Taking Exception

take exception with the statement made in the sidebar "Oil-Changing Tips" in Octobers article, "Is Oil Analysis Worth It?" You state, "If you are the owner, changing your own aircraft oil and filter is completely legal with the FAA." Not so!The authorization for this action is in FAR 43.3(g), which states: "The holder of a pilot certificate issued under Part 61 may perform preventative maintenance on any aircraft owned or operated by that pilot which…

Editorial Staff

Wednesday, November 22, 2006 at 12:00 AM ET

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Key Takeaways:

Only certificated pilots, not all aircraft owners, are legally authorized by FAR 43.3(g) to perform preventative maintenance on aircraft they own or operate, and proper log entries (FAR 43.9) are required.
Pilots have a critical responsibility to use all available tools, including HSI, FMS, visual checks, and ATC communication, to ensure they are on the correct runway for takeoff and prevent accidents like Flight 5191.

See a mistake? Contact us.

I take exception with the statement made in the sidebar “Oil-Changing Tips” in Octobers article, “Is Oil Analysis Worth It?” You state, “If you are the owner, changing your own aircraft oil and filter is completely legal with the FAA.” Not so!

The authorization for this action is in FAR 43.3(g), which states: “The holder of a pilot certificate issued under Part 61 may perform preventative maintenance on any aircraft owned or operated by that pilot which is not used under Part 121, 129, or 135.” Preventative maintenance is defined by FAR 43, Appendix A (c)].

An owner who is not a licensed pilot may not perform preventative maintenance. A licensed pilot may perform preventative maintenance on airplanes that he does not own, as long as he is an operator of that airplane.

The requirement for making a log entry, your last point, is a very important step that is often overlooked by pilots performing preventative maintenance. The requirements for the log entry are outlined in FAR 43.9 and every pilot who performs preventative maintenance should know those requirements.

Jerry Miel
Durango, Mexico

Thanks, Jerry. Youre right, of course. That error crept in by simply presuming all owners are also certificated pilots, something youve highlighted as not necessarily the case. Too often, we in the general aviation community refer to “owner-performed” maintenance tasks even though the FARs refer to owners relatively few times.
None of which, of course, says that a certificated pilot
should be performing preventative maintenance on his or her aircraft. In fact, weve often said that one of the most dangerous things in general aviation is a pilot with a #2 Phillips screwdriver. Look for more articles on the relationships between safety and maintenance in the coming months.

5191

As always, I enjoyed your editorial “5191” in Octobers issue. While I agree with much of what was said regarding Flight 5191, I believe you omitted some perspectives that deserve mentioning. There are several “safeguards” and just plain smart aviation techniques which might have prevented this tragic accident.