Regulations concerning Pilot performed preventative maintenance

Discussion in 'Maintenance Bay' started by alorio1, Apr 17, 2008.

  1. alorio1

    alorio1 Filing Flight Plan

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    c&p FROM 150cessna.tripod

    Regulations concerning Pilot preformed preventative maintenance


    What follows is excerpted from Part 43.

    Sec. 43.3 Persons authorized to perform maintenance, preventive maintenance,
    rebuilding, and alterations.....
    ..... (g) 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, 127, 129, or 135.

    Sec. 43.7 Persons authorized to approve aircraft, airframes, aircraft
    engines, propellers, appliances, or component parts for return to service
    after maintenance, preventive maintenance, rebuilding, or alteration.....
    ..... (f) A person holding at least a private pilot certificate may approve an
    aircraft for return to service after performing preventive maintenance under
    the provisions of Sec. 43.3(g).

    FAR 43, Appendix A.....
    ..... (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 certificate 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:
    (i) They are performed by the holder of at least 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 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; and
    (ii) The inspections and maintenance tasks are performed in accordance with
    instructions contained by the special inspection and preventive maintenance
    program approved as part of the aircraft's type design or supplemental type
    design.
    (31) Removing and replacing self-contained, front instrument panel-mounted
    navigation and communication devices that employ tray-mounted connectors that
    connect the unit when the unit is installed into the instrument panel,
    (excluding automatic flight control systems, transponders, and microwave
    frequency distance measuring equipment (DME)). The approved unit must be
    designed to be readily and repeatedly removed and replaced, and pertinent
    instructions must be provided. Prior to the unit's intended use, and
    operational check must be performed in accordance with the applicable
    sections of part 91 of this chapter.
    (32) Updating self-contained, front instrument panel-mounted Air Traffic
    Control (ATC) navigational software data bases (excluding those of automatic
    flight control systems, transponders, and microwave frequency distance
    measuring equipment (DME)) provided no disassembly of the unit is required
    and pertinent instructions are provided. Prior to the unit's intended use, an
    operational check must be performed in accordance with applicable sections of
    part 91 of this chapter.



    Now that I've shown you what work you are allowed to perform on an airplane here is the section that defines the "quality" of your work by establishing "performance rules".

    Sect. 43.13 Performance rules (general).

    (a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator, except as noted in § 43.16. He shall use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. If special equipment or test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus or its equivalent acceptable to the Administrator.

    (b) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).



    So, you can see from the above regulations, maintenance and preventive maintenance are two different things. Pilots may not perform maintenance without an A&P license, they may however, perform the preventive maintenance as specified above.
     
  2. Steve

    Steve En-Route

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    For completeness, most of those limitations do not apply to experimental category aircraft...
     
  3. stingray

    stingray Line Up and Wait

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    You can perform anything as long as you are being supervised by an A&P. The A&P does not have to do the work he just has to be there. Then sign it off.

    So if you need to do something to your plane buy a big pizza and a large soda. And give your favorite A&P a long lunch break or dinner break. If it is a longer job bring dessert.:goofy:

    Dan
     
  4. Stache

    Stache Pre-takeoff checklist

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    Just to clarify the rules a little bit more for pilot record entries under the supervision.

    Part 65 § 65.83 Recent experience requirements.
    A certificated mechanic may not exercise the privileges of his certificate and rating unless, within the preceding 24 months—
    (a) The Administrator has found that he is able to do that work; or
    (b) He has, for at least 6 months—
    (1) Served as a mechanic under his certificate and rating;
    (2) Technically supervised other mechanics;
    (3) Supervised, in an executive capacity, the maintenance or alteration of aircraft; or
    (4) Been engaged in any combination of paragraph (b) (1), (2), or (3) of this section.

    So the A&P has to be current and not a shade tree mechanic. And Part 65.81 states; 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.

    And the A&P must of performed the task before.

    So if the A&P meets all of the above and supervisors a pilot or mother inlaw perform maintenance Part 43.9 states:

    (a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
    (1) A description (or reference to data acceptable to the Administrator) of work performed.
    (2) The date of completion of the work performed.
    (3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
    (4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

    So now the pilots and inlaws name has to be in the maintenance sign off for the work performed.

    Just one man’s opinion.
     
  5. Tom-D

    Tom-D Taxi to Parking

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    How can you as an Airworthiness inspector prove that I have never preformed that work at an earlier date?

    Just curious, I have never figured out how that rule can be enforced.

    WE are not required to keep records of every log book entry we make, nor are we required to do recurrent training, or keep a training jacket on our selves.

    Tom Downey A&P-IA
     
  6. Tom-D

    Tom-D Taxi to Parking

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    Next question.

    Can an owner make entries in their aircraft logs and return to service after prevenitive maintenance, if they are not a pilot, A&P or a repairman?

    For example, I have a customer who owns his own aircraft and is only a student pilot. can he sign off his own logs without supervision?
     
  7. Stache

    Stache Pre-takeoff checklist

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    I didn't write the rules, I just put them out there to inform other of what they say. Aviation is built on trust that's why most pilots never ask to see your A&P cetificate they trust you have one and are properly trained and qualitified. Same goes for pilots we trust them they have one with the proper rating.

    I don't beleive I said you had to keep records of what you do as an A&P, but you must keep some kind of record for your IA. I just pointed out the rule its been around since 1958 and most people have never read it or forgot what it said. Its what you don't know that can get a person in trouble instead of what you do know.

    Just one man's opinion.
     
  8. stingray

    stingray Line Up and Wait

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    And it is not any different than if you took your plane to the same mechanic to have him work on it. The same rule applies. It has nothing to do with supervision. Is there any reason you do not like your name in the log book as the one that performed the work? I make all my own log entries then have them signed off. (You can actually read what I write or type). Are you saying that qualified mechanics don't need a good lunch?

    Dan
     
  9. Stache

    Stache Pre-takeoff checklist

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    I happen to be proud of the work I accomplish and use a word processor to make sure the record entry can be read and is legible. Many record entries can not be read or are full of jargon like R&R, IAW, and OK. I think these should be spelled out or referenced to the data is really the best way.

    Many Aircraft Owners and Operators have expressed a concern about whether or not there is a requirement for maintenance record entries to be legible.

    If we review Title 14 Code of Federal Regulations (CFR) Part 43, Section 43.9, we will see that the regulations does not have specific guidance concerning legibility requirements. However, if we look at Amendment 43-23, 47 Federal Register (FR) 41085, Sept. 16, 1982, we will find the following statement from the FAA: "Since legibility is a practical necessity and entries which are not legible do not satisfy the purpose of Section 43.9."

    Therefore, it seems that when we look at maintenance records, the entries, including signatures and certificate numbers, should be legible. I beleive this also applies to the other person who helps perform maintenance with just their name.

    Just one man's opinion.
     
  10. Tom-D

    Tom-D Taxi to Parking

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    I think you just danced around the answer, IA records are nothing more than activity sheet on how many 337s or annuals we do each year. they indicate nothing as far as what maintenance we preform over the years that we are A&Ps

    I didn't mean to imply you said anything, it was a simple question of how FSDO can prove I have never done the work before.

    But I take your lack of a method in your responce to indicate you can't enforce the rule.

    Also, I asked who can return to service of prevenitive maintenance, can a owner, not a pilot, sign off their prevenitive maintenance with out supervision.

    The rule says,

    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. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

    And 43.7 (f) A person holding at least a private pilot certificate may approve an aircraft for return to service after performing preventive maintenance under the provisions of §43.3(g).

    To me that says a "PILOT" must return to service, student pilots can't
     
  11. Tom-D

    Tom-D Taxi to Parking

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    As long as the FAA did not place that in the regulations, it is only your opinion, and non regulatory in nature. As you said the 43.9 makes no requirement that any entry must be readable.

    I was once told by the lead mechanic for the FAA that poor hand writting is a mechanics best insurance. I thought that was funny at the time.... but.
     
  12. timwinters

    timwinters Touchdown! Greaser! PoA Supporter

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  13. poadeleted20

    poadeleted20 Deleted

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    Stache's point on legibility is well-made. While Title 14 of the CFR's does not specifically state that required records must be legible, there is enough case law to over-gross a C-5 to support his position. When it comes to court, if you can't read it, it doesn't exist.
     
  14. Witmo

    Witmo Pattern Altitude

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    I am a properly licensed and current shade tree mechanic and take exception to this remark.
     
  15. Stache

    Stache Pre-takeoff checklist

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    All of us mechanics that hold A&P certificates are considered mechanics. However there are those who don't work in the industury except maybe one or twice a year to sign off a record entry they know nothing about. These are the shade tree mechanics who don't meet Part 65.83 recent experience that make the rest of us mechanic look bad. I sorry if I offend you, but there is a difference in mechanics we are either current or not.

    Its the ones that are not current that tend to cause most of the mistakes in our industry.
     
  16. Jebert

    Jebert Filing Flight Plan

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    I hasten to add that even PM work requires that the pilot doing it have the Service Manual for that aircraft, and a copy of AC 43-13B on hand and available in case the FAA guy happens to drop by the hangar.

    Having them open to the appropriate pages is a good thing, too. Saves the FAA guy from having to ask you "how did you know how much air and oil to put in your Cherokee struts?" and, "Is this safety wire .40 like it's supposed to be?" and, "Can I see all your mx logbooks, please?"

    Those publications at least address the level of performance required for doing PM work.
     
  17. Tom-D

    Tom-D Taxi to Parking

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    Show me the manual that tells us how to change oil. That's PM.
     
  18. Tom-D

    Tom-D Taxi to Parking

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    If a person with an A&P certificate that is working in a facility that does maintenance checks on heavy aircraft and never works on a small aircraft, should be sorted out and limited as to what they can do.

    The FAA data base is very convoluted as to who is really out there working and who is dead, out of country etc. that the FAA has no idea who is actually maintaining the GA fleet.

    I see log books at annual time that have no entries except the annual sign off from the years before, plus the transponder/altimeter checks and occasional ELT and AD compliance entries.. The Aircraft are in beautiful condition, you can tell some one is caring for the aircraft, and I know the owner has a tool box.
     
  19. Jebert

    Jebert Filing Flight Plan

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    Piper Cherokee Service Manual section 2-70 Lubrication proceeds to describe, in detail, the proper way to get access to the sump, drain the sump, change the oil filter, (or clean the screen) replace the oil filter (or screen) and then fill the sump with new (proper grade) oil.

    It's three pages long, (pp 107, 108, 109) and quite detailed. Following that are several pages of charts of which lubricants to use, and where they should be used.
     
  20. Tim

    Tim Line Up and Wait

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    Hurray for you! Now show the same for a cessna 140 and if you find that find a 46 T-Craft. Then find it for a 108 Stinson. Should we keep going?
     
  21. Jebert

    Jebert Filing Flight Plan

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    I simply showed NC19143 a manual that tells how to change oil, just as he asked.
     
    Last edited: Apr 27, 2008
  22. APIA57

    APIA57 Filing Flight Plan

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    After reading this thread, there is one significant detail that has not been addressed reguarding owner performed maintenance. FAR 43 App A (c) 30 (i). This requires that in addition to being the owner and having at least a Private, that the person performing the work ALSO have a certificate of competency. Yes this can be enforced and I have seen it done. Just a detail that you might consider.
     
  23. poadeleted20

    poadeleted20 Deleted

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    This applies only to "primary category aircraft." See 14 CFR 21.184 for more on primary category aircraft (which is separate from the usual normal/utility categories most all of us fly), although I'm pretty sure that if you had one, you'd know it. Other than this particular case, no "certificate of competancy" is required to perform preventive maintenance.
     
  24. jsadamson1

    jsadamson1 Pre-Flight

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    After reading this, I have a question for you guys,

    Under FAR Part 43.3 (G) it states that private pilots can perform general preventative maintenance to their aircraft. Then in Part 43 Appendix A it lists the definitions of preventative maintenance. The two I have in question is numbers (16) and (17).

    Does this mean that if my landing light rocker switch on be Beech C23 is going bad (very loose, wont stay on all the time) that I can change it out so long as I do a professional job and use actual replacement parts with correct part numbers? Also, if I did perform the work, will there need to be any log book entries?

    Also, as a side question, I can take off my cowling so long as the propeller and spinner do not need to be removed?

    I just bought a new plane and I am very mechanically inclined. I know there are rules in place to keep everyone safe, but I would also like to be able to maintain my plane (when legal) instead of paying a mechanic when it is not necessary.
     
  25. Tom-D

    Tom-D Taxi to Parking

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    Nope, that is not what the rule says...
     
  26. Tom-D

    Tom-D Taxi to Parking

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    FAR 43, applies to all aircraft, that operate in any operations not covered in the other operating categories. (135/121/119 etc), not just primary category.

    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. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

    as "Operator you can also work on other owners aircraft under the same rule..
     
    Last edited: Oct 27, 2011
  27. Skylane81E

    Skylane81E Final Approach

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    You must ALWAYS do a log entery when work is done, so yes you must log it.

    Is the switch part of the circut?

    And you may take off the cowl that doesn't require removing the prop. (some do)
     
  28. Tom-D

    Tom-D Taxi to Parking

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    that's a great idea,, but one thing you should do is, keep your A&P-IA informed about what you are doing, that doesn't mean you need their permission, but no surprises at annual time is a good thing.
     
  29. poadeleted20

    poadeleted20 Deleted

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    That sure seems to be what it says in item (16).

    14 CFR 43.9 pretty clearly says "yes." However, from your questions, one might think you aren't that familiar with aircraft maintenance procedures, so you might want to at least consult a licensed A&P mechanic for advice on both doing the work and making the log entry.

    Item (19) pretty clearly says yes.
     
  30. jsadamson1

    jsadamson1 Pre-Flight

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    Yes, the switch is part of the circuit, I just wanted some clarification. This eases my mind as a mechanic wanted to charge me 85 an hour for an hour + to do the work. It is so easily accessible I couldn't justify the charge just yet.
     
  31. jsadamson1

    jsadamson1 Pre-Flight

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    You are correct! Actually now that I have a confirmed answer that I can do the work, my next research topic is to find out how to make sure I do it according to maintenance procedures and properly sign enter it into the logbook. Do you have any advice as to where I might find these answers (assuming an A&P is not readily available to talk to locally)?
     
  32. Tom-D

    Tom-D Taxi to Parking

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    Call me 1-360-202-0961
    Tom Downey A&P-IA
    www.whidbey.com/fairchild-nc19143/
     
  33. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Final Approach PoA Supporter

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    If it's not logged, it didn't happen.

    Then you should have bought an Experimental - Amateur built aircraft.
     
  34. poadeleted20

    poadeleted20 Deleted

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    AC 43.13-1B (available on the net here) gives the basic rules for performance for all maintenance work, and there's a section on electrical stuff like yours. As for the log entry, read 43.9 (which is in even the pilot version of the FAR/AIM books) for the requirements, and look at some past entries in the logs to get a feel for the style.
     
  35. poadeleted20

    poadeleted20 Deleted

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    There's no reason a competent person can't do most of the maintenance on their own Standard category plane themselves as long as they ask the right questions of the right people before they do anything they don't know, and get appropriate supervision and signatures from the right people during and after the work.
     
  36. jsadamson1

    jsadamson1 Pre-Flight

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    Appreciate all of you help guys. Sorry for the lack of quotes, but I am using my iPhone and have not figured out how to yet.

    To the a&p, I will more than likely give you a call when it comes time for the work. I appreciate the help!

    To the dude who said by an experimental, no thanks!! I don't mind paying someone to do work to be legal, at the same time, I don't want an experimental plane just to work on it myself but if I am able to save some change and do the work myself legally, then I would like the option to do so! I own a 78 sundowner and love it!!
     
  37. jsadamson1

    jsadamson1 Pre-Flight

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    Ron, I agree. On that topic, one more question. I took off the cowling today to look around and see where a minor oil leak was coming from. To my surprise I found out of 4 valve covers, two of them had the lower screw backed out enough that I took my finger and gave it a 1/4 turn to tighten. This is also where my slow drip was coming from. What should I do to keep the screws from backing out? My guess is buy a new set of screws with a better locking star washer and have them put on when my mechanic changes out my valve cover gaskets. The last thing I need is to loose a valve cover mid flight!!
     
  38. Tom-D

    Tom-D Taxi to Parking

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    Quote from post #36 "I own a 78 sundowner and love it!!" He has a M/M he best use it.
     
  39. Tom-D

    Tom-D Taxi to Parking

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    Remove the valve cover screws, clean them with Phosphoric acid "loc-tite rust remover jelly" and a fine write brush, then rinse with hot water, allow to dry, then coat all threads except the first 2 with RED "loc-tight" allow to set over night and replace when the loc-tite is hard.

    use new gaskets :) too.
     
  40. Tom-D

    Tom-D Taxi to Parking

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    Changing the valve cover gaskets is a very easy do, why pay for it ?