The reporter has raised a safety concern regarding the oversight process of the maintenance of Recreational Aviation Australia (RAAus) registered aircraft. The reporter has questioned the appropriateness of self-certification by manufacturers of Light Sport Aircraft (LSA) for acceptance onto the RAAus register, without formal review by RAAus to ensure compliance with the applicable design standards.
[The ATSB notes a previous REPCON, RA2020-00061, in which a Fly Synthesis Texan aircraft was accepted onto the RAAus register with operating weights that differed significantly from those that the manufacture provided certification for. In addition, the ATSB notes REPCON RA2021-00014 in which a B&F FK9 aircraft was accepted onto the RAAus register with components that were not installed or certified by the manufacturer.]
The reporter has raised a further safety concern regarding the current method of disseminating Airworthiness Directives for RAAus registered aircraft. The reporter has stated that CASA AC 21.42 v2 requires manufacturers of LSA’s to 'maintain a database of all owners of aircraft in Australia and overseas, investigate service defects and address safety critical defects with corrective action by issuing safety direction (SD) to all affected owners/registered operators' and raises concerns with this arrangement due to the concern that RAAus is unwilling to share the database of current LSA owners with manufacturers due to privacy concerns. The reporter questions how this process is able to be effectively followed in these circumstances, and has advised that they are aware of at least one LSA manufacturer who has stated that they are not aware of all of the applicable aircraft owners in Australia – or how to contact them.
The reporter has stated that these concerns are further compounded by a perceived absence of trend monitoring and action by RAAus in the event that an airworthiness defect is reported through RAAus’ Occurrence Management System (OMS). The reporter has stated that they have previously entered a significant defect affecting the airworthiness of a particular LSA type on a number of occasions, and have not received a response or seen any information being disseminated to relevant owners by RAAus as a result. The reporter questions what processes are in place for RAAus to monitor such airworthiness concerns raised through OMS, and what processes RAAus has in place to alert owners to airworthiness safety concerns that are identified.
Additionally, the reporter has stated that on a number of occasions they have witnessed or discovered evidence of an LSA aircraft being incorrectly maintained by an L2 maintenance organisation with the potential to significantly impact its airworthiness. The reporter has stated that on one occasion, an aircraft was discovered to have been flying for a significant period of time with significant airframe corrosion, significant engine TBO exceedance, and various flight critical components in varying states of disrepair. The reporter questions what processes RAAus has in place to oversee organisations and individuals conducting L2 maintenance to ensure adequate compliance with airworthiness requirements and maintenance practices.
The reporter has questioned the appropriateness of self-certification by manufacturers of Light Sport Aircraft for acceptance onto the RAAus register, without formal review by RAAus to ensure compliance with the applicable design standards.
- RAAus registers LSA aircraft after CASA has issued a Special Certificate of Airworthiness.
- It is not the responsibility of RAAus or CASA to determine compliance to design standards, it is the manufacturer who self certifies to the standard through the supply of CASA form 681.
- To note. Improvement in processes – As of January 2020 first of type LSA aircraft require CASA assessment prior to registration.
- All new LSA aircraft require a CASA Weight Control Authority to verify the weight and balance.
- LSA has been developed internationally for the purpose of removing unnecessary red tape whilst understanding the changes in risk profile. LSA aircraft are in use all around the world and are designed to the ASTM Specifications.
The reporter has stated that CASA AC 21.42 v2 requires manufacturers of LSA’ s to 'maintain a database of all owners of aircraft in Australia and overseas, investigate service defects and address safety critical defects with corrective action by issuing safety direction (SD) to all affected owners/registered operators' and raises concerns with this arrangement due to the concern that RAAus is unwilling to share the database of current LSA owners with manufacturers due to privacy concerns. The reporter questions how this process is able to be effectively followed in these circumstances and has advised that they are aware of at least one LSA manufacturer who has stated that they are not aware of all of the applicable aircraft owners in Australia – or how to contact them.
- RAAus does not supply member information directly to the manufacturer, however, on request from the manufacturer RAAus contacts all owners of the aircraft and requests they supply their details.
- LSA manufacturers publish their service bulletins online on their website for owners to review, in accordance with the RAAus technical manual.
The reporter questions what processes are in place for RAAus to monitor such airworthiness concerns raised through OMS, and what processes RAAus has in place to alert owners to airworthiness safety concerns that are identified.
- RAAus has received almost exactly these concerns from a member. On that basis, and assuming this is the same person, we are able to advise that the manufacturer was informed of the defect by both RAAus and the aircraft owner. The manufacturer subsequently supplied an approved repair scheme to the aircraft owner.
- RAAus’ process is to ensure manufacturers are informed of defects reported to RAAus. It is, however, the responsibility of the aircraft owner to ensure defects are reported to the manufacturer for Light Sport Aircraft. The RAAus Technical Manual also outlines mandatory defect reporting requirements which must be provided to RAAus.
Additionally, the reporter has stated that on a number of occasions they have witnessed or discovered evidence of an LSA aircraft being incorrectly maintained by an L2 maintenance organisation with the potential to significantly impact its airworthiness. The reporter has stated that on one occasion, an aircraft was discovered to have been flying for a significant period of time with significant airframe corrosion, significant engine TBO exceedance, and various flight critical components in varying states of disrepair. The reporter questions what processes RAAus has in place to oversee organisations and individuals conducting L2 maintenance to ensure adequate compliance with airworthiness requirements and maintenance practices.
- Aircraft owners and maintainers are required to conduct maintenance in accordance with the RAAus Technical manual and aircraft manufacturers procedure (i.e. Maintenance manual).
- RAAus has a CASA approved audit and surveillance program, especially for the conduct of audits at of flight training schools and airworthiness matters are covered during these audits.
- RAAus welcomes the person sharing the specific details of all such occurrences as outlined above so we can take appropriate action.
RAAus remains committed to investigating any specific claims provided, however, escalation will only occur on the basis that a valid safety matter exists.