Owner Preventive Maintenance?

“Hey Kurt, can you come over and sign off the new wing bolts I installed in my Bonanza?” or similar is a much too often request made of me as an A&P.

But I will say God bless the owner for even asking for another set of “licensed” eyes to look at the work performed. Much of owner maintenance never gets a second look.

14 CFR Part 43, Appendix A, Subpart C, lists the 31 tasks that may be performed by a pilot/owner as preventive maintenance, but I’ll not reprint them here.

First note of interest is that you can perform preventive maintenance only if you hold a pilot certificate and are the owner of the aircraft.

The FAA views owner-maintained aircraft in such a dim fashion that they actually prohibit our friends of the north in Canada from operating owner-maintained aircraft in the U.S. airspace system. Canada, due to the size of the country, and remoteness of so many areas, has a special certification known as “Owner Maintenance,” out of necessity, I presume.

An owner can apply to have their aircraft certified as “Owner Maintained,” the serial number of the airframe and engine are modified, and the registration is so noted. The owner can then perform all maintenance on the aircraft in perpetuum.

The aircraft even must be visibly placarded so that any passengers climbing aboard can see the warnings about airworthiness or lack thereof. I personally was pursuing the purchase of an aircraft like this, but the tasks and hurdles to get it licensed by the FAA were so daunting, that I gave up and looked elsewhere.

It is interesting to note that a person can build an aircraft from scratch as experimental, maintain the aircraft as the builder, and fly anywhere in the USA. Even home-builts in Canada can fly in the U.S. airspace system, but the “Owner Maintained” aircraft are still banned from the USA.

Canada appears to be the only country with a certification such as this, probably because of a lack of certified mechanics for hundreds if not thousands of miles in remote areas. But I digress.

One does not have to look far in this digital age to find numerous stories of aircraft accidents, some fatal, with a finding or probable cause due to owner-performed preventive maintenance far exceeding the scope of 14 CFR Part 43.

My example above is not fabricated. Owners replacing wing bolts far exceeds, in this author’s opinion, the scope as allowed by the FAA.

Other examples include owners adding oil filters incorrectly, causing oil starvation even though the sump is full, owners changing alternator belts requiring removal and re-installation of the propeller, adding fuel flow sensors with massive fuel leaks on first flight, and an owner who decided to repaint his elevators, re-installing the trim tabs with reverse direction of movement, which was fatal. The stories never end. Hardware store type nuts and bolts can be one of the first tell-tail signs of un-supervised owner maintenance.

I see these quite often. I do, however, also understand the desire to exceed the scope of 14 CFR Part 43 in vintage aircraft. If you have owned your 1940 Culver Cadet for 50 years, you undoubtedly will know more about that aircraft than almost any A&P. However, will that additional set of eyes on your family aircraft really hurt? Food for thought. I also understand if your seaplane develops an oil leak in some northwoods lake, you might be inclined to change out that leaking starter adapter yourself. Just look back at the previous paragraph, and you’ll likely conclude you don’t want to be included as a statistic.

Speaking to our new digital age, I am continuously astonished at the number of pilot/owners, who post messages on the popular websites representing the owners of Piper, Beechcraft, Cessna, Mooney, and other aircraft, asking questions that would seem to admit work on aircraft far exceeding the scope of 14 CFR Part 43.

One recent story was a pilot/owner, who while away from his home airport, found a leaking engine-driven fuel pump on his big-bore, TCM 6 cylinder engine. He had a replacement shipped in and installed it himself. He was asking the general membership if a mechanic signoff was necessary for this. Not only is a repair such as this not allowable under preventive maintenance, but proper installation requires specialized tools and test equipment, and there are numerous service bulletins issued to properly setup the engine for proper operation. The possibility of engine damage to outright stoppage are the risks in this scenario.

What was even more discouraging than the question was the range of answers the pilot/owner received from the membership. But let us givecredit where it is due. In this story the pilot/owner was not sure, and they at least asked.

All that being said, I applaud aircraft owners in their desire for learning about the inner workings of their flying machines, and the development of their skills and knowledge in working on their own aircraft. Many

consider it therapy in their lives, especially in the society we all live in today. However, I think it unwise to experiment and hone one’s skills on

a machine that can carry friends and loved ones into the sky, without a second set of eyes looking at the craft.

The obvious solution here is to contact a licensed A&P (IA if an annual inspection) before you start the work on your aircraft. Develop a plan that works for you and the A&P. Working on your own aircraft can be rewarding not only financially, but also in the knowledge and experience you can gain from the work, and the satisfaction of putting your aircraft back into the sky safely. You don’t have to contact one of the gold medal full service FBO’s to accomplish this. There are many freelance A&P mechanics who would be happy to assist in accomplishing your goals. You can be a part of the solution and save some dollars along the way.

You can replace tires, safety wire, cotter keys, hoses (except hydraulic hoses), simple fabric patches, batteries, position and landing light bulbs, lubrication, safety belts, and others as well. The recent list includes

31 items that are included in preventive maintenance. The Coleal ruling/interpretation from 11 years ago would infer that this list of 31 items is

not all exhaustive. Search it out on the internet if you’d like to dive in. You have to remember to analyze the scope of what has to be done using simple processes. Servicing a strut with nitrogen might be simple on a PA-28, but very complex on an Aero-Commander 500.

A pilot/owner can also swap self-contained, front panel mounted, tray and connector mount avionics with same type units. Exceptions are

autoflight systems, transponders, and DME units. If your Garmin GNS430 becomes inoperative, you can buy another, and swap the unit yourself with just a log entry. I would caution owners to stick with identical part numbers on any avionics unit, however. Some similar looking units are only single voltage, some 14/28. Programming the I/O streams might be needed in order for it to operate properly. If you don’t know the difference between ARINC 429, RS232, RS422, and discreet inputs and outputs, I would seek out some help before attempting to program a replacement unit of any type. A recent trend in avionics design is that the small memory circuit containing the setup of the radio and its configuration are mounted in the tray/connector instead of in the radio. This means that any replacement will automatically reload the proper configuration upon powerup in your aircraft. If you’re not sure, ask!

We at the FAASTeam are here to promote safety. I personally believe that a pilot/owner who knows their aircraft through first-hand maintenance is

a better and safer pilot. I encourage all owners to be as closely involved in the maintenance of their aircraft as their lives will allow.

But, of course, please do it in the safe and legal manner. Alas, achieving an Airframe and Powerplant license for yourself is always a possibility depending on your time availability and skill sets. The certification is good for life, and no medical is required. This is perhaps why senior folks like me are still around turning wrenches on aircraft, and enjoying it! There are always options out there and I encourage all to completely investigate them. Fly safe!