Owner allowed preventative maintenance.

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pnancoz

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In Part 43, appendix A, subpart C, owners are allowed to replace any hose connection except hydraulic connections. Does this include replacing SCAT tubes and the duct between the air cleaner and carburetor?
 
Well they're not hydraulic are they? The reason hydraulic is excluded is because the system needs to have any air that might have gotten in bled out so replacing those types of hoses is more involved. You're fine with the scat tubes.
 
pnancoz said:
Does this include replacing SCAT tubes and the duct between the air cleaner and carburetor?
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Yes provided you dont need to disassemble anything of importance like remove the carb to replace the hose. The listing in 43 App A(c) are considered "catagories" similar to the major alteration, etc listings in the same appendix. So long as you can fit the task into one of those categories and it falls within the definition of preventative maintenance you are okay. But keep in mind you are held to the same criteria as an A&P when performing preventative maintence so be sure to use the proper replacement parts and make an entry for the work per 43.9.

FYI: as mentioned above there are different types of orange hose used within an engine compartment. The most common are SCAT and SCEET with the main difference SCEET has an additional internal lining. However, in some cases an OEM will use a specialized version of SCEET which further resists the internal lining from debonding.
 
pnancoz said:
In Part 43, appendix A, subpart C, owners are allowed to replace any hose connection except hydraulic connections. Does this include replacing SCAT tubes and the duct between the air cleaner and carburetor?
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If you are replacing the SCAT hoses from air cleaner to carburetor on a Piper, see the Service Bulletin which requires using the Piper part. The Service Bulletin came out because some of the non-Piper hoses collapsed during takeoff causing some accidents.
 
kshaw said:
If you are replacing the SCAT hoses from air cleaner to carburetor on a Piper, see the Service Bulletin which requires using the Piper part. The Service Bulletin came out because some of the non-Piper hoses collapsed during takeoff causing some accidents.
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A service bulletin is not regulatory, but highly, highly recommended in most case.
 
kshaw said:
If you are replacing the SCAT hoses from air cleaner to carburetor on a Piper, see the Service Bulletin which requires using the Piper part. The Service Bulletin came out because some of the non-Piper hoses collapsed during takeoff causing some accidents.
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It's a Cessna and I have the correct part from Cessna.
 
pnancoz said:
In Part 43, appendix A, subpart C, owners are allowed to replace any hose connection except hydraulic connections. Does this include replacing SCAT tubes and the duct between the air cleaner and carburetor?
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I think part 43 says "hose connection." Nothing about replacing the hose itself or ducting.
 
martym said:
I think part 43 says "hose connection." Nothing about replacing the hose itself or ducting.
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If your interpretation is correct, I believe the Colleal LOI would cover it anyway. IOW, if you’re allowed to replace hose connections, replacing the hose between those connections does not increase the complexity.

Appendix A is to be considered a set of examples, not an all-inclusive list.
 
Having a working relationship with an A&P/IA, especially the one who does your annuals, is a great insurance policy for owner maintenance. First, whenever you are unsure of what you can do and how to do it, you can have a quick chat with your A&P to clarify. Second, if you do wind up getting into something you shouldn't, the A&P can supervise you or do a conformance inspection and log the work.
 
Half Fast said:
Appendix A is to be considered a set of examples, not an all-inclusive list.
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The first sentence in para (c) says: Preventive maintenance is limited to the following work.
Permitted work tasks are subsequently listed. If other tasks were allowed it would say not limited to the following
 
martym said:
The first sentence in para (c) says: Preventive maintenance is limited to the following work.
Permitted work tasks are subsequently listed. If other tasks were allowed it would say not limited to the following
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Yes, it does say that. But FAA legal subsequently published a more liberal interpretation. See https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Coleal-Bombardier Learjet_2009_Legal_Interpretation.pdf .


“As with the other paragraphs of Appendix A (i.e., on major repairs and major alterations), the lists are better viewed as examples of the tasks in each category-they cannot be considered all- inclusive. There are, no doubt, many "simple or minor preservation operations [tasks]" and many "replacement of small standard parts not involving complex assembly operations" performed daily, especially on small general aviation aircraft, that the agency would consider to be preventive maintenance, though they are not included in the 32 listed items.“
 
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Half Fast said:
Yes, it does say that. But FAA legal subsequently published a more liberal interpretation. See https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Coleal-Bombardier Learjet_2009_Legal_Interpretation.pdf .


“As with the other paragraphs of Appendix A (i.e., on major repairs and major alterations), the lists are better viewed as examples of the tasks in each category-they cannot be considered all- inclusive. There are, no doubt, many "simple or minor preservation operations [tasks]" and many "replacement of small standard parts not involving complex assembly operations" performed daily, especially on small general aviation aircraft, that the agency would consider to be preventive maintenance, though they are not included in the 32 listed items.“
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This is the most useful post I have seen on PoA.
 
martym said:
I think part 43 says "hose connection." Nothing about replacing the hose itself or ducting.
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One could interpret that as the hose being the connection itself between two other parts.
 
martym said:
The first sentence in para (c) says: Preventive maintenance is limited to the following work.
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This and the similar limitation stated in the associated AC had been dealt with through other guidance until the Coleal LOI issuance made it easier. While this LOI is specific to a transport type aircraft it did provide a similar path found with the guidance involving the major alterations and repairs listings in the same 43 appendix.

While the Coleal LOI does not provide the ability to expand the 32 preventative mx items in 43, its does provide the guidance on how to define the tasks within those 32 items. The key guidance is applying the Part 1 definition to the lists in Part 43. Its this connection that gives the quoted statement above that those 43 lists are simply "examples" of tasks within the list categories. Same with the Part 1 definition of major alteration defining the list in 43 Appx A(a). Its this route that gives the OP the ability to change the SCAT hose under prevent mx.

Unfortunately, while the practice of defining prevetative maintenance tasks per this connection predates the Coleal LOI, its one of those topics that is not been discussed or promoted on a larger scale. There have been previous POA threads on this topic that also provide some examples of this guidance route if interested to review.
 
I would think that if one's A&P/IA is cool with it, then what's the problem? And if said A&P/IA is going to have a **** fit, then it doesn't matter what the regulations might allow.
 
Note to those pilots out there that aspire to one day becoming an A&P...:cool:
Your aircraft/engine log book entries can be used as record towards the practical experience requirement per (FAR 65.77). Qualifying pilot (FAR 43.3 (g)) needs to make a log book entry of whatever Preventative Maintenance items they did and sign it with their pilot license number per (FAR 43.9). There's a lot of good A&P's that acquired their certificate On-The-Job and there's no reason any of you can't do the same. :)

Example of a common standard Log Book Entry: Date; aircraft recording device number (Tach or Hobbs); Aircraft Total Time; Engine Since Overhaul and/or New time; Work accomplished, part numbers and manual references; Pilot name and signature; The words "43.3(g) Operator" and pilot number.

One More thing... No Maintenance may be performed without the use of appropriate 'MANUALS' per (FAR 43.13 (a) ). Aircraft are commonly older then 50 years anymore and good preventative practices and record keeping are making that possible.
 
kshaw said:
If you are replacing the SCAT hoses from air cleaner to carburetor on a Piper, see the Service Bulletin which requires using the Piper part. The Service Bulletin came out because some of the non-Piper hoses collapsed during takeoff causing some accidents.
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What is that service bulletin number? Couldn't find one. Also which aircraft, all Pipers? Thanks Bob
 
martym said:
The first sentence in para (c) says: Preventive maintenance is limited to the following work.
Permitted work tasks are subsequently listed. If other tasks were allowed it would say not limited to the following
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You are so wrong I actually feel bad calling you out.

I will enjoy jumping on this dog pile. Enjoy!
 
Ed Haywood said:
This is the most useful post I have seen on PoA.
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Because it shows how bad owners are at understanding the system?

There are many things to consider when replacing a ‘simple’ hose. Is it routed properly? You can’t rely on the current install to be correct. Are you considering heat sources? Are baffles missing? It’s only a simple tube until it fails because its installed wrong.
 
Ed Haywood said:
Having a working relationship with an A&P/IA, especially the one who does your annuals, is a great insurance policy for owner maintenance. First, whenever you are unsure of what you can do and how to do it, you can have a quick chat with your A&P to clarify. Second, if you do wind up getting into something you shouldn't, the A&P can supervise you or do a conformance inspection and log the work.
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This☝. I do a lot of maintenance work on my plane but I discuss everything with my A&P and anything that would not fall under owner maintenance (or a reasonable Coleal interpretation) I have him sign off on it. He’s the one signing off on the next annual anyway so he has to be confident everything is done properly. But I have all of the manuals, research everything to the nth degree before starting, and ask lots of questions. Probably takes me 10x as long to do it, and likely even more $. But I learn in the process, have confidence that my plane is maintained to my standards. And my way too busy A&P appreciates my plane not taking up a semi permanent parking spot in his hangar.
 
Robert Markle said:
What is that service bulletin number? Couldn't find one. Also which aircraft, all Pipers? Thanks Bob
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https://ad.easa.europa.eu/blob/CE1423.pdf/SIB_CE-14-23_1

https://www.aopa.org/news-and-media...ness-bulletin-issued-on-piper-air-inlet-hoses

https://piperowner.org/talk/discussion/comment/1439339#Comment_1439339

https://www.faasafety.gov/spans/noticeView.aspx?nid=5507

The SAIB database for the FAA appears to be down. But there’s plenty of info floating around the interwebs.
 
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FYI: SAIBs are not the same as a service bulletin issued by the OEM nor do they have same effect from a maintence point of view.
 
pfarber said:
You are so wrong I actually feel bad calling you out.

I will enjoy jumping on this dog pile. Enjoy!
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How long do I have to wait for the explanation? I'm not a young fella you know . . .
 
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