Can a pilot complete and log an AD?

[bcg]

I had AD 73-21-01 done today, or did it under supervision.  It's just lubricating flight controls and gear, which is something a Private Pilot is allowed to do under Part 43 so, I got to wondering...  If an AD consists solely of work that Part 43 allows a pilot to complete, can the pilot perform the work and log the AD as complied with? 

We discussed it in the shop and came to our own conclusion but, I'm curious to see if MS comes to the same conclusion and how we get there.

[N201MKTurbo]

1 minute ago, bcg said:

I had AD 73-21-01 done today, or did it under supervision.  It's just lubricating flight controls and gear, which is something a Private Pilot is allowed to do under Part 43 so, I got to wondering...  If an AD consists solely of work that Part 43 allows a pilot to complete, can the pilot perform the work and log the AD as complied with? 

We discussed it in the shop and came to our own conclusion but, I'm curious to see if MS comes to the same conclusion and how we get there.

I believe you can. As a mater of fact, if you do the maintenance you must log it with your pilots license number. Adding a note that it satisfies the AD is fine.

[EricJ]

The ignition switch AD is generally done by pilots/operators just before shutdown or during some convenient time, so that's another example of a pilot/operator complying with an AD.    As mentioned, if you do it, you should log it consistent with the requirements for logging AD compliance (which is a bit more stringent than normal maintenance entries).

If the actions required for compliance can be done by an owner/operator I don't know why an A&P would be required.   As long as everything is done and recorded properly I don't know what would stop you from doing it.

 

[Hank]

Memory says that I did the one-time AD checking for correct tail hinge assembly, I just had to remove the inspection cover on one side and shine my flashlight inside.

But I don't remember if I signed it off in the logbook, or if my A&P / IA did the writing and signing.

[N204TA]

I believe that the FAA answer is that a pilot/owner can sign off an AD only if it says so in the AD.  

While lubing flight controls can be done under preventative maintenance, AD 73-21-01 does not say anything about a pilot being able to certify the compliance so, he/she could do the work under supervision but an “appropriately rated” mechanic must sign it off.

The Bendix ignition switch AD, 76-07-12, however, does say, “3. The checks required by this AD may be performed by the pilot.”

 

from the FAASTeam:

Edited August 22 by N204TA

[A64Pilot]

There are many AD’s that even an IA can’t sign off, the specific one that comes to mind is Eddy current inspection of a Main Spar cap, unless of course the IA has the credentials 

But again the body of the AD states who can perform the AD.

[N201MKTurbo]

With regard to the lube AD. Someone on here who is retired and bored should petition the FAA to add the pilot as an approved person.

[A64Pilot]

16 hours ago, N201MKTurbo said:

With regard to the lube AD. Someone on here who is retired and bored should petition the FAA to add the pilot as an approved person.

A way to do that maybe by AMOC or Alternate Method of Compliance. They are often not all that hard to get through.

This kind of thing is where Type Clubs come into their own, believe it or not but the FAA listens to Type Clubs, they carry a lot of weight.

Maybe Mooney’s need a Type Club like the C-120/140 Assn or the Bonanza Society etc.

If we ever get a bad AD we may wish we had one. 

[Shadrach]

On 8/21/2024 at 6:06 PM, EricJ said:

The ignition switch AD is generally done by pilots/operators just before shutdown or during some convenient time, so that's another example of a pilot/operator complying with an AD.    As mentioned, if you do it, you should log it consistent with the requirements for logging AD compliance (which is a bit more stringent than normal maintenance entries).

If the actions required for compliance can be done by an owner/operator I don't know why an A&P would be required.   As long as everything is done and recorded properly I don't know what would stop you from doing it.

I could be wrong, but I think the AD must specifically state that the pilot may comply with the AD as AD 76-07-12 states under Compliance required as indicated:  3. The checks required by this AD may be performed by the pilot. 

Consider the recent elevator counterweight AD.  Determination of hybrid vs solid weight is simple enough for even the densest of pilots.  I knew I had solid weights from the start and verified so before calling my IA but I don't think a writeup with my signature would've been adequate even though checking applicability and airworthiness was completely non-invasive.  It was no great hardship, but the delta in cost would have been 5 minutes of my time and a line of ink from my pen vs My IA's minimum to do a hangar call and sticky (~$180).  One becomes so conditioned to expenses that driving to the airport a second time and paying someone $180 to run a magnet over a piece of lead and then sign a statement stating as much seems like a great deal. 

[A64Pilot]

I think often the possible consequences of the reason the AD was issued plays into who can perform it, plus I think frankly the FAA just defaults to Certified mechanic unless someone objects. 

Thats where type clubs can come in, during the comment section of issuing an AD they will often have a say, and very often affect the AD, it’s not uncommon actually for the type club to have more knowledge of the problem than the FAA and I think the FAA recognizes this.