Peter wrote:
except that AD compliance is never within pilot privileges even if purely visual.
Peter,
There are some AD’s which may be performed by the pilot. If so, it is stated in the AD itself.
Cobalt wrote:
I don’t know if @NCYankee says you cannot do these things, he just says they are not maintenance. In general, doing anything to your aircraft that does not change it is allowed. Otherwise you would not be able to operate it at all.
I would agree except I would add the word “preventive” before maintenance.
Michael wrote:
Mind you, I’m not suggesting that ANY of the above actions carried out by an Pilot / Owner would be part of an Annual or 100 Hour Inspection, but rather just possible Field Checks that are clearly in the context of Preventative Maintenance.
The FAA defines Maintenance in CFR 14 1.1 as:
Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance
By definition, an inspection that is not listed as “preventive maintenance” is maintenance. Simply looking at something and taking no action may not be an inspection, but if it is done for any airworthiness required reason or a log book entry is made, the pilot operator can’t sign the entry to return the aircraft to service. So I don’t agree with your assertion they are clearly in the context of Preventive Maintenance.
There are other things that would not be considered as maintenance such as normal pre-flight inspections, cleaning, servicing (adding air or topping off oil), sending oil samples for analysis, etc. But performing a compression check, inspecting a wing spar, doing a weight and balance update, checking the ignition timing, putting an RG aircraft on jacks and performing gear retraction cycles to verify normal operation are not in the class of field checks to be performed by pilots and do not fall under preventive maintenance, pre-flight inspection, or servicing and I would find it hard to argue they are allowed as preventive maintenance. All these tasks are covered in the maintenance manual for the aircraft or engine involved.
Somebody operating a G-reg recently posted here that th CAA has de facto removed his pilot maintenance privileges, by requiring an EASA66 engineer involvement on some inspection… I can’t find the thread but vaguely recall it was a PA28 and that all of them lost this option as a result. But this is off topic for an N-reg discussion… except that AD compliance is never within pilot privileges even if purely visual.
I don’t know if @NCYankee says you cannot do these things, he just says they are not maintenance. In general, doing anything to your aircraft that does not change it is allowed. Otherwise you would not be able to operate it at all.
Simple example – you can of course check if light bulbs are working. The list then allows you to change light bulbs if they are not working.
So as long as you can do the maintenance bit (e.g., removing panels) using the list, you of course can have a look (in whichever way you like). You also can weigh the aircraft, take photos of it. You can also jack it up (how else would you replace a tyre?).
None of these personal inspections, however, count; if for example a 100-hourly inspection of the wing spar is required because of an AD, you can look at it all you want, it does not count as that required inspection.
NCYankee,
Question: In your opinion, would ANY of the following examples fall within the scope of Pilot/Owner preventative maintenance, and would you kindly state why or why (or not) for each operation :
- Taking oil samples during an oil change to be sent out for analysis
- Removing an inspection plate then employing a borescope to inspect a wing spar
- Removing the cowls to clean the engine with appropriate products
- Putting the aircraft on scales to “check” the weight
- Putting a RG aircraft on stands and performing gear retraction cycles to verify normal operation and E extension
NCYankee wrote:
Some are called out as required on a 100 hour inspection or annual. Instructions on how to perform each of the tests is covered in the aircraft, engine, or accessory maintenance procedures.
So what difference does it make if such & such a procedure is called out in an Annual or 100 Hour Inspection ?
Mind you, I’m not suggesting that ANY of the above actions carried out by an Pilot / Owner would be part of an Annual or 100 Hour Inspection, but rather just possible Field Checks that are clearly in the context of Preventative Maintenance.
Michael,
I don’t think any of those tasks would be considered as preventive maintenance that can be performed by the pilot-owner. Some are called out as required on a 100 hour inspection or annual. Instructions on how to perform each of the tests is covered in the aircraft, engine, or accessory maintenance procedures.
NCYankee wrote:
If you can find the task in this list, it can be accomplished as preventive maintenance by the owner if they have a private pilot license or better, if not then no.:
I would add that there is a bit of wiggle room to perform tasks such as :
- Checking the magneto to engine timing since the Part 61 pilot/owner is allowed to R & R the cowl and a spark plug. That said, he is NOT allowed to do anything to the magneto if he does indeed find it is out of timing.
- Perform a compression check & borescope. Once again, since R & R of the cowl and the plugs is permitted.
- Check the fuel injection system per the Continental instructions, since R & R of the cowl and replacing fuel hoses is permitted. Once again, if the pilot/owner is NOT allowed to actually make any adjustments to the system as that would require an A&P.
Maoraigh wrote:
#12
and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under Sec. 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 Administrator; "Does this negate ALL pilot maintenance privelages?
That passage is a bit confusing, but my interpretation is that limitation only pertains to this part :"approved special inspection and preventive maintenance program "
and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under Sec. 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 Administrator; "
Does this negate ALL pilot maintenance privelages?
