Repairs vs Maintenance

[Paul-WI]

Ok - I hope NOT to open a can of worms here but I have what I think is a legit question. As I read these posts, I sense that a lot of owners are doing their own repairs. The discussion on the rear leaf spring is a case in point. Can we legally according to FAR replace our own spring and log it or do we need to have it signed off by an A&P mechanic to make it legal? The reason I ask this is that as an auto mechanic for the past 30 years, I believe I have some idea what I can safely handle and do on my own and what I would feel more comfortable having someone with more expertise tackle. I just would not want a situation where I did some repairs, had an incident and then insurance says "sorry, you are not covered because you did not follow FAR on repairs". Or do we just do the minor repairs and not log them which from what I understand is another violation of the FAR.
As a side note, I have already done some minor repairs and not worried about it but am wondering what the correct paperwork procedure should be.

Thanks ahead of time for any responses - Fly safe

Paul
N3458D

[GAHorn]

An owner-pilot may perform "preventive maintenance" which is described in FAR Part 43, Appdx A. Landing gear component replacement is not listed. (In fact, landing gear replacement is actually considered a major repair, if I recall correctly.)
I believe the answer to your question is: You must be supervised by an A&P while performing this repair, and the repair must be logged and signed by him. Lots of folks, including many A&P's, seem to believe that it's OK if you do the work and then if the result is inspected by the A&P ...that such actions constitute supervision. But that does not meet the rule.

(And you are also correct in that NOT logging repairs is illegal. Many FAA Inspectors consider the failure to record repairs as a more serious transgression than repairs performed/recorded by an unqualified repairman.)

[Paul-WI]

Thanks for the reply - kinda what I was thinking. Amazing what common sense would dictate preventive maintenance and what the FAR says is repairs. Oh well - time to buddy up with my A&P and keep the paper work legal. 3458D will be due for it's first annual this fall since I purchased it so it will be interesting to see what we find. I am trying to get all my paperwork corrected as previous owners did some minor repairs without logging anything.

Thanks again!

Paul
N3458D

[jrenwick]

The list in FAR 43 Appendix A contains what seem to many to be inconsistencies, but then we all know government regulations aren't required to make sense.

When I read Appendix A, I have a strong feeling that it was arrived at through some kind of a compromise in a political process -- like maybe when the rule was made, there was a struggle between some mechanics who didn't want any owner maintenance at all going on, and others who thought there should be some reasonable exceptions for preventive maintenance and the realities of ownership.

Does anybody know or remember how this particular list of tasks came to be? Just curious....

John

[n2582d]

If you want it straight from the horse's (some have suggested another equine) mouth, you can listen to Bill O'Brien for a price on http://www.amtonline . (It's a site where IA's can go to maintain currency instead of attending a maintenance seminar). Bill is the FAA National Resource Specialist, He can be reached at (202) 267-3796, Fax:(202) 267-5115, e-mail: william.o'brien@faa.gov . Anyway, he makes the point that FAR 43.9 requires that the name of the person performing the work be entered in the logbook.

a) Maintenance record entries. ... , each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:

(1) A description (or reference to data acceptable to the Administrator) of work performed.

(2) The date of completion of the work performed.

(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.

(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

Another thing he stresses is that, according to FAR 43.13B, the work performed should be at least equal to but not bettter than original. If it was better than original this would be considered an alteration. Is rounding off the sharp end of a tail spring an alteration? In my book it would be considered a minor alteration. What about installing tires with a higher number of plys than original? Using polyurathane paint rather than acrylic? The list is endless.

[Lee]

I just went through two days of work on my bird. BAS tail pull installed, new spark plugs, installed F&M spin on oil filter, wheel fairings removed and new pucks installed, brake system bled, new seals, repacked wheel bearings, tail wheel springs and leaf springs ... from what my A&P said, the work, STC or not, had to be done under the direct supervision of an A&P and STC work signed off by an IA. Some of this seems dumb but, rules are rules! Regards, Lee ('54B, N1967C)

[Bruce Fenstermacher]

...installed, new spark plugs, installed F&M spin on oil filter, wheel fairings removed and new pucks installed, brake system bled, new seals, repacked wheel bearings, tail wheel springs and leaf springs ...

Lee

Your A&P isn't the authority 43.13 appendix A is. From the short basic list you gave he is correct for the most part but you could have repacked your wheel bearings and replaced your spark plugs without his or any other A&Ps assistance.

I'm fond of telling people who ask that you can do any darn thing to your plane that you want, it's not illegal. It is illegal however, for the most part, for you, as just a licenced pilot, to return the aircraft to service after you work on it.