Question on owner performed maintenance

[dkalwishky]

I've always changes my brake linings and ELT batteries with a simple log book entry. I've never had my mechanic tell me differently, in fact, he told me I could.

Dave

[GAHorn]

ICA's (Instructions for Continued Airworthiness) are merely mfr's instructions (albeit approved data.) Mfr's do not have the authority to authorize pilots to become maintenance technicians, so ICA's should not be viewed as superceding FAR's. ICA's are also not defined as Preventive Maintenace. They are required maintenance. IMHO

George, I would think that an approved ICA which specifically specifies the pilot can perform certian maintenance proceedures would be the approving authority to do so.

After all it is the "Instruction For Conitnued Airworthiness". And it is approved data.

What else would you be looking for.

I think I understand what you are saying, Bruce,...but item (30) of appdx A exactly addresses this problem. A mfr's ICA does not certificate a pilot to perform ICAs. The repairman must have the appropriate certification. Which ELT mfr has FAA-Approved ICA's which authorizes the PILOT to perform the battery change? Just because the battery change is called for in ICA does nothing to authorize un-certificated persons to perform that ICA.

[Bruce Fenstermacher]

Which ELT mfr has FAA-Approved ICA's which authorizes the PILOT to perform the battery change?

George I don't know ofany that do. Thought that someone else said there was but looking back on the thread I guess I was imagining it.

But I'd still think that IF there was an ICA approval that specifically said a pilot could to a task then that would be the approval for the pilot to do that task on that aircraft.

[Tom Downey]

Bruce F.

The Brand new ELT that I just bought fron Ameri-King AK-450 ELT, for the Fairchild has ICAs It is a nice little blue booklet and in Para 2.5.1 It states and I quote

"Batteries replacement may be preformed by the owner or operator provided that the accessability, removal and re-installation of the ELT can be considered"simple" as described in AC91-44A paragraph 8.A.""

end quote

the next 4 pages of the ICAs give a detailed instructions for replacing the battries, both in the remote control and the main unit.

The requirements for replacement times are direct quotes from 91.207 (c)

ICAs are FAA approved data, in they tell us who, how, and when items are to be done.


FAR 43 appendix A

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:

There is no wording there to restrict this Appendix to aircraft only.

(24) Replacing and servicing batteries.

There is no wording there to restrict us from replacing the batteries in ANY ELT. other than complex assembly of the structure. Which is not the case in most aircraft. Removing an access panel and reaching in and unsnapping a clamp is not complex assembly.

And Last but not least, you gain your authority to do Preventive maintenance from FAR 43.3(g)

If you have any questions on this or any other subject, call your FSDO they all have web pages giving their phone numbers for the general aviation airworthiness inspectors. They have the correct answers, Not the so called experts on this and many other web pages.

Yes that includes me too GA.

[FredM]

The Ameri-King manual also references you to appendix b which is an exerpt from FAA AC-44A para 8.a " The replacement can be done by the pilot if the Preventive Maintenance limitations of Part 43.3 (h) of the FAR are complied with. For example, a portable type elt that is readily accessible and can be removed and reinstalled in the aircraft by a simple operation should be considered Preventive Maintenance. Fixed type elt installations are often permanently mounted in a remote area of the aircraft near flight control cables, vital aircraft components and critical attachments to the aircraft structures. Installations of this nature require an external antenna and often a remote ON/OFF transmitter control switch that is usually located near the pilot's flight position. this type installation is complex and battery replacement should be accomplished by a certified mechanic or certificated repair station"

[GAHorn]

I've always changes my brake linings and ELT batteries with a simple log book entry. I've never had my mechanic tell me differently, in fact, he told me I could.

Dave

Sorry Dave, but your mechanic cannot supercede FAR's. (or FAA rulings.)
Like I said before,....I too have been caught off-guard by this info. ..., if the ELT is located outside the cockpit, attached to structure, and has anything other than snap-out/snap-in batteries.....it requries an avionics shop or A&P (or supervision) to change them. If your mechanic tole you that you could do it....then he should supervise and sign it off.

Tom, I believe your comment referring our friends to contact their FSDO for a ruling on this is the best advice. My FSDO holds the ruling I posted above: Pilots may not change them without A&P supervision, and ELT battery changes are NOT preventive maintenance.

[Tom Downey]

""Tom, I believe your comment referring our friends to contact their FSDO for a ruling on this is the best advice.""

Thanks, we all should be able to contact FSDO for our answers.

My FSDO holds the ruling I posted above: Pilots may not change them without A&P supervision, and ELT battery changes are NOT preventive maintenance.

I would question them again, and-- I will get a reading on this from Bill O'Brien. WE need all FSDO's telling us the same things.

[Tom Downey]

Tom,

Bill forwarded your inquiry to me. The answer is best explained in AC
91.44A, dated 12/12/80

8. BATTERIES.
a. Battery Replacement. "...The replacement can be done by the pilot if the
preventive maintenance limitations of Part 43.3(h) of the FAR, are complied
with. For example, a portable type ELT that is readily accessible and can
be removed and reinstalled in the aircraft by a simple operation should be
considered preventive maintenance. Fixed type ELT installations are often
permanently mounted in a remote area of the aircraft near flight control
cables, vital aircraft components and critical attachments to the aircraft
structure. Installations of this nature require an external antenna and
often a remote on/off transmitter control switch that is usually located
near the pilot's flight position. This type installation is complex and
battery replacement should be accomplished by a certificated mechanic or
certificated repair station…”


Charles Fellows
Federal Aviation Administration
Airmen and Avionics Branch, AFS-350
Phone (202) 267-3922
Fax (202) 267-5115

[S2D]

Tom,

Bill forwarded your inquiry to me. The answer is best explained in AC
91.44A, dated 12/12/80

8. BATTERIES.
a. Battery Replacement. "...The replacement can be done by the pilot if the
preventive maintenance limitations of Part 43.3(h) of the FAR, are complied
with. For example, a portable type ELT that is readily accessible and can
be removed and reinstalled in the aircraft by a simple operation should be
considered preventive maintenance. Fixed type ELT installations are often
permanently mounted in a remote area of the aircraft near flight control
cables, vital aircraft components and critical attachments to the aircraft
structure. Installations of this nature require an external antenna and
often a remote on/off transmitter control switch that is usually located
near the pilot's flight position. This type installation is complex and
battery replacement should be accomplished by a certificated mechanic or
certificated repair station…”


Charles Fellows
Federal Aviation Administration
Airmen and Avionics Branch, AFS-350
Phone (202) 267-3922
Fax (202) 267-5115

My take is a pilot could put the battery in, but an A&P has to test it every 12 months. Is my thinking flawed? Wasn't that AC written before the implementation of 91.207 (d)

[Tom Downey]

You got it right..