Preventative maintenance and what is allowed?

[1964-M20E]

I was reading this article in AOPA magazine August 2023 issue.  While they didn't give any examples outside the list, it appears that according to the FAA themselves you can do more than what is listed in the 31 specific items listed as PM.  According to the article the list is not all inclusive.

[toto]

FAA P-8740-15 Maintenance Aspects of Owning Your Own Aircraft [hi-res] branded.pdf

A bit more detail from FAA

[EricJ]

There's a legal opinion letter from the FAA (often referred to as the "Coleal letter"), that states that the "Preventive Maintenance" list in Part 43 Appendix A(c) is not comprehensive, and the definition of "Preventive Maintenance" as "simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations" indicates that many other tasks may fall in that category.    There's not a ton of other detail relevant to our operations provided in the letter, but this is one source of where the idea comes from that the Part 43 App A(c) list is not limiting, despite there being language elsewhere that says it is (the Coleal letter addresses this).

One point in the letter is that what might qualify as Preventive Maintenance on one airplane may not on another, e.g., the list states that changing tires is Preventive Maintenance, but doing so on some large aircraft would not meet the definition of PM as "not involving complex assembly operations".     So judgement must be exercised.

The usual advice that if your IA agrees something is PM, then you can treat it as PM, probably applies.  

[TCC]

Keep in mind you can also perform work beyond PM under the supervision of an A&P or IA. Not all mechanics support owner-assisted maintenance, but some do.

If I didn’t enjoy wrenching and our A&P/IA didn’t support it, I would not do as much work as I do on the plane and little things add up over time.

[PT20J]

There are a few things to keep in mind. First, some of the FARs are often clear as mud. A former FAA attorney once said at a flight instructor refresher clinic I attended that the FARs are "A monument to vagueness." His point was that it is difficult and time consuming to go through the rule making process to change a rule, so the FAA prefers to give themselves as much leeway in interpretation as possible. This brings up the second point that you cannot really understand the FARs unless you read all the legal interpretations. Sometimes, the interpretations appear to contradict the language of the FAR itself. This is the case with the Coleal interpretation (attached) which is the basis of Mike's article. Basically, the idea here is that you can do more than outlined in the FAR so long as what you are doing is reasonably equivalent to one of the operations listed. That's not really very black and white and certainly open to interpretation.

I think the best course is to develop a good working relationship with an A&P/IA and discuss maintenance with them ahead of time. There are lots of options for working on your own airplane including preventive maintenance you do yourself, work you do under supervision, and help you provide the mechanic. A lot of mechanics are more open to having the owner involved these days because they have more work than they can do themselves. Just discuss it beforehand and find something that works for both of you.

Skip

Coleal - (2009) Legal Interpretation.pdf

[wombat]

@PT20J That was a really interesting legal interpretation. Thanks for posting it!

[A64Pilot]

I don’t think a “Legal interpretation” is anymore regulatory than an Advisory Circular or Mandatory Service Bulletin is.

The point is you can’t “pin” the FAA down, they are too slippery.

However they all carry some weight with the FAA.

99 times out of 100, even if your wrong, but your apologetic and thank them for pointing out your error you will be fine, the 1% is either your argumentative or your actions were plainly way off base.

But even something that falls into PM can get you into trouble, changing a light bulb, if accessing that light bulb has you removing aircraft structure to get to it for example.

The not involving complex operations is how Garmin can get away with selling you a yoke mount for a 2.5 lb. GPS that’s so heavy that it will cause the airplane to roll if you let go of the yoke. To me that’s an obvious Major Alteration, but I’m not in the FAA.

From what I’ve seen living where I do, the truth is on owner maintenance is that nobody cares, FAA may get involved if there is an accident or complaint.

 

[N201MKTurbo]

The FAA doesn’t really police individual aircraft owners. They have enough work to do policing the airlines, repair stations and service facilities. 
 

If you are going to work on your airplane, try to do it as properly as you can. The FAA doesn’t usually go after people who are trying to do things right. If you are trying to cut corners, that is a different story.