that EASA is answerable for the ‘problem’, that may be true as it is an EASA AD but there are, I believe, a few points worth considering before we drive a Centurion Tank through their (posh) doors. If they are responsible then should EASA start drawing up legislation to the effect that ‘all’ parts supplied have to have a Form 1 issued? AnnexII aircraft of all types don’t come under EASA control yet use many components common to AnnexI aircraft. If you are purchasing Rego connectors for use on a refuelling hose or Airtour Balloon do you want to spend an extra £12.00 to Lindstrands for a Form1 you don’t legally need? Secondly do you think that safety should be compromised when all the possibly affected parts cannot be fully traced? Should there be an acceptable ‘only a few’ number?
There may only be a few affected components but if you discover the one you have on your Polish registered balloon manifold is affected then I would think that you would be rather reassured that there is a method of getting the information out even if many owners rely on their inspector passing the information on. I don’t think any inspector minds promoting safety or helping to ensure that safety-related legislation is complied with and all feel a true sense of responsibility when it comes to the balloons they inspect. I’m sure many inspectors have been inundated with calls from concerned owners. As for the burden on the CAMO, it is just one of the things that has to be budgeted for, its part of their job and hence the need for an annual fee, free of course if you are a member of the BBAC and in their CAMO.
All aircraft owners (and repair stations, Maintenance Organisations and Nobby the spanner) should be checking ADs whether AnnexI or AnnexII aircraft are involved or not. That is exactly why having the AD system is such a good thing. As far as stock is concerned it is simple for us to check the parts on the shelf and parts supplied and fitted by referring back to the Form 1s. In the case of our customers we are certain that all balloons we have inspected since the Issue of Lindstrand Service Bulletin 12 in February will not be affected unless they have independently fitted Lindstrand Connectors after the annual inspection. For our customers not operating under the CAMO we will contact them accordingly and keep them updated through our website. If you have any problems please feel free to contact us, details in the Contact Us bit. If want the affected parts checked please call to make an appointment. There is no charge for this inspection, if required, or for signing off the logbook. For details of the AD please refer to the last Easy Balloon News issued on 06.08.12.