Tailwheel Main spring Replacement Question

[Globalpilot]

Hello,

Quick question regarding tailwheel main spring replacement. My question is in trying to
Determine if replacing the tailwheel main spring in our 170 is preventive maintenance allowed by owner/pilot or needs to be accomplished by A&P/IA?

This item is not specifically spelled out in 14 CFR Part 43, but have read several threads that this might be done by an owner pilot?

Thanks for the impute in advance.

[mmcmillan2]

I’d like to hear about this as well.

[GAHorn]

Preventive Maintenance items are specifically identified in Appdx A to Part 43, para (c). If it’s not listed... it’s not preventive maintenance. The only authorized operation I see you can do without an A&P is paint the spring... But only if you do not remove it. I do not see removal or disassembly of landing gear springs listed..instead I see (in bold) when removal/dissassembly of landing gear items is NOT performed:

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 certificiate 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 § 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 § 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.

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[c170b53]

Have new hardware on hand for both ends of the spring.

[gfeher]

George, I beg to differ that a task must be listed in Part 43, Appendix A, para.(c) to be preventive maintenance. The FAA has issued a legal interpretation that, despite the explicit language of para. (c), the list is not "all inclusive." See the interpretation attached to this thread: viewtopic.php?f=43&t=15234

Otherwise, I agree with your view that changing a tail wheel spring is not preventive maintenance.

[GAHorn]

(The following comments are “discussion-only” intended to provoke thought and not intended to start a controversy.)

That is a good point Gene... and I personally agree.... but the “law is the law” and FAA has not changed he wording of that regulation. Further, the letter is not a “legal interpretation” in the sense of a judicial rendering... as the letter states, it is an “opinion” by legal council for FAA. We all know what opinions are until in court.

... I do agree in that the example given in the letter (that of checking tire pressure) is NOT a pre-flight action...but is a preventive maintenance action.... and it’s absence in the listings of Appdx A indicates that list is inclusive, not exclusive.

Here’s a fine-point I’ll add: Notice that FAA Counsel did not mention anything other than CHECKING tire pressure... They remained silent on CORRECTING tire pressure. (What if a 120 psi specification was found to be at 80 psi after the last guy flew it.... was that tire sidewall damaged by operations below specification? Or what if it was found to be at 220 psi instead (like the idiot at Browning Aerial Service did to my HS-125 using the nitrogen-bottle regulator instead of pausing to actually use a tire gauge. The blow-out plugs are Temperature-limited...not pressure limited.) Can a pilot reduce the pressure to 120 and go fly? What if the wheel or the tire was somehow damaged by that overpressure and on takeoff the tire bursts, shreds, enters the engine intakes, causes engine failure or fire? Now was that a preventive maintenance action taken by that pilot? Did the pilot have the expertise, tools, and testing apparatus necessary to return that tire to service after the overpressure event? That would be a point the legal teams would certainly bring up at trial.... I.E., Does CHECKING tire pressures (preventive in nature) authorize CHANGING tire pressures...?

I know what you, myself, and readers will think... OF COURSE it’s a silly matter ... in most cases... Hmmmn.

Here’s another example: We as owner/pilots can legally change a tire under the “preventive mx” guidance of Appdx A/Part 43. BUT it is widely held that we may NOT install brakes.... yet to change a tire on a 170 absolutely requires removal/installation of brake assemblies. So, it would be “common sense” to most of us that we can remove/replace brake assemblies. Does that mean we can replace brake LININGS? That requires riveting the new linings onto the backing-plates.
OK... how ‘bout if we have PRE-rivetted brake linings? Would THAT be OK?
This is just an example of how the matter can be viewed and it will rest upon an OPINION ... it’ll be in the “eye of the beholder”. (Or perhaps the answer will lie in the question, “what if anything went wrong?” You have to place yourself at the site of the accident and work yourself backwards to the cause or the contributing factors.

Anyway, I agree that it’s ridiculous to confine the concept of “preventive maintenance” to only the specific, listed actions in Appdx A.
{edited 2/25]

[Globalpilot]

[quote][/quote

Preventive Maintenance items are specifically identified in Appdx A to Part 43, para (c). If it’s not listed... it’s not preventive maintenance. The only authorized operation I see you can do without an A&P is paint the spring... But only if you do not remove it. I do not see removal or disassembly of landing gear springs listed..instead I see (in bold) when removal/dissassembly of landing gear items is NOT performed:


Thank you for clarification. This was my interpretation as well.

[gfeher]

No controversy intended here either George, just a discussion of the issue in the spirit of clarification.

Whether anyone agrees or disagrees with the result of any legal interpretation letter of the FAA, they are not mere opinions without legal weight. They are the legal interpretation by the FAA itself of it's own regulations, and may be relied upon as such. That's why they are sought and issued. I think that the listing of preventive maintenance tasks of Appendix A is pretty darn comprehensive, so I personally don't see a need to go beyond it. But like it or not, the FAA itself has stated that the list is not all inclusive for the reasons stated in the second paragraph on p. 2 of the letter. How much wiggle-room the FAA will allow is not clear, and I personally wouldn't exceed what is in Appendix A paragraph (c).

[cessna170bdriver]

John R, you are probably already aware of this, but you (or anyone) can perform the actual work under the supervision of an A&P and have him/her make the logbook entry. It’s a great way to learn your airplane.