Australian Helicopters

The need to highlight the potential failure resulting from damage to the tail rotor blade by issuing this AD is understood and acknowledged. However, the practical application and the results of the pre engine certification are arguable. Recent discussions with other operators ( Australia and overseas) indicate that all operators have a very good understanding of the intent of the pre engine start inspection requirements but do not see any increase in the continuing airworthiness of the aircraft as a result of the certification. The issue with this AD concerns the pre engine start certification. The remainder of the AD requirements are accepted, indeed we implemented these some time ago as a standard inspection. The following are considerations and observations in relation to the AD requirements. 1. Currently the pilot must inspect and certify that the tail rotor blades are not damaged prior to engine start. The AD is written in such a manner that there may be occasions where the inspection of the TR blades is not possible, thereby rendering the aircraft un-airworthy and unable to fly. This may occur in situations such as: a. Tail of the aircraft inaccessible due to landing area (over water, extreme height, platform landings and uneven terrain.) b. Extreme weather conditions such as heavy rain and wind. c. No details are provided for the relief of the AD requirements in such situations. 2. The detail of how the inspection is to be performed is not included. That is, is the inspection performed with the use of ladders and stands to gain access for a close visual inspection, or is the inspection performed from the ground as is the situation during a preflight inspection? 3. Operational conditions may exist where the aircraft has continuous operations where the engines are operated without shutdown for a considerable period such as the case with firefighting operations. I submit, that a detailed inspection performed by a LAME endorsed on type as a daily (prior to first start of the day) will provided the necessary oversight to the serviceability of the blades. The ?daily? inspection is to be performed with the use of stands or ladders and a strong light source, specifically inspecting for damage and repairing or replacing the any blade with damage (IAW AMM ICA). The pilot is still to perform a visual inspection of the Tail rotor blades as part of the preflight inspection (without certification for the AD). This inspection will provide a greater level of safety as the LAME has detailed knowledge of the damage limitations and is able to react to any deficiencies immediately, thereby removing the potential for a pilot decision which may not be as informed. Justification: 1. The certification requirements for a pre engine start inspection do not provide any additional safety to the aircraft. 2. The pre flight inspection performed by the pilot IAW the procedures in the AFM include inspection of the tail rotor blades. 3. Whilst not specifically detailing the inspections of the blades for damage, this implied as standard inspection and engineering practices. Questions: 1. Is there an underlying issue with the manufacture and quality control of these blades? 2. Has the manufacturer indicated that an alternative solution to this issue is being considered? 3. Considering the nature of the defect, and the urgency of informing operators, why was the effective date delayed until the 21 May 2008?