Is a pilot the "Owner/operator" too?

[UndauntedFlyer]

Owner/Operator?

The Owner/Operator is authorized to perform “Preventive Maintenance.” OK, so you rent an airplane, you’re on a multi-day trip and it needs a repair while you’re on the trip. Can someone document that that person is the “Owner/Operator” and therefore qualified to perform any of the following 32 maintenance operations? And, how about if you’re just a day-renter and you want to replace (update) the nav-database (#32 below) before you fly? Where is the documentation that allows that renter to perform the “Preventive Maintenance?”.

Part 43 - Appendix A

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:


(1) Removal, installation, and repair of landing gear tires.


(2) Replacing elastic shock absorber cords on landing gear.


(3) Servicing landing gear shock struts by adding oil, air, or both.


(4) Servicing landing gear wheel bearings, such as cleaning and greasing.


(5) Replacing defective safety wiring or cotter keys.


(6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.


(7) Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. In the case of balloons, the making of small fabric repairs to envelopes (as defined in, and in accordance with, the balloon manufacturers' instructions) not requiring load tape repair or replacement.


(8) Replenishing hydraulic fluid in the hydraulic reservoir.


(9) Refinishing decorative coating of fuselage, balloon baskets, wings tail group surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear, cabin, or cockpit interior when removal or disassembly of any primary structure or operating system is not required.


(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices.


(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.


(12) Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.


(13) Replacing side windows where that work does not interfere with the structure or any operating system such as controls, electrical equipment, etc.


(14) Replacing safety belts.


(15) Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.


(16) Trouble shooting and repairing broken circuits in landing light wiring circuits.


(17) Replacing bulbs, reflectors, and lenses of position and landing lights.


(18) Replacing wheels and skis where no weight and balance computation is involved.


(19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls.


(20) Replacing or cleaning spark plugs and setting of spark plug gap clearance.


(21) Replacing any hose connection except hydraulic connections.


(22) Replacing prefabricated fuel lines.


(23) Cleaning or replacing fuel and oil strainers or filter elements.


(24) Replacing and servicing batteries.


(25) Cleaning of balloon burner pilot and main nozzles in accordance with the balloon manufacturer's instructions.


(26) Replacement or adjustment of nonstructural standard fasteners incidental to operations.


(27) The interchange of balloon baskets and burners on envelopes when the basket or burner is designated as interchangeable in the balloon type certificate data and the baskets and burners are specifically designed for quick removal and installation.


(28) The installations of anti-misfueling devices to reduce the diameter of fuel tank filler openings provided the specific device has been made a part of the aircraft type certificiate data by the aircraft manufacturer, the aircraft manufacturer has provided FAA-approved instructions for installation of the specific device, and installation does not involve the disassembly of the existing tank filler opening.


(29) Removing, checking, and replacing magnetic chip detectors.


(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided:


(i) They are performed by the holder of at least a private pilot certificate issued under part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under §147.21(e) of this chapter; (2) issued by the holder of the production certificate for that primary category aircraft that has a special training program approved under §21.24 of this subchapter; or (3) issued by another entity that has a course approved by the Administrator; and


(ii) The inspections and maintenance tasks are performed in accordance with instructions contained by the special inspection and preventive maintenance program approved as part of the aircraft's type design or supplemental type design.


(31) Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, and operational check must be performed in accordance with the applicable sections of part 91 of this chapter.


(32) Updating self-contained, front instrument panel-mounted Air Traffic Control (ATC) navigational software data bases (excluding those of automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)) provided no disassembly of the unit is required and pertinent instructions are provided. Prior to the unit's intended use, an operational check must be performed in accordance with applicable sections of part 91 of this chapter.​

 

[avbug]

Undaunted, I believe your question chiefly asks if the pilot can be considered an operator, and then goes on to ask if the work can be done.

14 CFR 1.1 defines "operate" as:

Operate, with respect to aircraft, means use, cause to use or authorize to use aircraft, for the purpose (except as provided in §91.13 of this chapter) of air navigation including the piloting of aircraft, with or without the right of legal control (as owner, lessee, or otherwise).

The maintenance requirements, as found in 14 CFR 91.403(a) & (b):

(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter.
(b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter.

One is authorized to perform preventative maintenance, per 14 CFR 43.3(g):

(g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

One must make the proper log entries, per 14 CFR 43.5:

No person may approve for return to service any aircraft, airframe, aircraft engine, propeller, or appliance, that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless—
(a) The maintenance record entry required by §43.9 or §43.11, as appropriate, has been made;
(b) The repair or alteration form authorized by or furnished by the Administrator has been executed in a manner prescribed by the Administrator; and
(c) If a repair or an alteration results in any change in the aircraft operating limitations or flight data contained in the approved aircraft flight manual, those operating limitations or flight data are appropriately revised and set forth as prescribed in §91.9 of this chapter.

Authorization to return aircraft to service following preventative maintenance, 14 CFR 43.7(f):

(f) A person holding at least a private pilot certificate may approve an aircraft for return to service after performing preventive maintenance under the provisions of §43.3(g).

What must be in the maintenance record entries executed by the person performing the preventative maintenance, per 43.9(a):

(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
(1) A description (or reference to data acceptable to the Administrator) of work performed.
(2) The date of completion of the work performed.
(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

Once the maintenance entries have been performed, per 91.407(a):

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless—
(1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and
(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made.

Once the appropriate maintenance entries have been made, they must be kept by the operator in accordance with 91.417 as follows:

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) including, for each, the method of compliance, the AD number, and revision date. If the AD involves recurring action, the time and date when the next action is required.
(vi) Copies of the forms prescribed by §43.9(a) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods prescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.

 

[avbug]

The following letter explores some specifics not relevant to the question, but also addresses the most salient point very appropriately, which is that "preventative maintenance" may be more than it appears at first reading, and may not be authorized even though it's one of the 32 cited items in part 43 Appendix A. The letter also addresses the differences in the operating regulations applicable to the specific aircraft situation (eg, Part 91, vs. part 135, etc).

http://www.faa.gov/about/office_org.../interpretations/data/interps/2009/Coleal.pdf

Dated February 26, 2009:

Bombardier Learjet
David M. Coleal
Vice President and General Manager
P.O. Box 7707
Wichita, Kansas 67277-7707
Re: Request for Interpretation of Applicable Rules in 14 C.F.R. parts 43,
91, and 135 Pertaining to Whether a Pilot of a Transport Category
Aircraft May Check Tire Pressure During a Normal Preflight Inspection

Dear Mr. Coleal:

By letter dated January 8, 2009, you requested a legal interpretation that would answer the question whether a pilot could legally check tire pressure on a transport category aircraft that was being operated under 14 C.F.R. parts 91 or 135. You noted that this issue had been discussed at three meetings between representatives of Bombardier Learjet and officials from various offices of the FAA, including the Flight Standards Service (AFS). Your request was supplemented by a letter dated January 30, 2009, from David M. Hernandez, attorney for Bombardier Learjet. Mr. Hernandez's letter provided additional information and legal analysis. For the reasons discussed below, it is our opinion that checking tire pressure on the transport category Learjet Model 60, the aircraft addressed in the correspondence, is preventive maintenance.

While your question was framed in the context of transport category aircraft, your inquiry, including as supplemented by Mr. Hernandez, is specific to the Learjet Model 60 aircraft. You referenced an FAA Continued Operational Safety (COS) initiative in which, in November 2008, the FAA's Wichita ACO (Aircraft Certification Office) requested an AFM (Airplane Flight Manual) limitation for the Learjet Model 60 that would require daily tire pressure checks. The issue, as you alluded to in your letter, is whether checking tire pressure on the Learjet Model 60 is considered to be a maintenance or preventive maintenance function, versus a simple preflight inspection task. Your correspondence correctly observed that, under 14 C.F.R. § 43.3(g), for aircraft not operated under part 121, 129, or 135 (e.g., part 91), a pilot may perform preventive maintenance on an aircraft operated by that pilot.

As you know, under the Federal Aviation Regulations, maintenance is defined to mean: "inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance." 14 C.F.R. § 1.1. And, preventive maintenance is defined to mean "simple or minor preservation operations and the replacement of small standard
parts not involving complex assembly operations." Id. Preventive maintenance, in general, includes tasks that are less complex than those deemed to be maintenance, and requires less sophistication in terms of the knowledge, skill, and tools required.

Many preventive maintenance tasks are listed in 14 C.F.R. part 43, appendix A, paragraph (c). The paragraph sets forth in 32 numbered subparagraphs items the FAA has determined to be preventive maintenance. 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 1.1, we believe that such limitation'is not controlling. Similarly, for the same reason, we also believe that the following sentence in Advisory Circular 43-12A, Preventive Maintenance (which was referenced in Mr. Hernandez's letter), is overly restrictive. That sentence, found in Paragraph 3(b)(1), states: "If a task or maintenance
function does not appear in the list, it is not preventive maintenance." 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[ s] 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. It is our understanding that Flight Standards' Aircraft Maintenance Division is planning to clarify this issue in a future revision to the AC.

Mr. Hernandez's letter observes that the first item listed as preventive maintenance in Appendix A, paragraph (c), is "Removal, installation, and repair of landing gear tires," and notes that checking tire pressure is not listed as a preventive maintenance item. The implications appear to be two-fold: First, because checking tire pressure is not listed, it
must not be preventive maintenance. Second, because checking tire pressure is but a simplistic and small subset of the tasks necessary in removing, installing, and repairing landing gear tires, it does not rise to the level of even preventive maintenance, and should therefore be considered an appropriate pre- flight inspection task. We do not agree. Paragraph 3(b)(1) of AC 43-12A also cautions that "because of differences in aircraft, a function may be preventive maintenance on one aircraft and not on another." The above reference to changing and repairing landing gear tires illustrates this maxim. The FAA may agree that the pilot of a small general aviation airplane may change and repair its landing gear tire, but the agency would not consider the changing and repair of a landing gear tire on a large transport category airplane to be preventive maintenance that a pilot could permissibly do.

Your letter stated that Bombardier Learjet's engineering and pilot specialists believe ample precedent exists for "qualified pilots to safely perform tasks that require mechanical, physical interaction with the airframe under the umbrella of preflight checks. " You followed with a long list of examples of pre- flight actions performed daily by professional pilots, including many actions that require use of a calibrated device. Our response to your request takes no position on the propriety of any of the cited examples as pre-flight tasks.

We have discussed this issue with officials in the FAA's Flight Standards Service Aircraft Maintenance Division (AFS-300) and concur with their determination that checking tire pressure on a Learjet Model 60 aircraft is preventive maintenance and not a simple pre-flight inspection task. We believe their determination is a reasonable one based on the relevant facts and circumstances. These include the high tire air pressure (up to 219 psi g), the need for a proper and calibrated gauge, and the possibility of an
incorrect reading if the check is not performed properly. Accordingly, a pilot operating that aircraft under the operating rules of 14 C.F.R. part 91 may, in accordance with the provisions of 14 C.F.R. § 43.3(g), perform daily landing gear tire pressure checks. Under the same regulation, however, a pilot of that aircraft operating under 14 C.F.R. part 135 may not perform that task.

As you know, under 14 C.F.R. part 11, an affected party may seek relief from an FAA regulation by filing a petition for an exemption. This is an avenue open to persons operating the Learjet Model 60 airplane under Part 135 who would be adversely affected by the requirement that only a certificated mechanic may check the tire pressure. Each operator seeking such relief should specify in its petition the relief sought and the reasons
for the relief. In addition, each petition must state the reasons why a grant of relief would be in the public interest and why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which exemption is sought. As to whether the FAA would entertain a request to grant a "blanket exemption" applicable to all operators upon their completion of "pre-determined criteria," we note that it is not the FAA's policy to do so.

This response was prepared by Edmund Averman, an Attorney in the Regulations Division of the Office of the Chief Counsel and coordinated with the Aircraft Maintenance Division of the Office of Flight Standards. If you have additional questions regarding this matter, please contact us at your convenience at (202) 267-3073.

Sincerely,

Rebecca B. MacPherson
Assistant Chief Counsel for Regulations AGC-200

 

[avbug]

The golden standards for the work to be performed, which apply equally to the certificated mechanic and the private pilot performing preventative maintenance, in accordance with 43.13(a) & (b):

(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).

As the operator of the aircraft, may you perform the work? Yes. What will the facility from which you rented the aircraft have to say about your performance of that work? Good question. Better check with them. While you're performing that work, do you have a current copy of the manufacturer's maintenance publications (all of them) available to you, and the appropriate tools called out in those publications? Are you using calibrated tools, the proper wire, lubricants, fittings, tools, and so forth to ensure the job is done to the industry standard, as required by the regulation? All necessary questions you must ask yourself when you undertake this work.

Given that preventative maintenance is limited in scope and not simply permissible because it's a listed function in appendix A, more thought must be given to the operation in question. Any function listed which involves complex assembly or disassembly, for example, isn't authorized, even though it's listed in Appendix A. Changing a tire is listed, but may require specialized jacking procedures. Changing the tire may involve an airworthiness directive, a requirement to perform dye penetrant or magnetic particle inspections on the wheel halves and bolts, even stripping and replacement of wheel coatings, removal of burrs, nicks, and other stress risers, even treatment of the wheel metal or measurement of various dimensions or hardness using calibrated tools and equipment. A calibrated torque wrench should be used in reassembly, and specific anti-seize compounds for wet or dry torque must be used as applicable by the manufacturer must be utilized by the specific milspec or other part number. The replacement of nitrogen in the tire must be done in accordance with the component publications, and often requires observation for 24 hours, and may not be authorized even though appendix A to part 43 specifically allows the replacement of tires.

The specifics of the particular operation must be closely scrutinized to determine if it's authorized, even though on the surface it appears to be authorized. The truth is that Appendix A is very limited in scope. Many mistakenly believe that simply because an operation is cited there, it's okay to perform, and this is just not the case. Take for example the legal interpretation provided by the FAA Chief Legal counsel on something as simple as putting air in a tire, or checking the pressure.

 

[avbug]

Another legal interpretaton addresses the differences in a renter being considered a commercial operator, or a private operator, in the rental of an aircraft. Again, like many legal interpretations (which define the regulation as applied by the Administrator), certain principles in the interpretation apply, though not necessarily the entire letter, to the question at hand.

http://www.faa.gov/about/office_org...0/interpretations/data/interps/1993/Green.rtf

October 26, 1993

Ryan S. Green
883 East Arnecia Court, #20
Salt Lake City, UT 84106

Dear Mr. Green:

This is in response to your letter dated September 29, 1993. You ask whether the following circumstances would constitute operations in Part 91 of the Federal Aviation Regulations or Part 135 of the Federal Aviation Regulations.

A company engaged in the purchase and sale of vehicles needs to transport its employees--commercial drivers--to remote locations to pick up vehicles that the company has purchased, and to drive the vehicles back to the company's lot to be sold. The company would hire you, a commercial pilot, to fly these drivers to remote pickup sites, in an aircraft that it would rent from a local flight school. The transportation would be provided to the drivers at no cost to them.

Generally, a commercial operating certificate under Part 135 is required to engage in the carriage in air commerce of persons or property for compensation or hire. Under the circumstances you describe, it would appear that the carriage of persons is not for compensation or hire, since there is no payment made to the company or compensation received by it for transporting its employees. I also note that the company's transportation of its own employees, by air, would be merely incidental to the company's principal business of vehicle sales.

I would caution you against allowing this arrangement to evolve into a de facto operation of private carriage for hire. This would occur if you, in fact, put together the transportation package consisting of aircraft and pilot services and received payment for the operation of the flights, even if the clientele was limited to one customer. This would require a commercial operator certificate.


The distinction between the two operations is that in the first scenario the company would be deemed the operator of the flights, for its own employees, with you hired merely as a commercial pilot; whereas in the second scenario, you would be considered the operator of the flight receiving compensation for the transportation of another company's employees. Under the first scenario, the company as well as you, are responsible for the operation of the aircraft. Prior to beginning the operation, you should ensure that the company accepts its role as the operator of the flights and recognizes that it is responsible for accidents or violations which occur as a result of the operation.

If you have any further questions, please feel free to call me at (206) 227-2007.
Sincerely,

George L. Thompson
Assistant Chief Counsel
[FONT=&quot][/FONT]

Notice that when the Assistant Chief Counsel makes the distinction in the difference between the two scenarios, he cites the renter of the aircraft as the Operator.

 

[brokeflyer]

that was all very vague avbug.....

you need to post more info

 

[nismo611]

maybe he should specify a bit more.

 

[UndauntedFlyer]

Avbug:

Thank you for your reply. Your posting on this topic is the work of a true aviation professional. I do appreciate the research required for such a documented and accurate reply.

 

[avbug]

Undaunted,

I have to apologize. I ran into some formatting issues with the reply citing regulation, which makes the reply harder to read than intended. Only regulatory excerpts should have been in quotes, but while editing I managed to get some of my comments as well as the regulation in quotes, which makes it less readable,and perhaps confusing. I ran out of time to edit, as the web site cuts off access at 60 minutes, and the post was stuck as it is now. I've also applied part of the following reply from one I made to a post on a different web site, on the same topic (to avoid retyping the whole enchilada). That reply, for the sake of illustration, addresses the simple act of replacing a tire.

 

[avbug]

Again, an apology for the sequential posting, but the web site limits the length to only so many characters.

The term owner/operator leads to some confusion in the regulation, as it's context can mean several things, and these are not interchangable in all settings, but may be the same in others. Owner refers to the registered owner of the aircraft, but operator can refer to a technical operator (pilot, etc) or one who operates the aircraft for compensation or hire, or privately. Operate, as shown in 14 CFR Part 1, applies regardless of the legal attachment of ownership or operation.

Further complicating the issue is the subject of the preventative maintenance, in which an identical preventative maintenance may be perfectly legal acceptable in one context, and forbidden in another. The Administrator's position is that the efficacy of preventative maintenance must very much be put in context to discuss or identify it's legal acceptance...the specific situation is important when considering what can or can't be done.

Another complication, separate from the regulation, is a relationship with the owner or owner/operator (such as a flying club or FBO which is operating the aircraft as a rental). Insurance, company policies, and liability/duty concerns may limit what one can do to the aircraft insofar as preventative maintenance. Further, other issues previously covered such as availability of current maintenance publications, availability of appropriate documented parts, and appropriate tools, must be considered.

Supervision by a qualified mechanic is a good idea. Some basic principles apply regardless of how you go about the project, and remember that holding a mechanic certificate is no guarantee of qualification or capability. There are plenty of mechanics out there who will take shortcuts or not do the job right, and every job should be taken seriously, whether it's driving a single rivet or replacing a nosewheel tire.

You're able to change the tire as a preventative maintenance function, found in 14 CFR 43, appendix A. Anyone who does work on the airplane, however, is still responsible for meeting the performance rules of Part 43. You've got to do the work to the same standard, using the same practices and techniques, as any certificated mechanic. You've also got to use the appropriate tools and parts called out by the manufacturer, and you have got to use a current maintenance manual, and relevant data. This is a regulatory requirement, found in 43.13.

The aircraft maintenance manual may not be sufficient for the work you do. In many cases, the component manufacturer will also publish maintenance data or information, and you must be in possession of the current version of this data. A cleveland wheel, for example, may have not only the airframe manufacturers manual, illustrated parts catalog, etc...but will typically also have a Cleveland document as well. To add to this more, you may also have an airworthiness directive to address, such as a wheel inspection.

When the work is performed, you're responsible for ensuring that it's done with the proper tools. A torque wrench for example...which while not required by regulation for the work you're doing, should have been calibrated in the past 12 months.

You're responsible for industry standards for assembly of that wheel, too. You need to balance it within 3 ounces when you put the wheel halves together, mate the tube and wheel, and mount the tire. You're responsible for separating the wheel halves, thoroughly cleaning them, and inspecting them. Multiple inspection points merit attention, including the inner and outer flanges, mating surfaces, and bolt holes, as well as bolts for stretch, creep, trueness, cracks, etc. Inspection should at a minimum involve a visual once-over, use of a 10X power magnifying glass, and ideally, dye penetrant such as magnaflux. Nicks or scraches in the metal are stress risers that lead to cracks, and must be addressed in accordance with both the manufacturers directions or recommendations, and advisory circular AC 43.13.

All the old rubber must be removed off the wheel assembly, and it should be thoroughly degreased and cleaned. It may need retreatment or spot treatment with alodine...but be careful. Do you have an aluminum wheel, or a magnesium alloy? You can damage it with the wrong process. Corrosion must be addressed. It may need treatment with chromate or other coatings. The wheel halves must be marked and put back together with the same parts relative to each other (same bolt holes together, etc...remember, it's supposed to be a balanced assembly).

When you clean the wheel, be careful of scratches, or using compounds that could damage the material or alloy. Be careful what abrasives you use, too; steel wool, for example, will embed in aluminum, and can lead to cracks, and corrosion.

The balance that's done should be done in several stages, with the wheel halves themselves being balanced, then with the tube and tire as well.

The tire must be inspected, as must the tube (if tubed). The proper assembly sequence must be followed, starting with taking the tire down (mechanics have been killed or lost fingers, eyes, etc, from loosening wheel half bolts before removing the valve stem core to relieve tire pressure). A wheel can fracture or blow apart during deflation as easily as inflation, as changing forces on the wheel halves occur. When assembly is made of the wheel halves, the proper torque sequence and partial and overinflation must occur in the requisite stages to prevent uneventorque, a pinched tube, proper seating of the tire bead, etc. Never guess at torque, or do it out of sequence. it's typically best done to half-torque in a criss-cross pattern, for example, then to full torque. I like to go back one more time at the same torque setting and always do a double click instead of a single click when checking the final torque. Improper torquing can cause wheel failure.

Wheel bearings should be thoroughly cleaned, inspected, and repacked. Ensure the proper grease, and be careful of combining incompatable greases. Ensure all packings, felts, washers, circlips or retaining clips, and other parts are put back in the respective side in the proper order.

When the wheel is put back on the airplane, ensure proper tension on the nosewheel fork, proper securing of the wheel nuts. If you do the cotter key (for cotter keyed installations) wrong, it's got half-strength. If you're using an assembly that involves two small bolts and nuts, you're also responsible for knowing and applying standards applicable to self-locking nuts.

The wheel in most cases should be reinflated with dry nitrogen...not just shop air.

When the wheel assembly is complete and re-installed, you're also responsible for the next 24 hours for performing a leak-down test on the tire; the installation isn't done until this is complete.

The installation also isn't done until all associated paperwork is complete. This includes your maintenance log entries (using references to the proper paragraphs in the maintenance publications). Part 43.5 provides part of this requirement, but not all. 43.9 provides the documentation specifics for completion of the paperwork, and the inspection of your work...you've got to inspect the work and approve it for return to service.

Your signature for this maintenance entry will count for aproval for return to service for the work performed. If you've addressed an airworthiness directive and are qualified to do so, then you must also cite the AD and should also update the master AD list for the aircraft records.

You're not done yet. If you've had to remove other parts, such as a wheel fairing to get to the wheel, you're also responsible for inspecting the parts removed and ensuring they're put back properly...but you can't do this if there are discrepancies involving those parts...and some of them you may be able to address, some you may not. Remember that preventative maintenance is permissible when the work does not involve complex disassembly or reassembly. As your work also involves the nosewheel fork and gear, you'll be responsible for inspecting the gear attached to the fork.

While you do the work you're also responsible for jacking the airplane properly using the approved process and tools. Some will set cases of oil on the horizontal stab...is this an unauthorized process for your airplane? Often yes, just as pushing down on the tail is also not authorized in most light nosewheel airplanes...you have to act in accordance with all of the manufacturer directions.

I point some of these things out as a reminder that aircraft maintenance based on watching a video, for the most part, doesn't cut it. It's a little more involved. I also point it out because you may get a mechanic to supervise you who doesn't fullfill all the requirements. This still doesn't absolve you of the duty to meet them, and a bad mechanic may set a bad example. In maintenance, one should always strive for the highest standard,a nd there are too many out there who will settle for a quick fix or shortcuts. Don't let anyone do that to you; it's a disservice to you and to anyone who might fly your aircraft.

Even something as simple as changing a tire requires the full respect and treatment that would be accorded any maintenance operation with the airplane. Never let anyone tell you "it's just a tire." It's not. It's that and a lot more.