Primarily for general aviation discussion, but other aviation topics are also welcome.
By Bobcro
#1699238
As the owner of Beechcraft B19A G-AWFZ (auw 1,021 kg) I have had the aircraft maintained by a licensed engineer to an SDMP he prepared and this is based on the MIP with 100hr inspection plus a check on EASA, FAA and CAA ASDs. I do not undertake any 'maintenance tasks' other than those that as a pilot I am approved to carry out.

I fly less than 100 hr PA and have oil changes at 25 hr or 6 months.

I fly the aircraft only privately 'on condition' and have any defects that affect flight safety fixed.

I do not believe that the aircraft needs an annual radio inspection by a licensed engineer.

I do not believe that an SDMP requires a signature by a CAMO, licensed engineer or approved organisation

Am I correct in assuming that providing that I am satisfied that the necessary work has been carried out then the only signature that is required is mine stating that I am so satisfied and that I should write this in the Airframe Log Book and Engine Log Book and keep a copy of the worksheets.

I have read through the CAA document relating to the SDMP many times and this Forum and do believe that I am correct in assuming the above.
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By BoeingBoy
#1699349
I am in exactly the same situation with my Archer and the way I understand it is that by signing the SDMP you are stating that you are the 'Continuing Airworthiness Manager'. That makes you responsible for what maintenance the aircraft receives and when, it doesn't make you responsible for the declaration that the work carried out is safe and compliant. That still needs to be done by a licensed engineer. You also need an annual review certificate issued by the CAA. (The ARC).
Another misconception is that people think that by creating an SDMP they no longer need to comply with Airworthiness directives in the forum of bulletins and service letters etc. Whilst some are not mandatory anyway the directives still are and you would be expected to have incorporated them into your work order when specifying a check to your chosen maintenance company.
The declaration that forms the lead part of your SDMP only means that you accept the overall management of the maintenance program, not how well it was done.
By Mick Elborn
#1699359
According to the SDMP Template linked from CAP 1454 the SDMP at Section 7 needs a signed declaration from the Owner, an approval stamped and signed by the contracted CAMO and a signed approval from the Competent Authority.

There is also a Certification Statement at Section 8.

However, what is confusing is that CAP1454 under Development of the AMP it says: "Under the revised regulation, an owner may develop an AMP for their aircraft that does not require an approval from the CAA. "

Does that mean that the actual programme can be developed without approval by the CAA but then the programme acceptable to the CAMO does then need CAA approval as per the template.
By Bobcro
#1699399
Mick Elborn wrote:According to the SDMP Template linked from CAP 1454 the SDMP at Section 7 needs a signed declaration from the Owner, an approval stamped and signed by the contracted CAMO and a signed approval from the Competent Authority.

There is also a Certification Statement at Section 8.

However, what is confusing is that CAP1454 under Development of the AMP it says: "Under the revised regulation, an owner may develop an AMP for their aircraft that does not require an approval from the CAA. "

Does that mean that the actual programme can be developed without approval by the CAA but then the programme acceptable to the CAMO does then need CAA approval as per the template.


My interpretation is that it is a Template but I am at liberty to use it as a guideline which I have but it's layout is NOT mandatory.

In SECTION 7 and 8 it requires a signature by the owner/lessee OR CAMO or CAA but not all.

I don't believe that I have to use a licensed engineer, but I do, but I can use anyone who i judge is competent to work on the simple aircraft and that it is up to me to be so satisfied. As many engineers work under company approval they just don't lose their skills the day they leave or retire.

SDMP is what it says on the tin.
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By flybymike
#1699411
According to the SDMP Template linked from CAP 1454 the SDMP at Section 7 needs a signed declaration from the Owner, an approval stamped and signed by the contracted CAMO and a signed approval from the Competent Authority.

Our SDMP aircraft is uncontrolled with no contracted CAMO.
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By BoeingBoy
#1699452
The fact that the SDMP makes the owner the CAM is the reason maintenance companies hate it. I have had two that tried to make me place the aircraft into controlled maintenance so that they could tell me when it was fit to fly and how much it was going to cost me whilst charging me handsomely for the privilege of overseeing the whole program. That said, SDMP oversight is not for everyone. Chasing up the latest regulations without the dedicated software that engineering companies pay a lot for means subscribing to both FAA and EASA bulletins along with ALL the manufacturers who put something into your aircraft. For me in retirement it's almost a full time job.

Whilst most engineers will still audit to check if the latest notices have been included in your work order some will be 'bloody minded' and do exactly what you specify and no more. Hence if you are then found out not to have complied with a something they will simply shrug their shoulders and say it was your fault for not letting the professionals do their job. The person signing the ARC however is still responsible for saying the aircraft is airworthy.

Whilst Bob's idea of not using an engineer might be nice in theory I for one would not even entertain buying an aircraft that had not been audited for compliance and serviced by a Part 145 or Part M company. Remember that when you think that it might save a few bob to cut corners now. It will cost you dearly at the time of sale and also dearly if your insurance company find you have not complied with AD's etc that should have been completed.

In many ways the level playing field of the old LAMP system meant that we all knew what work was expected at each check and who should sign for it. SDMP was a good idea in principle but it's implementation has been very confusing to say the least.
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By aerofurb
#1699516
Although I’m not as directly involved with the maintenance of certified aircraft as I used to be, I think some words of guidance are needed here to avoid some of the apparent misinterpretation and misunderstandings written in this thread.

G-AWFZ holds an EASA Certificate of Airworthiness and in the UK this entitles it to be maintained to the Self Declared Maintenance Programme (SDMP). At 1021 kg MTWA, it is classed as an ELA1 aircraft (non-complex, sub 1200 kg).

The maintenance tasks that a pilot/owner can carry out on their aircraft are clearly defined in Part-M, Appendix VIII: ‘Limited Pilot Owner Maintenance’. Part-M can be tricky to find on the EASA website, it has to be said. There is an excellent Swiss training organisation called QCM through which you can gain access to the EASA documents (including Part-M) free of charge: https://www.qcm.ch/en/

As per the CAA’s CAP 1454 SDMP ‘Guidance Document’ there are effectively three options for its Maintenance Programme:

1. An MP approved by the CAA (or a CAMO with appropriate approvals)
2. Manufacturer’s Maintenance Programme
3. EASA Minimum Inspection Programme

Note: The EASA MIP is broadly similar to the FAA FAR ‘Appendix D to Part 43’ inspection and in that regard, is now broadly similar to FAA rules.

From the EASA website, FAQ n.43423 includes the following statement:

‘In accordance with Part-M Appendix VIII point (b)(9), the tasks that are part of the annual or 100h check contained in the ‘Minimum Inspection Programme’ do not qualify for pilot-owner maintenance referred to in M.A.803.’

Also:

‘…the declared AMP shall not be less restrictive than the ‘Minimum Inspection Programme’ (MIP) referred to in point M.A.302(i).’

https://www.easa.europa.eu/faq/43423

This means you cannot do less than is called up in MIP. Dress it up how you like but MIP is pretty much the same as any manufacturer’s maintenance schedule or the old CAA LAMS/LAMP – you have to take bits off to look inside then put the bits back on etc. MIP does it in less pages by having fewer individual tasks but it’s still the same.

The aircraft owner has always been responsible for ensuring that their aircraft has been maintained ‘correctly’, ie in accordance with the requirements. That’s not so say they are responsible for the ‘standard’ of maintenance (that remains the responsibility of the signatory of the Certificate of Release to Service (CRS)) but that maintenance has been carried out at the correct times.

Airworthiness Directives as published by the State of manufacture and the appropriate regulating authority for the State of registration (ie for the UK registered EASA CofA aircraft – EASA), remain as they always have been, legally mandatory.

Airworthiness Limitations which are covered in Chapters 4 and/or 5 of the aircraft’s Maintenance Manual are also legally mandatory.

Service Bulletins and other such continuing airworthiness data should be technically assessed and complied with as deemed necessary.

The SDMP ‘template’ (as linked in CAP 1454) is a template but actually perfect for the job it is designed to do. No one can complain that your SDMP data is incorrect if you’re using the CAA’s template.

The required signature for the ‘approval’ of the SDMP is either the owner or a contracted CAMO or the competent authority (CAA) – not all of them, only one is required. The SDMP is not approved by the CAA but of course they may come across it if they choose the aircraft for an ACAM survey at some stage.

FAA and EASA Airworthiness Directives are available free of charge. Some manufacturer’s provide all of their manuals and continuing airworthiness data FOC as well: Diamond, Tecnam, Extra, Lycoming, TCM and Rotax to name a few. Others choose to charge for the privilege of seeing the manuals, such as Cessna and Piper although SBs etc may be available FOC. Normally you can find current revisions of manuals from ‘unapproved sources’ if you look hard enough.

The signatory of the Airworthiness Review Certificate (ARC) is not responsible for ‘saying the aircraft is airworthy’. The signatory of the CRS for maintenance or a check signs to say that the aircraft is fit for release to service but not the ARC signatory. The ARC is, as its name suggests, a review of the maintenance carried out since the last ARC issue or extension. A new ARC also requires an inspection of the aircraft but not the complete aircraft – it’s more of a sampling exercise. The ARC signatory may not even be a licenced engineer.

Maintenance is a necessary evil that owners don’t like to pay for – it’s not the same as spending hard-earned cash on new avionics or paint etc. As some have said on this thread, there is a lot of background work involved in keeping the aircraft ‘airworthiness’ up to date, ie paperwork, ADs, SBs etc as well as pumping up the tyres and changing the oil and that labour input has to be paid for if the owner isn't confident in doing it themselves.

Hopefully, that clears some points up. Not all engineers are out to shaft owners – there are some very honourable ones out there. If in doubt, there are enough aircraft owners on this Forum to question as to how they get on. I know for a fact that many are quite happy with their engineering support. Find a good engineer, work with them to maintain your aircraft and it’ll pay dividends in the long run.

Lastly, if anyone has any other questions and is going to AeroExpo, the CAA have a stand there….
Last edited by aerofurb on Tue Jun 11, 2019 11:22 pm, edited 1 time in total.
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By Bobcro
#1699520
Thanks, just the clarification that I needed and as in Dragons Den I had chosen you before I asked. I am at Aero Expo on Thursday and Friday at the Sonaca 200 and hope to catch up with friends old and new and visit the CAA.