Wrenching Decision – Pilot Prep for Preventive Maintenance

At home, I’m a fairly fearless handyman.  I will start projects and/or try to fix things with little restraint.  At the hangar, I am much more cautious and deliberate.
I have two sets of tools; one set for home and the other for the airplane hangar.  At home, I’m a fairly fearless handyman.  I will start projects and/or try to fix things with little restraint.  At the hangar, I am much more cautious and deliberate.  I am not an A&P mechanic and I am careful to only undertake tasks that I am permitted and qualified to perform.  

Aircraft owners and pilots interested in hands-on maintenance should become very familiar with 14 CFR Part 43.   The relevant sections of this part provide, among other things, the legal framework on who can do what and how in terms of pilot performed maintenance.  

The who is described in section 43.3 and includes a reference to pilot certificate holders being permitted to perform preventive maintenance on aircraft owned or operated by “that” pilot.  Of course, there are restrictions.  The holder of a sport pilot certificate, for instance, may only perform preventive maintenance on light sport aircraft.  And, pilots may not perform preventive maintenance on aircraft used in air carrier operations, including airline and charter operations (there are limited exceptions for the latter).  

The what is contained in Appendix A, subsection (c). There it lists 31 maintenance tasks that pilots are permitted to perform.  It’s a fairly comprehensive list, but arguably, there may be some other operations not listed that fall within the definition of preventive maintenance.  If there’s any doubt about the complexity or suitability of an operation or task, consult a certificated mechanic.  

The how aspect of the regulation is extremely important to understand.   Section 43.13 prescribes the performance rules and says, in summary, that persons (read mechanics and pilots alike) shall use methods, techniques and practices prescribed in the current manufacturer’s maintenance manual or Instructions for Continued Airworthiness and shall use tools and equipment and complete the work in accordance with accepted industry practices.  It also allows persons to use other methods and such that are acceptable to the Administrator (FAA).  The take-away for pilots: you will be held to the same standard as a certificated mechanic when performing preventive maintenance.  The FAA will expect that you have suitable guidance material and tools.  If a task calls for a particular torque value, you better have a torque wrench available and make sure it’s properly calibrated.  The other thing you better have is know-how.  Implicit, if not explicit in the regulation is the expectation that you are competent to perform the task.  In my experience the mechanical competency of pilots varies greatly.  Seek expert assistance until you are competent.  And finally, don’t forget the paperwork.  Section 43.9 requires an entry in the maintenance record containing a description of the work performed, the date of completion, plus the name, signature, certificate number and type of certificate held by the person approving the work.  Section 43.9(a)(4) states that if the work is performed satisfactorily, then the signature constitutes the approval for return to service only for the work performed.

The best tool I own is in the box between my ears.  I use it to decipher the regulations and to judge the limits of my mechanical abilities.  And, over the years, I’ve used it to make friends with an assortment of mechanics who have been exceedingly generous in supervising my work and/or answering my maintenance-related questions.  
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.

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