ADD status when MEL revision affects open defect.

[Neil Armstrong]

I guess thinking more about this all these different issues could or should be answered by the way in which the previous revision is deemed still valid or not, hence my search in my Co's docs for written help to no avail.

The MEL I was involved with recently had two issues, firstly the MEL code had changed in the new revision and so no longer referred to the item concerned, the original item was now under a different code and had become more restrictive, the second item had been coded under a different ATA from 46 to 23 if I recall correctly.

The Captain I spoke with was confused as the old ATA MEL codes were now different in the new MEL and he had no access to the old revision MEL and so he asked me about this, I changed the MEL code to the more restrictive new code and inoped the item whereas before it did not have to be made inop. My MOC then said I didn't needed to have done that and I replied by asking where it says I don't have to and it went all quiet..... my argument was that the only MEL on board did not accurately reflect the ADD and so was confusing to the crew in this case.

[Alber Ratman]

I guess thinking more about this all these different issues could or should be answered by the way in which the previous revision is deemed still valid or not, hence my search in my Co's docs for written help to no avail.

The MEL I was involved with recently had two issues, firstly the MEL code had changed in the new revision and so no longer referred to the item concerned, the original item was now under a different code and had become more restrictive, the second item had been coded under a different ATA from 46 to 23 if I recall correctly.

The Captain I spoke with was confused as the old ATA MEL codes were now different in the new MEL and he had no access to the old revision MEL and so he asked me about this, I changed the MEL code to the more restrictive new code and inoped the item whereas before it did not have to be made inop. My MOC then said I didn't needed to have done that and I replied by asking where it says I don't have to and it went all quiet..... my argument was that the only MEL on board did not accurately reflect the ADD and so was confusing to the crew in this case.

The crew will be operating to the new MEL. My view mate is if the MEL data has changed, etc, the ADD MUST BE REVIEWED regardless of what Maintrol or LMC think to align the ADD entry to the MEL. The crew should be rejecting to fly the aircraft if it does not tie up. They fly the aircraft to the restictions of the MEL, not the Tech log. The Tech log only tells them there is a deferred defect and is released against the MEL. That document is the one that tells them what they can fly with or not. I have seen MEL defects raised as non airworthiness defects and have had no hesitation in closing the one raised in error and transfering it to a MEL ADD. Your arguements are exactly the same as I would put forward, there is no grey area on that IMHO. You are the certifier not the guy in Maintrol (that in some companies is not even a licence holder!) I doubt it is the sort of thing you would find in PART M for such senario's (bar all defects must be investigated before being deffered). Company proceedures could be so muddy as to be worthless. I have just started somewhere else and the basics I have discussed have had me raising eyebrows very much like Mr Spock! I could not believe what I was hearing TBQH.

[Neil Armstrong]

I am of the opinion that the Part M should review all current ADD's prior to the new MEL revision hitting the streets and ask Part 145's to correct, amend, adjust as required to the new revision otherwise how else can the Operator be sure he remains in compliance?

As I say me thinks a question for our beloved regulator..................

[Alber Ratman]

I do not disargee Neil, the company PART M should do look at the MMEL or their restrictions to the MMEL and tie things up.. Alas you know like me that sometimes nobody actually can communicate across a desk or corridor. If the type Cert Holder is changing the MMEL, they will give EASA enough warning and the NRA to PART Ms should know.. Or is this a change by Company? However I still stand that as the certifier you will be the bloke doing the changes to get compliance anyway. Nobody else will ammend the info in the TL of reflect the changes or carry out the rectification to correct the ammendments.

[Neil Armstrong]

Thanks Alber, not sure if the changes were Operator or OEM/EASA driven but I guess either way, as you say, the Part M should react to new revisions in advance. It was simple for me in my example when a skipper was unsure. I will be following this issue up via SMS and if no good then thru the CAA as it does seem to be a gray area.

[Jarwot]

Is there a reluctance to contact the CAA here. If in doubt ask them (CAA)

[Neil Armstrong]

Hi Jarwot, no reluctance just surprised it doesn't seem to have been formally covered before in Company manuals.

[Jarwot]

The MEL is part of the aircraft flight manual so there may well be a bit of confusion between quality and flight ops. Early days of Ops1 caused a lot of problems with the guy looking after flight manuals coming up with required items which maintenance JAR145 did not, in first aid kits for one thing. Operators pay a lot of money to the CAA C of A's registration etc and even more when introducing new aircraft to the UK. So always feel the CAA should be the bible on all matters even if you ask them a question and the response is can I come back to you! You know the guy is not sure but there is no doubt he can get the answer.

[Alber Ratman]

The MEL is part of the aircraft flight manual so there may well be a bit of confusion between quality and flight ops. Early days of Ops1 caused a lot of problems with the guy looking after flight manuals coming up with required items which maintenance JAR145 did not, in first aid kits for one thing. Operators pay a lot of money to the CAA C of A's registration etc and even more when introducing new aircraft to the UK. So always feel the CAA should be the bible on all matters even if you ask them a question and the response is can I come back to you! You know the guy is not sure but there is no doubt he can get the answer.

Very true as well. Then again, if Flt Ops and Compliance are similar to others I have seen, communication was almost non existant.

[Jarwot]

Got to agree Alber. One operator I worked for had a monthly meeting with reps from quality, operations, aircrew and engineering, which worked well not sure it carried on but it did help in understanding each sections problems. OK a bit of a while back but I think a good idea. Thinking about it maybe quite a way back as the aircrew rep was a flight engineer! And he did have some worrying ideas, he never quite saw documented limitations as the norm to release an aircraft for flight. One of his concerns was brake wear limit pins, brake still in limits if pin not flush. He wanted to introduce replacement of brakes with 4/5 mm still above flush. After a lot of chat about manufacturers already having built in margins and then advised of the costs involved he did back down reluctantly.