Replacing Circuit Breaker

[Dick Denenny]

Quick question to the group. Does replacing a circuit breaker fall under Owner Maintenance like replacing a fuse?

Thanks Dick

[A64Pilot]

In my opinion, no.

My reasoning is it can’t be accomplished by “simple means” but then my opinion carries no weight.

[Utah20Gflyer]

In my opinion this would fall under owner preventative maintenance because you are replacing a standardized part that requires no complex disassembly or reassembly.  I’m going off my interpretation of the Coleal legal interpretation on the issue.   

Generally you are only removing 2 screws and one nut and then replacing them to reinstall the breaker.   The operation is approximately as complex as installing a new battery which is explicitly allowed.  If this seems like a stressful operation I would recommend having an A&P assist you with it, or maybe supervise you doing it yourself.  
 

You might ask the IA who does your annual what they would think of you replacing the breaker and logging it. 
 

This opinion is also just my own and also carries no weight.   

[N204TA]

Per Part 43, Appendix A, unless it’s a landing light circuit, I vote no.

[Ragsf15e]

That’s explicitly not a complete list though, and the task is simple and uses standard parts as @Utah20Gflyerpointed out. If comfortable, I’d do it and log it.

[EricJ]

What does or doesn't fall under Preventive Maintenance is a bit grey and therefore subject to a wide variety of opinions.   The best approach is to ask your IA, since they'll have to sign off an annual with whatever work you may do in the logbook.   By reg you should log any maintenance you do as Preventive Maintenance, so if your IA is okay with it and will sign off a subsequent annual with that work in the logbook, go for it.    An easy alternative is to talk to a cooperative A&P that will let you do it and then supervise (by inspection or whatever) and sign it off.    Even then it's best if you make the log entry and put your name on it, and then the A&P sign it to return it to service.

 

[A64Pilot]

I know on my Mooney just accessing the CB to change it is not a simple operation, perhaps mine is different?

However asking a bunch of pilots if they are allowed to accomplish a maintenance task is likely to get a different answer than asking a bunch of maintainers if a pilot is allowed to accomplish the task.

Of course then there is the guy who says record it on a piece of paper, then lose the paper after a year too.

[Mark89114]

My ovation I wouldn't want to change a CB unless on the top row, the others are buried in a sea of wires that you can look at, but would be damn near impossible to gain access.

The funny thing is it looks like it has a hinge to allow panel to open, but there is no slack in the wires.  I have no idea.

 

[N204TA]

25 minutes ago, Ragsf15e said:

That’s explicitly not a complete list though, and the task is simple and uses standard parts as @Utah20Gflyerpointed out. If comfortable, I’d do it and log it.

 CFR 14, Part 43, Appendix A, (c) begins:  “Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations.”
 

It seems pretty clear to me that if the task isn’t on that list, it’s not preventive maintenance, period.

[Hank]

7 minutes ago, N204TA said:

 CFR 14, Part 43, Appendix A, (c) begins:  “Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations.”
 

It seems pretty clear to me that if the task isn’t on that list, it’s not preventive maintenance, period.

Except the FAA has written that this list is not exhaustive but representative. 

There is a lot you can do under the supervision of an A&P, too.

Edited July 29 by Hank

[Will.iam]

3 minutes ago, N204TA said:

 CFR 14, Part 43, Appendix A, (c) begins:  “Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations.”
 

It seems pretty clear to me that if the task isn’t on that list, it’s not preventive maintenance, period.

And that was clear until the Coleal legal interpretation on the issue. which the FAA specifically stated that list is not all inclusive and that other maintenance can be done as well. What those items are is unfortunately left to the A.I. you deal with or you can request every single item to have the FAA weigh in on each and eventually we will have enough rulings on individual items after most of us are long dead. Bottom line FAA specifically stated the task list is not the only things an owner is allowed to do even though that is exactly the wording the FAA has written. 

[201Mooniac]

Here is the interpretation mentioned so you can read and make your own decision.

Coleal-Bombardier Learjet_2009_Legal_Interpretation.pdf

In there it states:

Many preventive maintenance tasks are listed in 14 C.F.R. part 43, appendix A, paragraph (c). The paragraph sets forth in 32 numbered subparagraphs items the FAA has determined to be preventive maintenance. Even though the introductory text of subparagraph (c) states that "[p]reventive maintenance is limited to the following work

... ." (emphasis added), in view ofthe broader definition ofpreventive maintenance in section l. l , we believe that such limitation'is not controlling.

[EricJ]

In addition to the above notes and citations of the Coleal letter, it also references AC 43-12A, which also helps provide some guidelines on what might or might not be Preventive Maintenance.    As the Coleal letter points out, it says, "Also, because of differences in aircraft, a function may be preventive maintenance on one aircraft and not on another."  It then makes one of my favorite points on the topic, "Owners and pilots must use good judgment when determining if a specific function should be classified as preventive maintenance."

So, yeah, it's pretty grey, but a risk in an owner making an assumption on their own is that the IA at the next annual might have an issue with it.    If you clear that hurdle first, or get an A&P to sign it off, you have a much better chance of it not being an issue at the next annual, solely due to the IA having a differing opinion on what is or is not PM, which is a totally legit thing.   If your IA is cool with it, go for it.

 

[MikeOH]

I’ve been pretty careful with the Coleal letter despite knowing I’m competent. My reasoning is that even though my IAs are okay with my work, come time to sell I’m not so confident in what the seller’s A&P/IA may think!

[Ragsf15e]

1 hour ago, N204TA said:

 CFR 14, Part 43, Appendix A, (c) begins:  “Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations.”
 

It seems pretty clear to me that if the task isn’t on that list, it’s not preventive maintenance, period.

I agree it sounds like it should be an exhaustive list and should be clear.  I should have referenced the legal interpretation the others have mentioned that opens up the possibility of other tasks as that’s what I meant.  The regulations are rarely interpreted exactly as written, or maybe just interpreted differently by different people.

[DCarlton]

34 minutes ago, MikeOH said:

I’ve been pretty careful with the Coleal letter despite knowing I’m competent. My reasoning is that even though my IAs are okay with my work, come time to sell I’m not so confident in what the seller’s A&P/IA may think!

I talked to an M20 owner recently that said he didn't even have the skills to replace an interior plastic panel himself.  Frankly, I don't know how you can keep an old airplane flying or keep your plane in decent condition if you can't help yourself to some degree.  If you're competent and skilled, you know when to stop and discuss something with your A&P/IA.  If you know your airplane, I've found that just a little troubleshooting before going to the shop can be a huge time and cost saver.  Would I start wrenching on an engine though?  NO.  At the other extreme, I've talked to folks that do whatever it takes to keep their plane flying and they have no intention of selling; they'll die with it or scrap it to avoid the liability or blowback. 

[A64Pilot]

When you dig into dealing with FAA inspectors like I have in the past you’ll learn that these legal “interpretations” etc are not the law, that is to say they aren’t FAR’s.

If your apologetic instead or argumentative and if you get them into the teaching mode that plays to their ego and I’ve seen some get away with murder, while the one that argued about something insignificant has problems with future visits etc.

But then neither are AC’s and the FAA tends to try to treat Advisory Circulars as Regulation.

The honest truth is as much as we hate to hear this, but it depends, what it depends on is who you are talking too, as often as not during aircraft certification meetings I’ve had with the FAA, they were arguing amongst themselves far more than with me.

99% times out of 100, if you try to honestly comply with a reg that will carry you through, I have never seen one get wrapped around the axle about a honest mistake or a difference in opinion, they have too many Private Pilots that sell tickets or something to worry about somebody that adjusted the timing on a magneto or something because they thought they were allowed to.

Timing a Mag is not as complex as changing a tire etc.

[EricJ]

11 minutes ago, Ragsf15e said:

I agree it sounds like it should be an exhaustive list and should be clear.  I should have referenced the legal interpretation the others have mentioned that opens up the possibility of other tasks as that’s what I meant.  The regulations are rarely interpreted exactly as written, or maybe just interpreted differently by different people.

In the specific case of the Coleal letter, they needed clarification that their charter pilots could check the pressure in the high-pressure tires on the Learjets, because it was required in the preflight checklist in the manual that they were required to operate under.    If they were away from home and it required a mechanic, they were screwed.   So some of these opinion letters come out of a necessity for clarification, and it seems obvious in that case that the burdens created by a literal interpreation of the reg were unnecessary and counterproductive.

I'm glad the FAA makes this stuff available, though.    The opinion letters are all public and they've made them pretty easy to find and sort through.    At our most recent IA seminar some of the FAA reps went out of their way to show how they could be accessed and encouraged people to go through them. 

[EricJ]

12 minutes ago, DCarlton said:

I talked to an M20 owner recently that said he didn't even have the skills to replace an interior plastic panel himself.  Frankly, I don't know how you can keep an old airplane flying or keep your plane in decent condition if you can't help yourself to some degree.  If you're competent and skilled, you know when to stop and discuss something with your A&P/IA.  If you know your airplane, I've found that just a little troubleshooting before going to the shop can be a huge time and cost saver.  Would I start wrenching on an engine though?  NO.  At the other extreme, I've talked to folks that do whatever it takes to keep their plane flying and they have no intention of selling; they'll die with it or scrap it to avoid the liability or blowback. 

There's such a variety of people flying and owning airplanes, though, and many just have zero interest in turning a wrench or a screwdriver or touching anything with a little bit of lubricant on it.   I think many of them just know that they don't have those skills and so leave it to others, or just like making it somebody else's problem or something.   The same thing happens with cars and houses and appliances or whatever.    It used to surprise me how people would pay to have somebody else do what I thought was an easy or simple task, but now it just seems normal that some folks are just that way.   Most of my hangar neighbors are very capable maintainers and wrench-turners, but one in particular is just not at all interested in participating in any of that.   He totally trusts one of the local A&Ps to take care of anything that comes up with his airplane, and is more than happy to delegate it.

I agree with you that it seems like a weird thing, but it's totally normal for more people than I'd have expected. 

[N201MKTurbo]

Aside from all this legal stuff, if you want to change out a circuit breaker, remove the nuts from the whole row and push the whole row behind the panel. There is usually enough service loop on the jumpers to do it. In some cases you may need to remove the row jumper, which is usually easy. After getting the row out, it is easy to replace the individual breaker, then slide the whole row back in.

[tony]

sometimes, when the moon hasn't rising yet and its very quiet at the airport, a hanger fairy might visit......  

[N201MKTurbo]

A few years ago at the maintenance symposium, the FAA said that they don’t care what you do as long as you don’t screw up. If you screw up and you did it counter to the regs, all hell will break loose.

[DonMuncy]

But if you screw it up, you can always let your A&P fix it. You would have to be pretty dense to take wires off a circuit breaker and not be able to put them back onto an identical circuit breaker. 

[EricJ]

2 hours ago, N201MKTurbo said:

A few years ago at the maintenance symposium, the FAA said that they don’t care what you do as long as you don’t screw up. If you screw up and you did it counter to the regs, all hell will break loose.

"If it's not a problem, it's not a problem.   If it's a problem, it's a problem."   

 

[N201MKTurbo]

3 hours ago, DonMuncy said:

But if you screw it up, you can always let your A&P fix it. You would have to be pretty dense to take wires off a circuit breaker and not be able to put them back onto an identical circuit breaker. 

You have to screw up enough that it gets their attention, like landing at a major airport with your panel on fire.