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Pilot adding engine oil allowed under Pa

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Checks

Well-known member
Joined
Dec 23, 2001
Posts
447
Can a pilot under Part 135 refill hydraulic oil, engine oil, or transmission oil?
 
I think your answers are: No(or maybe), yes(under certain conditions) and maybe.

FAR 43.3(g) states:

"The holder of a pilot certificate....may perform preventive maintenance on any aircraft owned or operated by that pilot which is NOT used under Part 121, 127, 129 or 135."

Now before you go running off, 43.3(h) has an exception for operating rotorcraft in a remote area (and since you listed transmission, I'm thinking you're flying rotor stuff). So if your operation has this exemption, well carry a small toolbox! ;-)

For normal stuff (i.e. you are not exempted) then we go down your list:

Hydraulic fluid - listed as preventative maintenance under the Appendix to Part 43 (bullet # 8). Ergo, 121/135 pilots can NOT do this unless otherwise exempt.

Engine Oil - this is NOT listed anywhere BUT Part 135 DOM's (Directors of Maintenance) have to keep a very strict engine log. Generally, one sign of wear is oil consumption and most operators require a "log" for the pilot to note oil added. Ergo, a pilot should be able to add oil or have a line boy add oil, but you "should" have to note this or log this and hand in the log to the maintenance dept. Your Operations Manual should cover this operation.

Transmission Oil - may be in the Appendix under #6 and concerns the lubrication of parts that only requires the removal of a cover plate. I am not helicopter rated and have no idea if this is considered a special lubricant or is just considered as another engine oil.
 
Also note that updating GPS databases fall under this as well. Instead of getting a mechanic sign-off every 28 days, we now have approval from our FSDO to update our GPS (uses a simple flash card). We had to get a letter from our DOM saying he gave us "training" for removal and installation of the database. Same goes for changing out the seating arrangement in small (9 or less pax seats), which I did in in an air ambulance service years back in a C-340. Built my own dolly where I could have the isolette on top level with the door frame and slide it in the cabin door by myself.
 
Engine oil would depend on piston or turbine. I have yet to asked by a fed if I had training to add oil in a piston aircraft. The reality is that we have all had training in adding oil to piston aircraft. But turbine, they have asked me if I had, had training in adding oil. Mostly because of the variations in oil types and the fact that too much causes problems you don't have with pistons.

As for the GPS, it depends on the FSDO. Mine considers the GPS database like approach plates. Any pilot should be able to change them. But after some of the screw ups I have seen pilots make in the Jepps, maybe your FSDO has a better idea.
 
I think the answer would come from your maintenance manual.

My GUESS is that you would not be able to.

For 121 ops, definitely not, unless you have been trained, and it is part of the company manual.
 
We used to do it at my company when we were Part 135. The company even provided step ladders and cases of oil to take with us to check and service the oil. Later on, The FAA said that pilots may not perform these functions since they were not A&P certified. The same went with hydraulic fluid check and service.

It became a MX function from then on and the oil (Exxon 2380 Turbine) was considered a hazardous material so we could not carry it anymore.

The arguement we had was per the checklist which stated in the pre-flight checklist "Engine Oil-----Checked." Since the 1900 is a single pilot aircraft and can be flown under Part 91 that item was in the checklist. At least that is what I heard from other pilots.

Under Part 121, the answer is no. No matter if Hydraulic or Engine oil. Pilots cannot service the acft.

Hope that helps.
 
Thanks for all the replies. I pretty much knew the answer but needed confirmation. It is amazing you cant add your own engine oil but that is the FAA way.
 
B190C,

You can carry a spare can of oil, even 2380. Although it is HAZMAT there is an exception for required aircraft supplies. Most feds are not aware of that. Not surprisingly as it is hidden within the HAZMAT regs. Which are administered by FAA Security.
 

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