Maintenance

[starcheckdriver]

Does anyone know if FAR 135 operators can allow pilots to perform any maintenance functions such as adding oil, draining pitot-static systems, etc.?

 

[Checks]

No reference for you but adding oil and fuel are considered "servicing" the aircraft and is not considered maint.

 

[nosehair]

Does anyone know if FAR 135 operators can allow pilots to perform any maintenance functions such as adding oil, draining pitot-static systems, etc.?

?!..Absolutely NOT!!...135 Pilots are NOT to touch anything beyound arm's reach of the Captain's Chair.

~Greasel
​

 

[MauleSkinner]

?!..Absolutely NOT!!...135 Pilots are NOT to touch anything beyound arm's reach of the Captain's Chair.

~Greasel

​

Right...ya gotta get a $5/hour line guy to add oil...just make sure you check the cap when he's done.

Fly safe!

David

 

[bocefus]

Under normal circumstances nosehair is correct. HOWEVER, it can and has been done. You can have this approved in your op spec. There are a number of 135 helo operators that have approvals for pilots to perform varying levels of maintenance that would otherwise not be permitted.

 

[starcheckdriver]

I have heard both sides of the argument and understand that FAR 43.3 (I think) states that 135 operators cannot allow pilots to do maintenance. However, where is it stated that things like adding oil are not considered maintenance?

 

[erj-145mech]

14CFR43, appendix D spells out what may be performed as preventive maintenance, but that excludes aircraft that are used in part 121 or 135 certificates. As mentioned earlier, this may be changed depending on the operators ops specs. But if a discrepancy is found by the crew, it must still be rectified by a maintenance action.

Adding oil is considered servicing, so thats excluded. Draining water from a static line depends. Is there a quick drain valve that can be opened to allow the moisture to be drained? If you have to open a line, as in removing a fitting, then no. If the static system is opened, then a static system test must be performed.

 

[nosehair]

?!..Absolutely NOT!!...135 Pilots are NOT to touch anything beyound arm's reach of the Captain's Chair.

​

Hey!! Don't get me in this...I was only being facet...fasis..fashis.., uhh, just kiddin'.

Of course you can service the airplane....(rolleyes)
​

 

[bocefus]

Hmmm, lots of opinions here. To properly answer the original question, the answer is no, unless you get it approved in your ops specs, or it is in the POH/AFM of your aircraft, and their are numerous examples where approval was given in ops specs for pilots to conduct maintenance. As I mentioned, it is not uncommon with 135 helo operators. As for part 121, numerous operators use PFE's who are expected to resolve maintenance discrepancies, and do.

 

[avbug]

The Director of Maintenance can authorize a pilot to perform a function as a delegated act under the authority of the maintenance department for the company. However, in order to do so, you must be knowledgeable in the techniques and practices necessary to accomplish the task, must have access to the current maintenance publications for the appliance, aircraft, powerplant, or accessory, you must have had training on that function, must have the calibrated tools called out for in the manufacturers publication, must be under a drug program (a given, if you're flying the airplane), and the work must be done to industry standard and to any specific standards spelled out in the manufacturers current maintenance pubs. You must also have undergone any company mandated training (eg, if the company GOM calls out flight safety as the maintenance training vendor, then you need to have attended the requisite FSI maintenance courses...not pilot courses...for that type). You'll also need specific training done and signed off in your employee records regarding Section D of your OpSpecs.

That all applies weather you're checking oil or performing a maintenance act.

If you're servicing the oil in a turbine engine, it needs a writeup. It may not necessarily be included in the permenant logs (seldom if ever is), but needs to be retained until oil is either added again or the oil is changed. This is generally kept in the flight logs, and is just as official a maintenance entry as any.

Same goes for a simple FMS database update.

You can do the work, if authoirzed, but still need to meet all the requirements that any maintenance personnel must meet. Additionally, there are a lot of functions you just can't perform if you're non-certificated, and a lot of things you can't sign off unless you're certificated. Any configurational changes require a signature, endorsement, and a rework of the weight and balance...which also requires a mechanic certificate and associated log entry.

Don't forget that any maintenance act you do will require a signature somewhere. Without the appropriate log entries, line 6 of your airworthiness certicate will tell you the aircraft is no longer airworthy, and that opens you up to more violation potential.

When serving as DOM in the past, I've caught pilots doing things on their own, and I subsequently grounded the airplane and required an inspection. Such acts, and the authorization to delegate or permit acts beneath the DOM, are at the purview of the DOM. It's his butt, his liability, and his responsibility.

 

[cvsfly]

The Director of Maintenance can authorize a pilot to perform a function as a delegated act under the authority of the maintenance department for the company. However, in order to do so, you must be knowledgeable in the techniques and practices necessary to accomplish the task, must have access to the current maintenance publications for the appliance, aircraft, powerplant, or accessory, you must have had training on that function, must have the calibrated tools called out for in the manufacturers publication, must be under a drug program (a given, if you're flying the airplane), and the work must be done to industry standard and to any specific standards spelled out in the manufacturers current maintenance pubs. You must also have undergone any company mandated training (eg, if the company GOM calls out flight safety as the maintenance training vendor, then you need to have attended the requisite FSI maintenance courses...not pilot courses...for that type). You'll also need specific training done and signed off in your employee records regarding Section D of your OpSpecs.

That all applies weather you're checking oil or performing a maintenance act.

If you're servicing the oil in a turbine engine, it needs a writeup. It may not necessarily be included in the permenant logs (seldom if ever is), but needs to be retained until oil is either added again or the oil is changed. This is generally kept in the flight logs, and is just as official a maintenance entry as any.

Same goes for a simple FMS database update.

You can do the work, if authoirzed, but still need to meet all the requirements that any maintenance personnel must meet. Additionally, there are a lot of functions you just can't perform if you're non-certificated, and a lot of things you can't sign off unless you're certificated. Any configurational changes require a signature, endorsement, and a rework of the weight and balance...which also requires a mechanic certificate and associated log entry.

Don't forget that any maintenance act you do will require a signature somewhere. Without the appropriate log entries, line 6 of your airworthiness certicate will tell you the aircraft is no longer airworthy, and that opens you up to more violation potential.

When serving as DOM in the past, I've caught pilots doing things on their own, and I subsequently grounded the airplane and required an inspection. Such acts, and the authorization to delegate or permit acts beneath the DOM, are at the purview of the DOM. It's his butt, his liability, and his responsibility.

We wanted to address the FMS database (flash card - UNS-1M) issue some time ago (135 operator). Our DOM and ourselves thought it rediculous that an A&P had to install it (to the cost of .4 hr x $70 = $28). The FSDO inspector was kind of fuzzy on it, but asked our DOM to write a letter authorizing the pilot to replace the database card and he gave us "training on the procedure". We have a maintenance entry in the Avionics Log. He later made some comment that he might have to readdress this, but he never follwed up. We also recently made up an oil consumption log to keep better track/history of oil use (limitation in POH for oil consumption - BE-200). Didn't know you had to keep an official log, but it makes sense. BE-200 operators - how do you account for oil use as it relates to the limitation 1qt/10 hr? At what point do you establish the "stabilized" level to where oil is no longer "blown out" and can then establish a reliable consuption rate? Our's appears to be at around 3 qts low (cold). For those who suggest it be addressed in the Ops Specs - which paragraph in Part D are these maintenance functions addressed or do you mean written into the Operations Manual?

 

[icefr8dawg]

Where I used to work we'd reposition the airplane around the corner where no one could see, accomplish the required maintenance task and contiue on. This prevented us from waiting all night for a mechanic to be brought up to wherever we were stranded. Although certain pilots were disallowed from filling oil because they subscribed to the more is better theory and blew seals and oil all over the place on a regular basis.

 

[avbug]

Where I used to work we'd reposition the airplane around the corner where no one could see, accomplish the required maintenance task and contiue on. This prevented us from waiting all night for a mechanic to be brought up to wherever we were stranded.

Hopefully you're not advocating that.

 

[icefr8dawg]

Hopefully you're not advocating that.

Do what you have to do to get home. If you have experience changing a starter or de-crudding plugs all the better to just get it done and get home.

 

[erj-145mech]

Is your equipment that shoddily maintained that you have to violate the regulations, or is it that your company is too cheap to safeguard its crews lives?

Does this happen on a regular basis? You must be the apple of your bosses eye, not having to pay a mechanic when he's got you for free.

Changing a starter is not preventive maintenance. How do you log the change?

 

[icefr8dawg]

Is your equipment that shoddily maintained that you have to violate the regulations, or is it that your company is too cheap to safeguard its crews lives?

Does this happen on a regular basis? You must be the apple of your bosses eye, not having to pay a mechanic when he's got you for free.

Changing a starter is not preventive maintenance. How do you log the change?

Yea, it's a violation of MX Far's but who wants to wait in a hotel for a mechanic to come do a job i'm perfectly cabable of doing. They can inspect it while I'm sound asleep in my bed and not at some Acron, OH hotel for hours on end.

 

[avbug]

Do what you have to do to get home. If you have experience changing a starter or de-crudding plugs all the better to just get it done and get home.

That's a poor attitude that's going to get you violated one day, or killed. What makes you think you can do the work? Do you have the publications, tools, training, and signoff to do the work? Once you've done it, and you've placed the company certificate in jeopardy by flying an unairworthy aircraft, how do you explain yourself?

Decrudding those spark plugs...how did you retorque them when you were done? Why were they "crudded" to begin with?

Same for the starter. Do you have the company authorization? Are you aware that hours spent as a mechanic are counted against flight hours, for good reason?

Yea, it's a violation of MX Far's but who wants to wait in a hotel for a mechanic to come do a job i'm perfectly cabable of doing. They can inspect it while I'm sound asleep in my bed and not at some Acron, OH hotel for hours on end.

You should have stopped at "Yea, it's a violation of..." and decided then and there that's as far as you're going to go. It's a violation, and therefore you're not goign to do it. Certainly not try to justify it. Especially on the grounds that you just didn't want to wait.

Ten feet down and still digging. Now's a good time to resolve to A) never do that again, and B) never tell anybody about it again, and C) avoid justifying illegal and potentially unsafe acts...especially for mundane and uncompelling reasons.

 

[icefr8dawg]

Uh, NO. I'll work however I like to actually. If anyone is being dangered it's me and I've been doing this since I was little so actually there's no danger to myself.

What I'm saying is that if you have the knowlege and are stuck in the middle of the night it's ok to bend the rules a little to get the job done. I'm not saying you have to do it this way but I won't accept you telling me I can't.

 

[icefr8dawg]

...and the sparkplug was fouled because someone forgot to teach leaning in Indoc I guess. I didn't foul it but I wasn't going to fly all night with it running like that. The torque wrench was absent that night but I assure you I didn't overstress the insert nor did the plug back out midflight.

 

[avbug]

What I'm saying is that...it's ok to bend the rules a little to get the job done.

Ah yes, justification. The narcotic of the soul.

The torque wrench was absent that night but I assure you I didn't overstress the insert nor did the plug back out midflight.

You must have one of those calibrated elbows that modern mythology speaks so much about. One of the aircraft types I fly had three wing failures in flight due to people with such elbows, overtorquing wing attach clevis fittings.

Incidentally, the reason for the torque isn't to keep the plug from backing out...tight will do that. It isn't to keep from overstressing the helicoil. It's to prevent stress on the head itself, and to provide the proper tension in the metal...only one torque value or a value within a narrow range will do that.

The torque wrench was absent that night

So what you're really saying is that you flew an unairworthy aircraft with an invalidated airworthiness certificate (line 6, remember?), that night, following illegal maintenance that was improperly done using the wrong tools, and lacking the appropriate maintenance publications.

Gotcha.

I'm not saying you have to do it this way but I won't accept you telling me I can't.

Heavens no. I won't tell you that. We have the FAA for that.

You remember them? That pesky federal agency that grants you your flying privileges and establishes the regulations which governs them? Those guys. They tell you you can't.

If anyone is being dangered it's me and I've been doing this since I was little so actually there's no danger to myself.

Well there's a sermon and a half. From this we learn that it's okay to do dangerous things and break the rules so long as we're only hurting ourselves. Excellent rational justification if ever there was, and the bane of drug users, suicides, and criminals the world over.

Of course, it's perfectly justified since you've been doing it since you were a kid. I understand that completely. Speeding is illegal, but if you have done that since you were a kid, it's okay, and you're justified. Stealing is illegal, but if you have done it since you were a kid, it's okay, and you're justified. Ad infinitum.

Of course, as long as youv'e gotten away with it before, it's okay. Gotcha.

You're a bright one, right you are. Gotta give you that.

Of course, this is the FAR board...I suppose it's okay to brag about your justification for violating the regulation...so long as at least you're talking about regulation.

 

[icefr8dawg]

Incidentally, the reason for the torque isn't to keep the plug from backing out...tight will do that. It isn't to keep from overstressing the helicoil. It's to prevent stress on the head itself, and to provide the proper tension in the metal...only one torque value or a value within a narrow range will do that.

1. It's not a helicoil and close is good enough if it gets me home with the engine running properly.
2. Not bragging just telling it how it is out here at certain places. You don't have to work there. You don't sound like you'd enjoy flying freight anyway.
3. I made a point of telling ya: "yup, it's a violation to do it that way." After all this is the FAR's board isn't it P I don't need to be blasted for operating the aircraft in an unairthworthy state I can go talk to my POI about that. Chances are he won't care so long as he didn't see it happen.

Anyway, I'm done arguing. Not gonna change anything I do because it works and I have the endorsement of the folks I work for. Your opinion differs.

 

[USMCmech]

If anyone is being dangered it's me and I've been doing this since I was little so actually there's no danger to myself.

I may disagree with AvBug on some issues, but not this one!

I assume that you realize that other people may fly this plane after you get home and park it. Yes, I have seen an example of where the threads failed on a spark plug/head and it blew out durring opperation.

Just because you can physicaly do the job dosen't mean you know what you are doing. For example, changing/cleaning ignitor plugs on a turbine is a good way to electrocute yourself if you are not VERY careful. It's an easy simple job, except for one key safety step that dosen't apply to piston sparkplugs.


I have no problem with pilots performing preventative maintence as allowed under pt 43, or as allowed under pt 135 opspecs, or "owner assisted" annuals. There are plenty of skilled people who do fine work on their own planes. Changing sparkplugs is one of the items that pilots are allowed to do. HOWEVER, maintence must be done right regardless of who does it. Shoting from the hip on maintence tasks places inocent lives at risk.

This kind of thing may be commonplace in Alaska, and other remote locals, but also rember that Alaska has the worst safety record in the US.

If you don't want to get stuck in the middle of nowhere then have your opspecs changed, carry the parts and service manuals on CD-ROM, and a small kit with the proper tools and spares. A small torque wrench isn't expensive and dosen't weigh much.

 

[cvsfly]

We wanted to address the FMS database (flash card - UNS-1M) issue some time ago (135 operator). Our DOM and ourselves thought it rediculous that an A&P had to install it (to the cost of .4 hr x $70 = $28). The FSDO inspector was kind of fuzzy on it, but asked our DOM to write a letter authorizing the pilot to replace the database card and he gave us "training on the procedure". We have a maintenance entry in the Avionics Log. He later made some comment that he might have to readdress this, but he never follwed up. We also recently made up an oil consumption log to keep better track/history of oil use (limitation in POH for oil consumption - BE-200). Didn't know you had to keep an official log, but it makes sense. BE-200 operators - how do you account for oil use as it relates to the limitation 1qt/10 hr? At what point do you establish the "stabilized" level to where oil is no longer "blown out" and can then establish a reliable consuption rate? Our's appears to be at around 3 qts low (cold). For those who suggest it be addressed in the Ops Specs - which paragraph in Part D are these maintenance functions addressed or do you mean written into the Operations Manual?

Anyone have an example of any crew performed maintenance like a FMS database update "written into their Ops Specs"?

 

[JAFI]

Cusfly, I did oil servicing on the aircraft I flew (135) but I do not remember it being written into the OPSPECS. We were trained by an approved training program (written into the POH and I assume maintenance manual) with recurrent training. No problem.


--------------------------------------------------------------------
Non A&P's doing unapproved maintenance on aircraft. Let's see....

I know of a pilot who knew better than the aircraft manufacturer (wood wing bi-plane) and did not have the wings inspected at the regular interval (he said it was too expensive), the wings folded (in flight), the landing path was straight down.

A helicopter pilot (not an A&P) did not like the transmission chip detector going off all the time so he disabled the detector, when the transmission ate it self (the chip detector was working properly) a short time later in flight, the auto rotation and him surviving the landing was unsuccessful.

A pilot (non A&P) thought it was OK to use compressed air (because it was cheaper than aviation oxygen) in his O2 bottle. He never woke up.

A non pilot/non mechanic owned and flew a small helicopter. He illegally flew and did his own inspections and maintenance. He must not have noticed the corrosion on the tail rotor. The rotor departed the aircraft in flight. Luckily it happened a couple inches from the ground. He lived, but the aircraft was a ball of aluminum.

I attended a crash investigation class for homebuilt aircraft. The EAA presenter told us that the greatest percentage of accidents were because the pilot builders decided to "improve" the fuel system with their own modifications.

If you do not have the training, knowledge, tools, authorization, and the certificate .... Let some one who does do the work.

JAFI

 

[cvsfly]

Specifically looking for the GPS database update (flashcard) for a 135 operation. I think it has been established that adding oil is servicing not maintenance.

 

[A Squared]

This kind of thing may be commonplace in Alaska, and other remote locals, but also rember that Alaska has the worst safety record in the US.

Who said anything about Alaska?

A pilot (non A&P) thought it was OK to use compressed air (because it was cheaper than aviation oxygen) in his O2 bottle. He never woke up.

OK, that's not a pilot/A&P/Maintenance issue, that's a stupidity issue. That guy should have never become a pilot.

 

[JAFI]

OK, that's not a pilot/A&P/Maintenance issue, that's a stupidity issue. That guy should have never become a pilot.

Stupid or not, that's why I said:

If you do not have the training, knowledge, tools, authorization, and the certificate .... Let some one who does do the work.

JAFI

 

[mike1mc]

Although I don't like it, no pilot is allowed to touch a 135 aircraft. The closest I have gotten is approval to perform specific (M) Maintenance Procedures in MEL Items. My PMI has given us approval to ahve crewmembers disengage circuit breakers and placard items when these are functions of a Maintenance or (M) Procedure. These items have specific procedures included in our Ops Manual, everyone completes training, and this training is documented every year. Basically allows me to pull a breaker to say complete the TCAS MEL procedure without having to find an A&P.