It does, but as noted in the LOI any tasks are to be viewed as examples of each 32 categories which doesn’t mean you can expand the number of categories. This is how the prevent mx guidance and other noted guidance has been practiced for years.
Yes, I know that's how the FAA has interpreted the interpretation, but it isn't what the LOI actually says. The LOI says
Even though the introductory text of subparagraph ( c) states that "[p ]reventive maintenance is limited to
the following work... ." (emphasis added), in view of the broader definition of preventive maintenance in
section l. l , we believe that such limitation is not controlling.
It does not say that PM must fit into one of the categories; rather, it says that the limitation of Appendix A does not control whether or not a task is PM. If a task fits the PM defintion it's PM, regardless of Appendix A.
Granted, if you can argue that a task can be described as similar to something that's on the list, you'll have a much easier time convincing someone that it's PM. Most times that's practical. For example, @xenadu mentioned replacing a landing light switch. I could argue that task fits this category:
(16) Trouble shooting and repairing broken circuits in landing light wiring circuits.
since the switch is part of the circuit. So long as no complex disassembly and reassembly were necessary to access the switch, I think replacing it would be considered PM.But there are other tasks that can't really be made to fit one of the App A categories but are equally simple and fit the definition well. For example, the overhead PA speaker in my Musketeer can be accessed by removing a handful of screws and the electrical connection is made with two slip-on connections. The speaker is certainly a "small standard part" and replacing it would not require anything close to a "complex assembly operation," but I don't see any category in the App A list that would cover it. Nonetheless, I'd feel comfortable replacing it if it ever failed and I'm confident the A&P-IAs that I use would agree that it fits the PM definition. I would log it as such and I'd be very surprised if that were ever challenged.
The Office of the Chief Counsel has generously allowed us lots of room here.