Preventative Maintenance by the Owner or Operator

We have all seen, or at least heard about, this list of things a pilot can ‘fix’ on their airplane. But is it as simple as finding the list, and then we have carte blanche to go forward and do great things? Well, not exactly.

The FAA has built into the Code of Federal Regulations, 14 CFR Part 43 appendix A to be specific, a list of maintenance activities they have labeled “Preventive Maintenance” which afford certain pilots who do not hold a mechanic certificate the privilege of performing that limited maintenance. Before telling your mechanic “I got this” and kicking him to the curb it is important to understand the terms and legal constraints that come with that privilege. There are some qualifications that must be met and some additional requirements that must be discussed, lest we draw the ire of an FAA inspector, or worse compromise safety of our aircraft. To this end let’s touch on some of the finer points of this concept of preventive maintenance as it relates to us as private pilots or higher (you sport pilots have a few different nuances to your aircraft and your privileges so please ensure you review the terms of Part 43 that apply specifically to you).

To start this discussion, we ask who can perform preventive maintenance? Seemingly simple, but not always clear cut to some. The FAA allows the owner or operator of the airplane, not being used for part 121, 129 or 135 operations to perform these limited maintenance tasks. But they must hold at least a private pilot certificate, issued under part 61. So, airplane owners that are not FAA certificated pilots possessing at least a private pilot certificate cannot perform preventive maintenance on their own airplane. Sorry, student pilots…you have to get past that check ride first. Likewise, a private pilot who owns or is flying a 172 cannot perform preventive maintenance on every 172; this privilege is limited to the specific airplane you own or operate. The key is you must be the owner and/or operator of the specific airplane you want to maintain, and have at least the private pilot certificate (again, those light sport folks are a little different).

So, you fit the bill and qualify to bend those wrenches. Cleared for take-off, right? Not so fast. All persons performing maintenance, preventive or otherwise, must meet the same standards, so a pilot removing and replacing a tire is held to the same standard as a certificated mechanic. But what does this entail? Two major things are at the forefront of this part. First, a maintenance entry returning the aircraft to service must be made which complies with the regulations. Second, the task has been accomplished according to “methods, techniques, and practices prescribed in the current manufacturer’s maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator.” In layman’s terms the FAA is telling you that to replace that tire you must have the current maintenance manual or acceptable procedure, just like the mechanic. Further, you must have the appropriate tools and requisite knowledge to perform the task according to the procedure. If you have never changed a tire in your life, you likely do not have the requisite experience to tackle it on your plane for the first time. It never hurts to have the mentorship of your mechanic the first few times you perform a specific task; it will build your confidence and you might even learn something!

Should you perform your own preventive maintenance? Sure! It is a great way to learn your airplane better than you did before, and you may come to appreciate a good mechanic even more. But ensure, just like the mechanic, that you have the proper tools, the proper parts, the proper manuals, understand the procedure and most importantly are able to make the proper logbook entry to document the return to service. As a mechanic, and now an attorney speaking to clients, I always encourage owners with the interest to get involved in the maintenance of their aircraft. Maybe you do so under the strict supervision and tutelage of your mechanic. Perhaps you have more experience to tackle it on your own with more confidence. However you approach preventive maintenance, take the time to acquaint yourself with Part 43 and keep yourself and your aircraft compliant and safe.

Eric Kallio is an aviation attorney with over 24 years of aviation experience reaching back to his time as a helicopter pilot in the Army. He holds an Airline Transport Pilot certificate for helicopters, commercial and instrument ratings for single and multi-engine airplanes and flight instructor, instrument instructor and multi-engine instructor certificates. He also holds an Airframe & Powerplant mechanics certificate with and Inspection Authorization. He has managed to accumulate nearly 6,000 hours of flight time in almost 40 different aircraft from a 152 to a Citation to a Blackhawk helicopter.

In his Aviation practice Eric handles aircraft transactions, leases and the establishment of business entities and operating agreements as well as defending against FAA Airman and Medical certificate actions.

Related Articles