Question on owner performed maintenance

[russfarris]

This came up at our local EAA chapter meeting tonight. Most of us do our own maintenance as outlined under FAR 43, Appendix A, which lists the tasks we as aircraft owners with a private certificate or greater can perform, such as oil and filter changes, spark plugs, tires, ect.
The following is a quote from FAR 43, Appendix A.

Refering to items listed that are classified as preventative maintenance performed by owner pilots:

"They are performed by at least the holder of a private pilot certificate issued under Part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under section 147.21 (e) of this chapter, (2) issued by the holder of the production certificate for that primary category aircraft that has a special training program approved under Sec. 21.24 of this subchapter, or (3) issued by another entity that has a course approved by the Adminstrator."

OK, what does this mean? I need another piece of paper (certificate of competency for the C-170) before I can change my own oil? This isn't new, Part 43 was last updated 5/31/96

Since we all know George Horn stays up late nights studying the FARs, maybe he can explain exactly what the requirements are for owner performed maintenance. Does anyone know? Russ Farris

[Tom Downey]

Russ,
Anyone can work on any aircraft. Knowing that, it is a matter of who can return to service.

read FAR 43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.

If you are not an A&P but you have completed a training course for a certain aircraft you may be elegable for a repairmans certificate which allows you to return that aircraft for return to service.

[jrenwick]

Refering to items listed that are classified as preventative maintenance performed by owner pilots:

"They are performed by at least the holder of a private pilot certificate issued under Part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under section 147.21 (e) of this chapter, (2) issued by the holder of the production certificate for that primary category aircraft that has a special training program approved under Sec. 21.24 of this subchapter, or (3) issued by another entity that has a course approved by the Adminstrator."

OK, what does this mean? I need another piece of paper (certificate of competency for the C-170) before I can change my own oil?

You quoted paragraph (i) of this:
(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided: (i)....

I read this to mean that what you quoted only applies to item 30: the other piece of paper is only required to perform tasks that weren't mentioned in the other 30-odd items of Appendix A, but that were called out as PM in the Type Certificate or an STC.

Best Regards,

John

[GAHorn]

Russ, ...Appdx A of FAR 43 describes Preventive Maintenance. It lists 32 items that constitute Preventive Maintenance (PM). Item 30 is what you posted a partial quote of.
Item 30 refers to special inspections and procedures that are specifically identified by the type certificate holder (or STC holder) as being a PM function. The partial quote you posted merely explains that IF a particlular model airplane has a special inspection procedure that is specifically identified as PM by it's TC/STC holder....then the owner may perform that procedure IF he's been certificated (trained) to do so (and then it gives examples of the authorities that may issue such certificate.)
For example: You own a FlopWith Camel (a replica WWI fighter with a Lycoming.) The mfr of that airplane requires that it undergo a detailed inspection of the engine valve lifters before every flight as a Preventive Maintenance item. You, as a 1/100th partner in the airplane, attend the mfr's special school, offered in an overnight course in Joe's Bar and Grille, on how that PM procedure is to be accomplished, and actually PASS the course! (picture that!) You get the certificate of course completion. Now, as an owner, you may tear down that engine and perform that required PM because you met the rule you quoted.
Hope that helps. (and it's now early in the morning so that bit of info is offered with a huge disclaimer.)

[russfarris]

Sorry I didn't read the paragraph in question a little more throughly, I could have saved myself some embarassment. In my defense, it was my IA, as the guest speaker at our EAA chapter that brought this up. Two FAA airworthiness inspectors present allowed that they had never heard of the "Certificate of Competency", but they would get back to us (standard government reponse.) All is well, I can keep changing tires and
oil. Russ Farris

[GAHorn]

Yep. You just can't change your brakes (no matter that you have to remove and replace them in order to change the tires and repack wheel bearings) and you can't change your ELT battery (unless it's the EBC type that's installed as removeable equipment in the cockpit.) Go figure.

[Tom Downey]

Yep. You just can't change your brakes (no matter that you have to remove and replace them in order to change the tires and repack wheel bearings) and you can't change your ELT battery (unless it's the EBC type that's installed as removeable equipment in the cockpit.) Go figure.

I hope you meant is, that you can't re-line your brakes when you have them removed for a tire change.

Any pilot can change the batteries in an ELT, but they can't comply with the inspection required in 91,207,(d) 1-4

see item 24 in FAR 43 Appendix A

the wording does not limit batteries to "aircraft Batteries" so you can do them all.

[GAHorn]

Yep. You just can't change your brakes (no matter that you have to remove and replace them in order to change the tires and repack wheel bearings) and you can't change your ELT battery (unless it's the EBC type that's installed as removeable equipment in the cockpit.) Go figure.

I hope you meant is, that you can't re-line your brakes when you have them removed for a tire change.

Any pilot can change the batteries in an ELT, but they can't comply with the inspection required in 91,207,(d) 1-4

see item 24 in FAR 43 Appendix A

the wording does not limit batteries to "aircraft Batteries" so you can do them all.

Yes, changing brakes (or linings) does not fall under Preventive Maintenance, despite the fact that removal/reinstallation of existing linings is necessary to perform other Preventive Maintenance items.
AppdxA, Item 24 refers to aircraft ship batteries...not avionics memory/performance batteries which require disassembly of the unit, and/or removal of aircraft structure for access. (This according to the SAT FSDO avionics inspector, A. W. Carter.) 91.207 (d) is exactly the sort of item that Appdx A, item (30) refers. A separate certification is required in order for an owner/pilot to change ELT batteries. I was very surprised (not to mention caught off-guard) to learn this. I too, once thought item 24 applied to ELT batteries. (No mfr of ELT's to my knowledge offers such certificate with regard to their units or batteries.)

[Bruce Fenstermacher]

George and Tom
I think you'll find the elt battery change thing is a gray area depending on who you ask and where your located.

Here in Quakertown PA if your tied down on the west side of the field you can change your elt battery and brake lining thickness always seems to improve just after the wheel bearings are repacked. Now if your on the east side of the field it's a different story.

[Tom Downey]

"""AppdxA, Item 24 refers to aircraft ship batteries...not avionics memory/performance batteries which require disassembly of the unit, and/or removal of aircraft structure for access. (This according to the SAT FSDO avionics inspector, A. W. Carter.) """

I will send you a E-mail address that you should send that info to.

Mr O'Brien is the lead in this area, have him inform the mr carter that a battery is a battery.

Watch your e-mail.

[Tom Downey]

Upon re-read of your statement.. disassembly of structure never has been allowed, but if you read the ICAs that come with the new ELTs you will see a pilot can change the batteries, check for proper operation.

[GAHorn]

ICA's (Instructions for Continued Airworthiness) are merely mfr's instructions (albeit approved data.) Mfr's do not have the authority to authorize pilots to become maintenance technicians, so ICA's should not be viewed as superceding FAR's. ICA's are also not defined as Preventive Maintenace. They are required maintenance. IMHO
Niether batteries nor databases may be changed in avionics by owner/pilots unless provision has been made by the mfr for such change to be made without removal of the unit from the aircraft and without disassembly of aircraft structure for access. (In other words, the battery or database must be front-loaded/mounted. I believe none of the ELT's of are so designed.)
(These tasks fall under the "Do as I say ...not as I do" category. I think it's ridiculous that owner/pilots should be prevented from changing self-contained batteris in avionics that are simple, straight-forward designs,...Cleveland/McCauley type brake linings... and pre-fabricated hydraulic hoses....but the FAA has not asked me my thoughts on this subject lately.)

[Bruce Fenstermacher]

ICA's (Instructions for Continued Airworthiness) are merely mfr's instructions (albeit approved data.) Mfr's do not have the authority to authorize pilots to become maintenance technicians, so ICA's should not be viewed as superceding FAR's. ICA's are also not defined as Preventive Maintenace. They are required maintenance. IMHO

George, I would think that an approved ICA which specifically specifies the pilot can perform certian maintenance proceedures would be the approving authority to do so.

After all it is the "Instruction For Conitnued Airworthiness". And it is approved data.

What else would you be looking for.

[zero.one.victor]

Bruce, to take it to a ridiculous level, what about the mfr that sez "drive it like a car! anybody can fly this plane!" FAR's still require you to hold a pilot certificate.
I have to agree with george on this issue, at least as fas as the FAR's being the final word. But this stuff is alot like an "owner-assisted annual"-- the owner's doing the actual work, the IA is directing & supervising him.

Eric

[Tom Downey]

I couldn't say it better my self..

"""George, I would think that an approved ICA which specifically specifies the pilot can perform certian maintenance proceedures would be the approving authority to do so. """


Where does the FAR's say?

"""AppdxA, Item 24 refers to aircraft ship batteries...not avionics """

I believe the lack of specific wording leaves the door open. Changem if you gotem. I have my owners do it sign it off using the PPL number. No problems with SEA FSDO.