Preventive Maintenance Training

idahoflier

idahoflier

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idahoflier
Is training required for an aircraft owner with a PPL to legally perform any of the preventive maintenance items described in Appendix A to Part 43—Major Alterations, Major Repairs, and Preventive Maintenance (C)?
 
You have to get a private pilot certificate. A sport pilot certificate is not adequate unless the aircraft has a special airworthiness certificate in the light-sport category.
 
idahoflier said:
Is training required for an aircraft owner with a PPL to legally perform any of the preventive maintenance items described in Appendix A to Part 43—Major Alterations, Major Repairs, and Preventive Maintenance (C)?
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Technically, no on training. But not advisable if you have never performed a preventive mx task before. However, there are certain limits, rules, and processes you must know and understand, before you attempt any preventive mx task.
 
Bell206 said:
Technically, no on training. But not advisable if you have never performed a preventive mx task before. However, there are certain limits, rules, and processes you must know and understand, before you attempt any preventive mx task.
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That is my thought as well. That said, I attended a local EAA chapter meeting a year or two ago and the local FSDO FAAST Program Manger gave a presentation on Owner Performed Preventative Maintenance. In that presentation he said before an owner could perform any task listed in Appendix A to Part 43—Major Alterations, Major Repairs, and Preventive Maintenance (C), they must have received training for that task.

After the presentation I asked for clarification as I had not heard of that requirement and didn't see that requirement in Part 43 or any of the previous FAA AC's or publications I had read. He referred me to 65.81 General privileges and limitations (a). I gently pushed back as 65.81 was dealing with "certificated mechanic" and as such I didn't believe that was applicable. He still disagreed...
 
There’s no regulation requiring specific training, but as @Bell206 mentions, there are many regs related to how maintenance must be performed and logged, regs about permissible parts and materials, advisory circulars concerning approved methods, etc. Whether you’re an A&P or a PPL, you’re on the hook to comply with the FAA’s maintenance rules.

It’s not as simple as walking into AutoZone and grabbing a set of brake pads to slap on your F150. There’s a lot you need to learn and some documentation you must have available (like your plane’s maintenance manual). You can find many articles, books, videos, etc., and you should expect to put in some time studying.

Owner Assisted Aircraft Maintenance by Dan MacDonald is a good book to start with. You may also want to get the Light Plane Maintenance Library. It’s out of print but you can find used copies. The EAA has a DVD on preventive maintenance that’s helpful though a bit Cessna specific.

Do some homework before you pick up a wrench.
 
idahoflier said:
He referred me to 65.81 General privileges and limitations (a). I gently pushed back as 65.81 was dealing with "certificated mechanic" and as such I didn't believe that was applicable. He still disagreed...
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I’ve heard of that before. Its purely his opinion, but I believe it was meant in a positive way.

Regardless, in general, aircraft maintenance tasks are “classified” into different groups.

There are tasks that do not “raise up to the level” or are not defined as preventive mx or maintenance which include cleaning, refueling, giving opinions and so on. Those items require no training/experience or record entry.

Next are preventive mx tasks which are defined by Part 1 and Part 43, require a minimum of a PPC and a record entry, but no prior experience or training. Part 65 does not apply.

Maintenance tasks on the other hand are defined as: inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance. Alterations and rebuilding are also separately included at this level. Part 65 prior experience or proven ability is in play as well as a number of other FARs, requires an A and/or P or repairman certificates, and all maintenance requires a record entry.

Fortunately, there is plenty of guidance on several levels that can assist in navigating this topic. But I wouldn't be "gentle" next time and insist on a reference or his "professional" opinion on why Part 65 is applicable to a PPC performing preventive mx per Part 43.
 
Bell206 said:
But I wouldn't be "gentle" next time and insist on a reference or his "professional" opinion on why Part 65 is applicable to a PPC performing preventive mx per Part 43.
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By "gently" I meant I tried not to be confrontational. I did point out that 65.81 was for mechanics and it even said so. I also asked him if his position was correct, what was the mechanism to prove and/or document I had received training on a particular task? He didn't have an answer for that, but he wouldn't budge. I didn't feel it was worth further discussion and I didn't want to become memorable so I thanked him and moved on.
 
idahoflier said:
By "gently" I meant I tried not to be confrontational. I did point out that 65.81 was for mechanics and it even said so. I also asked him if his position was correct, what was the mechanism to prove and/or document I had received training on a particular task? He didn't have an answer for that, but he wouldn't budge. I didn't feel it was worth further discussion and I didn't want to become memorable so I thanked him and moved on.
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Interesting.
 
idahoflier said:
I didn't feel it was worth further discussion and I didn't want to become memorable so I thanked him and moved on.
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One of the ways I developed my knowledge of the FARs and other FAA inner workings was taking those type discussions to their end. There are several ways to remain "diplomatic" through the discussion and you may end up being "memorable" for the right reasons.
 
Salty said:
Nah. If you can’t figure out on your own if you need training to do the things allowed, you’re probably not the right type of person to be doing it.
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I’ve met hundreds of people who don’t know what they don’t know…. -Skip
 
I remember preventative maintenance coming up during the oral exam of my ppl. I made the comment I was surprised how much they let you do, like repacking wheel bearings seems like it would be a little too technical for a lot of people. DPE ... "I agree..."

Id have asked the fsdo faast manager who/where the training would come from. The AC said as a ppl I can clean and repack wheel bearings. I was trained to repack bearings on the race cars. Would that meet his training criteria?
 
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Half Fast said:
The problem comes when you say “I know how” but you really don’t.
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Problem is lots of people don't have the ability to self assess their abilities and think they can "figure it out" from disassembling someone else's work....which may or may not have been done correctly to begin with.
 
idahoflier said:
Is training required for an aircraft owner with a PPL to legally perform any of the preventive maintenance items described in Appendix A to Part 43—Major Alterations, Major Repairs, and Preventive Maintenance (C)?
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The answer is that no one (including A&Ps and IAs) can work on anything Aviation without the approved documents that detail the task they're doing. If you do not understand the instructions then don't perform the task. Changing oil without the approved maintenance manuals and/or Instructions for Continued Airworthiness (ICA) is not permitted by anyone.


43.13 Performance rules (general).​


(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the 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, except as noted in § 43.16. He shall use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. If special equipment or test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus or its equivalent acceptable to the Administrator.

(b) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).
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Klaus M said:
The answer is that no one (including A&Ps and IAs) can work on anything Aviation without the approved documents that detail the task they're doing.
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As an aside, I’ll mention that I keep my plane’s maintenance docs on a USB stick in the plane. If I have a problem away from home, I don’t want an A&P to be legally prevented from working on my plane because he doesn’t have the required documentation.
 
Klaus M said:
The answer is that no one (including A&Ps and IAs) can work on anything Aviation without the approved documents that detail the task they're doing. If you do not understand the instructions then don't perform the task. Changing oil without the approved maintenance manuals and/or Instructions for Continued Airworthiness (ICA) is not permitted by anyone.
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Respectfully, that's not an answer to the question I asked. Lots of good ancillary discussion by you and others though...
 
idahoflier said:
Respectfully, that's not an answer to the question I asked. Lots of good ancillary discussion by you and others though...
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Sorry, Let me say it another way...

The 'Training' for doing a task is acquired by the manufacture's publication. So, YES, you are being trained by studying the appropriate publications.

If you are looking for a school or college course? I don't know of any.

The FAA expects an A&P mechanic to train themselves through the publications. Quite often the mechanic has never done a certain task before. Studying the maintenance documents satisfies the FAA regulation's experience requirement.

If an Airworthiness Directive (A.D.) comes out today nobody has experience on that A.D.. So, the FAA expects the mechanic to read and study all the publications referenced and follow through with the A.D. request.

Owner/Operator can do the same thing. Studying publications is an acceptable means of 'Preventative Maintenance Training'.
 
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