Engine Maint. Question

[JasonCT]

Greetings Everyone,

Here is a question that I am a little unsure of. If you own your own plane, how much maint. can you leagally do not being and a&p ?

Your thoughts always appreciated.

~Jay

 

[ejensen]

You can do most anything under the direct supervision of an A&P. Alone you're limited to prevatative maintenance defined in Appendix A of FAR part 43. Still have to follow proper procedures including logs and return to service. Other than really minor stuff I bought manuals and got training first:

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:
(1) Removal, installation, and repair of landing gear tires.
(2) Replacing elastic shock absorber cords on landing gear.
(3) Servicing landing gear shock struts by adding oil, air, or both.
(4) Servicing landing gear wheel bearings, such as cleaning and greasing.
(5) Replacing defective safety wiring or cotter keys.
(6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.
(7) Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. In the case of balloons, the making of small fabric repairs to envelopes (as defined in, and in accordance with, the balloon manufacturers' instructions) not requiring load tape repair or replacement.
(8) Replenishing hydraulic fluid in the hydraulic reservoir.
(9) Refinishing decorative coating of fuselage, balloon baskets, wings tail group surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear, cabin, or cockpit interior when removal or disassembly of any primary structure or operating system is not required.
(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices.
(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.
(12) Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.
(13) Replacing side windows where that work does not interfere with the structure or any operating system such as controls, electrical equipment, etc.
(14) Replacing safety belts.
(15) Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.
(16) Trouble shooting and repairing broken circuits in landing light wiring circuits.
(17) Replacing bulbs, reflectors, and lenses of position and landing lights.
(18) Replacing wheels and skis where no weight and balance computation is involved.
(19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls.
(20) Replacing or cleaning spark plugs and setting of spark plug gap clearance.
(21) Replacing any hose connection except hydraulic connections.
(22) Replacing prefabricated fuel lines.
(23) Cleaning or replacing fuel and oil strainers or filter elements.
(24) Replacing and servicing batteries.
(25) Cleaning of balloon burner pilot and main nozzles in accordance with the balloon manufacturer's instructions.
(26) Replacement or adjustment of nonstructural standard fasteners incidental to operations.
(27) The interchange of balloon baskets and burners on envelopes when the basket or burner is designated as interchangeable in the balloon type certificate data and the baskets and burners are specifically designed for quick removal and installation.
(28) The installations of anti-misfueling devices to reduce the diameter of fuel tank filler openings provided the specific device has been made a part of the aircraft type certificiate data by the aircraft manufacturer, the aircraft manufacturer has provided FAA-approved instructions for installation of the specific device, and installation does not involve the disassembly of the existing tank filler opening.
(29) Removing, checking, and replacing magnetic chip detectors.
(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:

 

[ScottM]

In adition to the last post you can do all the maintenance you want as long as you are supervised by an A&P or if you built at least 51% of the plane that requirment can be waived.

 

[RotaryWingBob]

In adition to the last post you can do all the maintenance you want as long as you are supervised by an A&P or if you built at least 51% of the plane that requirment can be waived.

I guess that's right, but it will be a cold day in hell before I fly any aircraft that I worked on

(Seriously, and I mean very seriously, lacking in mechanical skills...)

 

[Henning]

I guess that's right, but it will be a cold day in hell before I fly any aircraft that I worked on

(Seriously, and I mean very seriously, lacking in mechanical skills...)

See, that's why I think owner maint/no owner maint is an over rated issue. For the most part, owners who will do their own work on their own plane are a pretty skilled and safe bunch. Small planes aren't particularly complicated (actually the opposite), and any reasonably adept mechanic can work on one. The owners who aren't mechanically inclined, they aren't gonna work on their planes for the most part, they know better. I think as an "issue" this probably only covers 2% of owners who would scum patch a plane.

 

[Bill]

See, that's why I think owner maint/no owner maint is an over rated issue. For the most part, owners who will do their own work on their own plane are a pretty skilled and safe bunch. Small planes aren't particularly complicated (actually the opposite), and any reasonably adept mechanic can work on one.

I agree. I'm not quite sure I want to build (I have a 3 year old daughter who deserves my time more than a pile of rivets), but buying a plane and not being able to do the maint bothers me. I've worked on every car and bike I've ever owned, done countless valve adjusts, accessories (alternators, water pumps, fans, you name it), done tranny swaps, replaced clutches on front wheel drivers (sometimes no small feat), done CV's, U-joints, driveshafts, more brake jobs than I can count, etc.

While I would definately want some A&P oversight the first time I was inside an engine, I have no doubt I could do most all of the other mechanical work. As an electrical engineer, I could probably do a good job on the avionics as well.

And, I don't just go hacking into the job, I've bought the factory service manual for each vehicle, and study the repair/maint to be accomplished, and make sure all tools/parts/materials are on hand before starting the job.

Oh well. Nice choice, spend countless hours building your own, get an A&P, or not be able to work on your plane. If anything keeps me in the realm of renting, it will be mx and wondering about user fees. I see user fees as potentially very damaging to aircraft values. Not so sure I want to pony up until the dust settles.

 

[Tom-D]

Greetings Everyone,

Here is a question that I am a little unsure of. If you own your own plane, how much maint. can you leagally do not being and a&p ?

Your thoughts always appreciated.

~Jay

You can do anything your A&P is willing to supervise, and return to service.

I supervised 2 engine rebuilds, a fabric recover, last year by thier owners.

 

[gismo]

In adition to the last post you can do all the maintenance you want as long as you are supervised by an A&P or if you built at least 51% of the plane that requirment can be waived.

I'm pretty sure that the owner of an experimental aircraft can legally do all the maintenance, whether he built all or none of it. The 51% rule governs signing off your own condition inspection (experimental version of an annual).

 

[Henning]

I'm pretty sure that the owner of an experimental aircraft can legally do all the maintenance, whether he built all or none of it. The 51% rule governs signing off your own condition inspection (experimental version of an annual).

That is correct. On an experimental that has it's blessings from the Feds, the only thing that plane will need an A&P to sign for is the annual condition inspection, and the 51% rule can get you a repairmans certificate for that airframe that will allow you to do that as well. ALSO, You do not have to be the origional builder of the plane. Talk to the FSDO man. If you take the plane apart substantially (51%+) and put it back together with their involvement, they can issue you one as well. Talk to them first so you know what the person/office you are working with wants to see and when.

 

[poadeleted20]

You can do anything your A&P is willing to supervise, and return to service.

Note that to the FAA, "supervise" means direct supervision, i.e., physically present and immediately available to assist. Telephonic supervision, supervision of your work in your T-hangar from his office in the maintenance hangar, etc., does not meet the FAA's idea of "supervision." See 14 CFR 43.3(d) for the exact verbiage.

 

[PoAdeleted5]

deleted.

 

[Tom-D]

Note that to the FAA, "supervise" means direct supervision, i.e., physically present and immediately available to assist. Telephonic supervision, supervision of your work in your T-hangar from his office in the maintenance hangar, etc., does not meet the FAA's idea of "supervision." See 14 CFR 43.3(d) for the exact verbiage.

My Primary air worthiness inspector at FSDO says that I can supervise as much as it requires to insure a complete, and safe repair.

When doing the fabric re-covers I do not watch each and every stitch, I teach, then observe, and when satisified the owner can do the job they can work on thier own, but I will inspect every thing they do.

The FAA feels that when I sign off on a return to service, it is the same as if I did the job. I am legally and morally responsibie for the repair.

to quote the reg..

(d) A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally -->

observes the work being done to the extent necessary

<-- to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation. However, this paragraph does not authorize the performance of any inspection required by Part 91 or Part 125 of this chapter or any inspection performed after a major repair or alteration.

 

[Stache]

To answer your question can you work on your airplane? The answer is yes, HOWEVER you need to read part 43.9 you have to work under the DIRECT supervision of and mechanic. This does not mean available by cell phone, but the person should be in the general area or close to where the work is performed. This rule goes on to say your name has to be in the record entry indicating what work you performed.

The only thing you cannot perform is inspection this cannot be delegated to anyone, only the certificated mechanic can perform the inspections.

The 51% rule is only for home builder that built there own aircraft and have built at least 51%, which means they can be issued a Repairman certificate to perform the Condition Inspection and sign it of.

If you own a experimental aircraft anyone can work on it, however only a A&P, Repair Station with the proper rating or the builder with a repairman certificate can sign off the Condition Inspection.

Stache

 

[Witmo]

I may have missed it but besides being the owner, don't you have to be at least a private pilot to do any of the approved mx tasks? A student pilot who owns his own airplane would not be legal to change his own airplane's oil, or am I wrong?

 

[ScottM]

I may have missed it but besides being the owner, don't you have to be at least a private pilot to do any of the approved mx tasks? A student pilot who owns his own airplane would not be legal to change his own airplane's oil, or am I wrong?

According to part 43.7(f) a private is required as the minimum to return a plane to service after performing preventative maintenance.

But 43.3 (g) states that except for Sport Pilots any person who holds a pilot certificate issued under part 61 may perform preventative maintence on any aircraft owned or operatoed by that pilot. Sprot pilots can only do maintenance on LSA aircraft.

61.83 discussed how a student pilot certificate is granted, so it would seem to me that if a student pilot owned their own aircraft they are authorized under 43.3(g) to perform preventative maintenance but a private pilot would have to verify the work and return the plane to service under 43.7(f)

Other opinoins??

 

[Tom-D]

""" This does not mean available by cell phone, """

There are others in your organization who think different. They believe that;

(d) A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform,

if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation.

However, this paragraph does not authorize the performance of any inspection required by Part 91 or Part 125 of this chapter or any inspection performed after a major repair or alteration.

There is NO statement that says "DIRECT"

Opinions count, but I think your wrong.

 

[ScottM]

There is NO statement that says "DIRECT"

Opinions count, but I think your wrong.

To be fair Stache did go on to say

but the person should be in the general area or close to where the work is performed

Which is a true statement but is more indicative of the definition of indirect supervision

 

[Tom-D]

To be fair Stache did go on to say Which is a true statement but is more indicative of the definition of indirect supervision[/SIZE][/FONT]

Let us say you are restoring an aircraft that requires a lot of riveting, you are doing this in your garage. you are not an A&P, but are a very good mechanic.

You own all the tools that are required to do this job, I have taught you how to do the riviting, and have watched you you do it several times with good results.

You are working, I am watching, and it is getting late, I go home and you continue to work, You mess up a buck tail. You quit (lke you were told to) and call me in the morning and tell me what you did, I say I'll be right over.

The rule as written, says I can't send my flunky to help you, I must do it.

The rule says "(d) Snip .... if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation."

It says nothing about me being there when the work is done.

When you think about the director of maintenance of a repair station working non A&Ps, the DOM would have to be watching every one at the same time, and we know that doesn't happen. And yet they sign off the repairs every day.

 

[Tom-D]

I will admit that working over the phone doesn't work in this situation.

" if the supervisor is readily available, in person, for consultation."

Not for me anyway, just try to teach some kid how to tie thier shoes over the phone..... I just can't.... there is subsitution for being shown how.

 

[Stache]

Lets take a look at direct supervision and see what it means. For example part 61.51 is about pilot logbooks and pat 91.109 safety name (direct supervision). So from a pilots view you can see a second pilot is required for training and should be sitting next to you directly supervising.

Here are several references I found where the word direct supervision is found:

AC 65-31 Trainee. An individual participating in a training program for an NDI method who is not yet qualified. Trainees should obtain work experience only under the direct supervision of a Qualified Instructor, Level II, or Level III in the same method. Trainees should not independently conduct tests; make, accept or reject decisions; or perform any other NDI functions.

AC 141-1 For the purpose of FAR Part 141, the term "direct supervision" would require that the chief or assistant chief instructor be present at the base when instruction is being given (this will only involve ground training given by noncertificated instructors).

AC-187-2 Direct supervision of designees to ensure they are performing assigned authorized functions in accordance with the appropriate regulations, policies, and procedures.

AC120-42 Maintenance Training . program should focus on the special nature of ETOPS. This program should be included in the normal maintenance training program. The goal of this program is to ensure that all personnel involved in ETOPS are provided the necessary training so that the ETOPS programs are properly accomplished and to emphasize the special nature of ETOPS maintenance requirements. Qualified maintenance personnel are those that have completed the operator's extended range training program and have satisfactorily performed extended range tasks under the direct supervision of a FAA certificated maintenance person; who has had previous experience with maintaining the particular make and model aircraft being utilized under the operator's maintenance program

FAA Order 8130-2 (c) All maintenance and inspection of the aircraft must be conducted under the direct supervision of qualified personnel holding appropriate licenses issued or rendered valid by the [insert country of registry] CAA and according to [insert country of registry] aircraft maintenance requirements.


Now on the maintenance side which part 21, 43, and 65 covers.

Part 43 does not use the work DIRECT, but says “under the supervision” I will concede that.

Part 65.81(a) states:A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with §§65.85, 65.87, and 65.95. However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned.

Part 65.107 which is for Light Sport aircraft say “If that person has not previously performed that work, the person may show the ability to do the work by performing it to the satisfaction of the FAA, or by performing it under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned. The repairman may not exercise the privileges of the certificate unless the repairman understands the current instructions of the manufacturer and the maintenance manuals for the specific operation concerned.”


Part 21.289 Major repairs, rebuilding and alteration is really for manufactures, but again it says “Inspects, or is in direct charge of inspecting, the repair, rebuilding, or alteration”.

What all this is points to is what does is mean? In our case direct supervision sounds like it means the person should be close by. The legal system I believe would agree and talking to some on a cell phone is not direct supervision when it comes to performing maintenance. I could be wrong, but part 65.81 is pretty hard for an A&P to get around when it say under the direct supervision of a certificated and appropriately rated mechanic. However direct supervision is excluded under preventive maintenance as FAR 1.1 explains under the term maintenance.

Stache

 

[Tom-D]

What all this is points to is what does is mean? In our case direct supervision sounds like it means the person should be close by. The legal system I believe would agree and talking to some on a cell phone is not direct supervision when it comes to performing maintenance. I could be wrong, but part 65.81 is pretty hard for an A&P to get around when it say under the direct supervision of a certificated and [/COLOR]appropriately rated mechanic. However direct supervision is excluded under preventive maintenance as FAR 1.1 explains under the term maintenance

Student training is not what we are discussing.

Don't you think pilot training is a bit absurd, as a reference here? who would want to try to do it remote? When I allow a owner to work alone the training is already completed. unlike a student pilot it is a lot easier to inspect the results after the work is completed. We always have the opportunity to do it over. unlike the student pilot.

Training is not the issue, the quality of the work is, and this can be assured by inspection after completion. I don't have to see a rivit being bucked wrong to tell it was. and my being at the scene will not stop a bucking bar from slipping.

There is no requirement for the superviser to be on site in FAR 43.3 (d). But there is a requirement, "the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly."