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Owner-assisted annual inspections: Are they allowed?

With limited exceptions, only a certified mechanic holding an inspection authorization (IA) can perform an annual inspection in accordance with 14 CFR 91.409(a)(1). Thus, unless the owner-pilot also holds an IA, he or she is not permitted to assist with the inspection function of an annual.

Many pilots (myself included) regularly and actively participate in the maintenance of our aircraft. We all should be familiar with what we can and cannot do. Appendix A to Part 43 lists preventive maintenance actions that can be performed by the holder of at least a private pilot certificate on an aircraft owned or operated by that pilot. But what about helping out with the annual? This is where it gets a little tricky and the meaning of words matters. A qualified pilot is permitted to perform preventive maintenance concurrent with the annual inspection, such as changing oil and cleaning spark plugs, but may not help with the performance of the inspection itself. What about removing cover plates, cowlings, and fairings? Interestingly, in Part 43 Appendix D subpart (a) it says, “Each person performing an annual or 100-hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling. He shall thoroughly clean the aircraft and aircraft engine.” Does that mean only the IA can do this work when it’s associated with an annual? No, I don’t think so. A 2015 FAA legal interpretation clarifies that “… inspection plate removals and aircraft cleaning are preliminary and incidental to the actual inspection of the required items. As such, they may be performed by individuals under the supervision of the holder of the IA.” This same interpretation authoritatively states that “…any assistance provided by a non-IA holder must not include an inspection and airworthiness determination of the item at issue.” Thus, the owner may perform the preliminary and incidental tasks to an annual inspection without running afoul of the regulations.

And so, again, stated plainly, owner-pilots cannot actively participate in an annual inspection of their aircraft. You may think that I’m quibbling over the distinction between maintaining and inspecting, but it’s vitally important. Our law firm is presently involved in a case in which the FAA latched onto comments by a pilot who told the FAA that his A&P mechanic, a non-IA, did his annual inspection. The mechanic did certain maintenance, but an IA did the inspection part. Nevertheless, the pilot’s misstatement produced a torrent of FAA scrutiny resulting in two re-examinations and a proposed certificate suspension.

I am not advocating for a change to the aviation lexicon. “Owner-assist annual” is a time-honored expression. Rather, I think it’s useful to deconstruct it for the sake of clarification. And, by the way, “Owner-assist maintenance during and/or preliminary and incidental to the annual” just doesn’t flow very well.

Mike Yodice

Mr. Yodice has been a pilot since 1979. He took instruction at the historic College Park (MD) airport and co-owns a Piper Cherokee and flies the family Piper J3-Cub.
Topics: Maintenance, Ownership, Pilot Protection Services

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