Can a pilot decowl the airplane

TMetzinger

TMetzinger

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Tim
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Related to our discsussion on "Operator" and airworthiness - is a pilot legal to remove the nose cowling as part of the preflight inspection, then re-cowl the airplane when done?

Does this action need to be entered in the maintenance logs?
 
It seems reasonable since an aircraft owner can do his own oil changes.
 
I would think that Part 91 you could uncowl an airplane. I have been told (but have not looked up any documentation so I could very well be wrong) that in Part 135 you cannot do anything which requires tools. So if your cowling has a quick release mechanism you are OK. If it requires a screwdriver, not so much so.
 
smigaldi said:
I do it all the time for oil changes. Why would it have it removed and replaced have to be in the maintenance log?
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As an owner/operator, you can certainly do that (and you do log the oil change), so let me refine the question...

I'm really thinking about renters - the FAA may not consider the renter pilot the owner or the operator of the airplane. Can the renter pilot still do any of the "allowed" maintenance tasks? Can he remove the cowling?

The reason I have questions was that I was told in no uncertain terms by an IA that I could NOT change the landing light on the rental airplane, because I was neither the owner or the operator. This wasn't a reflection on my limited wrench skills because this IA had watched me change landing lights on an airplane I owned.

So, FBO concerns aside, would the FAA find a FAR violation in a rental pilot pulling the cowling on a 172 as part of the preflight?
 
TMetzinger said:
The reason I have questions was that I was told in no uncertain terms by an IA that I could NOT change the landing light on the rental airplane, because I was neither the owner or the operator.
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I guess this must be the alternate definition of "operator". In the other thread I thought the consensus was that the pilot was the "operator" (although I'm still not convinced). I guess that was your point...
 
TMetzinger said:
So, FBO concerns aside, would the FAA find a FAR violation in a rental pilot pulling the cowling on a 172 as part of the preflight?
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FAR 43.3(g) does say the holder of a private certificate or higher can perform preventive mx as outlined in appendix A, which specifically allows "(19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls." As for the whole operator question, I think if an FAA guy wanted to find a way to bust someone, perhaps they'd play that card. But if not, well, I frankly don't think it's an issue.
 
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Everskyward said:
I guess this must be the alternate definition of "operator". In the other thread I thought the consensus was that the pilot was the "operator" (although I'm still not convinced). I guess that was your point...
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I'm a pretty firm believer that a rental pilot is NOT the "operator", but FSDO opinions apparently vary. I believe a rental pilot IS the PIC, and there's a certain amount of due diligence (inspections, no open squawks that affect airworthiness, etc) that is required.
 
TMetzinger said:
I'm a pretty firm believer that a rental pilot is NOT the "operator", but FSDO opinions apparently vary. I believe a rental pilot IS the PIC, and there's a certain amount of due diligence (inspections, no open squawks that affect airworthiness, etc) that is required.
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I agree with you there. I also agree with Ken in that the FAA might play the operator card if they really want to go after you for something for whatever reason, but that it's not generally a thing to be that concerned about.
 
I'm gonna disagree here. The renter is the operator of the aircraft, and has full authority to do the mx specified of the 'owner/operator' in section 43.

I believe the IA is incorrect in his assessment, and has a personal axe to grind about the work in question, whether it is an oil change or a light replacement.
 
Not in my case - he'd have been happy to have me change the light (we are good friends), he felt that would be an issue.

Unless Ron or someone else can weigh in with some rulings or opinions, it seems we've got a bunch of people whose opinions I respect on both sides of the "who is the operator?" question, so I'm gonna treat it as undefined for now.
 
Keep in mind that many Rental agencies are Part 141 operators and all maintenance must be returned to service by the DOM. or as their certificate states.

And if the renter is a student, they have no pilots number to use in the return to service entry.
 
NC19143 said:
Keep in mind that many Rental agencies are Part 141 operators and all maintenance must be returned to service by the DOM. or as their certificate states.

And if the renter is a student, they have no pilots number to use in the return to service entry.
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OK - does removing the cowl and putting it back on require an entry and return to service? Your message implies that it does, to me at least.

Additionally - the operations I've used are definitely 141 operators, which might have explained the landing light issue too.
 
For those who do not understand airworthiness I have a PPS presentation that the SEA FSDO uses to train the IAs at the annual seminar..

E-Mail me at ([email protected]) and I will send it to you, it will not attach here.
 
TMetzinger said:
OK - does removing the cowl and putting it back on require an entry and return to service? Your message implies that it does, to me at least.

Additionally - the operations I've used are definitely 141 operators, which might have explained the landing light issue too.
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It is a maintence action under 43-appendix A "prevenitive maintenance" thus technically it must be logged. ad returned to service along with and other stuff that was done.
 
docmirror said:
I'm gonna disagree here. The renter is the operator of the aircraft, and has full authority to do the mx specified of the 'owner/operator' in section 43.

I believe the IA is incorrect in his assessment, and has a personal axe to grind about the work in question, whether it is an oil change or a light replacement.
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I quote: "FAR 43.3 (g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter." (My emphasis)

Aren't flight schools Part 121 aircraft? I'm a Canadian, so I'm not sure, but we have here in Canada similar regs that allow the owner of an aircraft to do certain tasks on their privately-registered airplanes, and commercially-registered aircraft have a much shorter list of permissible tasks. Removing and reinstalling a cowling is OK for the private but not for the commercial here.

Dan
 
US FARs
FAR 121.1 to 121.1400-121.1499 OPERATING REQUIREMENTS: DOMESTIC, FLAG, AND SUPPLEMENTAL OPERATIONS.
 
CHAPTER I--FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF TRANSPORTATION

PART 141--PILOT SCHOOLS
 
NC19143 said:
Keep in mind that many Rental agencies are Part 141 operators and all maintenance must be returned to service by the DOM. or as their certificate states.

And if the renter is a student, they have no pilots number to use in the return to service entry.
Click to expand...

And a renter probably doesn't have access to the log books either.

--david
 
Hmmm.... last week when flying a rental plane for a lunch with some other POAers, the plane did not start after lunch. I called the FBO, and they more or less told me to poke around at the bendix, which was stuck (and had happened on some other recent flights).

Not being comfortable doing that myself, I got help from a local A&P.

When I returned to the FBO, I "squawked" the problem (and they assure me it will be fixed).

Should that have been logged by someone?

If I had done it myself, would that have been legal?

--david
 
dparter said:
Hmmm.... last week when flying a rental plane for a lunch with some other POAers, the plane did not start after lunch. I called the FBO, and they more or less told me to poke around at the bendix, which was stuck (and had happened on some other recent flights).

Not being comfortable doing that myself, I got help from a local A&P.

When I returned to the FBO, I "squawked" the problem (and they assure me it will be fixed).

Should that have been logged by someone?

If I had done it myself, would that have been legal?

--david
Click to expand...

You should have had the A&P replace the starter and sent the bill to the FBO, then you would have known it got fixed.
 
docmirror said:
I'm gonna disagree here. The renter is the operator of the aircraft, and has full authority to do the mx specified of the 'owner/operator' in section 43.
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14 CFR 1.1 seems to support your view:

Operate, with respect to aircraft, means use, cause to use or authorize to use aircraft, for the purpose (except as provided in §91.13 of this chapter) of air navigation including the piloting of aircraft, with or without the right of legal control (as owner, lessee, or otherwise).

Seems like a pretty broad definition.
 
But looking at this from a real world perspective, if the FAA really thinks a renter should be prohibited from decowling a plane, then they have their heads up their asses. It's a couple of freakin' screws for cripessakes!!!!!!
 
TMetzinger said:
As an owner/operator, you can certainly do that (and you do log the oil change), so let me refine the question...

I'm really thinking about renters - the FAA may not consider the renter pilot the owner or the operator of the airplane. Can the renter pilot still do any of the "allowed" maintenance tasks? Can he remove the cowling?
Click to expand...

Since uncowling the plane can fall within the scope of a preflight (PIC has a wide latitude on preflight, and the Feds will never set precedent of saying "No, you don't have to look at that") since you have to be satisfied of airworthiness, I say PIC can pull cowl, no worries.. I frequently pull cowls on preflight.
 
Devils advocate - what if it is a flying club and you're a member - then aren't you technically a partner, meaning owner?
 
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flyersfan31 said:
But looking at this from a real world perspective, if the FAA really thinks a renter should be prohibited from decowling a plane, then they have their heads up their asses. It's a couple of freakin' screws for cripessakes!!!!!!
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There isn't a single screw in my cowl, yet I'll wager you can't get it off.
 
I went out once to fly one of my father's rental 172s back in 1978 and I had to remove the top cowling during the preflight to get to the service manual that was laying on the cylinders. The 172 had flown a lot since it's last maintenance. I don't rent out my airplanes and I really don't care what kind of maintenance you might want to call it. I would never feel comfortable letting the average pilot R&R the cowling unsupervised. Where would we be at if the cowling flew off on the next renter because it wasn't installed properly. I couldn't allow that if it were my rental, I would drag a mechanic out to do the job if the pilot would feel better.

Regards, Kevin
 
It's an interesting situation - as we've covered in this and the "operator" thread, when a commercial entity dispatches an airplane to a pilot, the entity is the "operator", and is warranting that the airplane is airworthy at the time of dispatch.

How far the rental pilot goes beyond taking that assurance from the dispatch process and doing his normal preflight is a matter to be negotiated between the pilot and the operator. Your concern about a pilot causing damage by not replacing the cowl properly has merit.

I don't think we've reached agreement that removing/replacing the cowl (and doing nothing else) is a "maintenance" event that needs to be in the airframe log. If it IS a maintenance event, then for some FBO/Schools operating under part 141 the airplane cannot be returned to service without the specified person (Maint. Dir. or designate) signing it off.
 
NC19143 said:
Don't focus on the cowl, focus on the prop.

Here's a screen saver for ya to study.
Click to expand...

Hmmm. Vice grips near the #4 cylinder.

Can I figure it out from that picture? It would be easier in person, I would think.
 
The true question is not if you can get it off but whether you'd like to have it in tack. It's like flying. Everybody knows that almost anybody, even a kid with MSFS experience could get a plane off the ground but it takes someone with experience to end a flight with a usable aircraft.

I could get it off... :D
 
Greg Bockelman said:
Hmmm. Vice grips near the #4 cylinder.

LOL you are the first person to catch that.. that's in lew of the latch that opens the cowl separation seam, the latch was yet to be made, it is in place now, and works great. there is one in back too.
But you can't sepatate the cowl far enought to get it to come over the prop anymore with out cracking it, and getting your head broke by the old mech standing behind you.

Can I figure it out from that picture? It would be easier in person, I would think.
Click to expand...

Prolly, but all you need is your fingers to remove the latch safety pin, and open the latch to spread the cown far enought to clear the cylinder supports and lift it off. but the prop must be removed first.

Got an A&P certificate? you can do it legal.
 
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