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European-reg owner-pilot maintenance privileges

From here

Howard wrote:

Am I allowed to replace this bulb myself under EASA regulations or do I need to ask a man with a posh certificate to unscrew about six philips screws and swap out the bulb then do the cover screws up again? The plane is a G-Reg TB20.

Yes and no. :-) Changing the bulb is permitted as pilot/owner maintenance, but that possibility must be written in the maintenance program. Otherwise, you need someone with a posh certificate.

ESKC (Uppsala/Sundbro), Sweden

AFAIK changing any bulb is permitted pilot maintenance, EASA and FAA. There are some past threads on it. Why would one need a maintenance programme to support already permitted pilot maintenance privileges? I have a reference from 2012 here. The pilot can change any bulb, so long as no special tools etc are required.

Normally this sort of thing is done off the books. Accordingly, an old joke is that the bulbs in AOC aircraft (the bulb has to be traceable back to a batch covered by an EASA-1 form, a work pack has to be raised, etc) last for ever

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

AFAIK changing any bulb is permitted pilot maintenance, EASA and FAA. There are some past threads on it. Why would one need a maintenance programme to support already permitted pilot maintenance privileges?

You must distinguish between two things:

  1. What pilot/owner maintenance can be permitted
  2. What pilot/owner maintenance is actually permitted for a specific aircraft

Your reference shows what kinds of pilot/owner maintenance can be permitted. But to actually be permitted, it has to be listed in the maintenance program of the individual aircraft as pilot/owner maintenance. In other words, no pilot/owner maintenance is “automatically” permitted. Also, pilot/owner-maitenance is not possible in aircraft used in commercial ops.

The actual rules for this are spread out over part-M which is possibly the most incomprehensible of the EASA regs, but this paragraph is pretty clear:

M.A.803 (c) The scope of the limited Pilot-owner maintenance shall be specified in the aircraft maintenance programme referred to in point M.A.302.

The only things you, as a pilot, can do “automatically” are those which are described in the AFM as normal operational tasks.

Part-M Appendix VIII (b): ….Any task described in the aircraft flight manual as preparing the aircraft for flight (Example: assembling the glider wings or pre-flight), is considered to be a pilot task and is not considered a Pilot-owner maintenance task….

ESKC (Uppsala/Sundbro), Sweden

I simply cannot believe we have this complicated maze of regs for this trivial topic which – in the UK at least – has many decades of precedent. The link I posted is very clear. Most planes have no custom maintenance programme, and maintenance is done “IAW the mfg MM” and that’s it.

The UK is going to be leaving the EU before too long also.

And there are so many EASA regs that it’s like the old joke about standards; they are wonderful because there are so many to choose from

In reality you obviously do this off the books.

The only people who can’t are the poor sods who are over the barrel, with a tight maint company/CAMO and a tied hangarage+maintenance contract. Those have to fly to another airfield which doesn’t have that problem, and flying elsewhere for maintenance is another popular GA activity which underlines what a bloody mess the GA scene is in, with so many people scraping a living out of the bottom of a barrel. Or those who can’t pick up a screwdriver… but they will always pay heavily.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

In reality you obviously do this off the books.

The only people who can’t are the poor sods who are over the barrel, with a tight maint company/CAMO

Right. But including these things in the maintenance programme is really not difficult. It’s a PIA, certainly, but not more. Having the aircraft under CAMO doesn’t preclude pilot/owner maintenance.

ESKC (Uppsala/Sundbro), Sweden

Who would go to the hassle of preparing a custom maintenance programme when that EASA doc lists practically everything which one might want to do and be able to do without having one’s own maintenance facilities?

We’ve had a few threads on it here, and it is basically people who want to get around some onerous local-CAA requirement, but most of the really useful stuff (e.g. avoiding the UK 150hr annual-like check) will never get approved.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Who would go to the hassle of preparing a custom maintenance programme when that EASA doc lists practically everything which one might want to do and be able to do without having one’s own maintenance facilities?
Every EASA aircraft has an individual maintenance programme anyway. You can’t just have a standard one for the type as there will be always be individual differences, different ADs etc.

I’m not talking about an owner-declared maintenance programme here — that is something else.

ESKC (Uppsala/Sundbro), Sweden

The MM for the TB20 (IAW which the maintenance is done) makes no statement about pilot maintenance privileges, nor does it need to.

That practically nobody actually performs all the tasks listed in the 100 or so pages, is a separate matter.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

The MM for the TB20 (IAW which the maintenance is done) makes no statement about pilot maintenance privileges, nor does it need to.

The MM is not the maintenance programme. The maintenance programme will reference the MM, certainly.

ESKC (Uppsala/Sundbro), Sweden

Peter wrote:

AFAIK changing any bulb is permitted pilot maintenance, EASA and FAA. There are some past threads on it. Why would one need a maintenance programme to support already permitted pilot maintenance privileges? I have a reference from 2012 here. The pilot can change any bulb, so long as no special tools etc are required.
Normally this sort of thing is done off the books. Accordingly, an old joke is that the bulbs in AOC aircraft (the bulb has to be traceable back to a batch covered by an EASA-1 form, a work pack has to be raised, etc) last for ever

I know of a recent example of an engineer being flown from the UK to the South of France by GA just to change a nav light bulb in an airliner.

Darley Moor, Gamston (UK)
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