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Rules for Owner Repairs/Mods

Dave H.

Member
Say I want to put a bigger oil cooler on my RV. Am I allowed, as long as I document? I'm not the builder, nor am I an A&P. Do I need an A&P "sign-off", or is just documenting the work OK?

-Dave
 
You can do that yourself. All you need an A&P for is an inspection once a year.

As far as documentation, not much is required, but I always ask myself, "What would the person who buys my airplane like to see in the logbooks?"
 
Sign Offs

Mel I find your post confusing. ELT is not required for single seat OR for other than airplanes(glider, gyrocopter, etc) Where required on non commercial aircraft battery change and function test can be signed off by owner. This in NOT NESSARILY tied to condition inspection, it may very well be due at a different date. Example: New ELT installed six months after condition inspection, ELT function test is due 12 months after installation.
Transponders are not required equipment except to comply with certain airspace requirements. When a transponder is installed the sign off is every 24 months, not by an A&P but by a certified avionics shop/individual.
 
Mel I find your post confusing. ELT is not required for single seat OR for other than airplanes(glider, gyrocopter, etc) Where required on non commercial aircraft battery change and function test can be signed off by owner. This in NOT NESSARILY tied to condition inspection, it may very well be due at a different date. Example: New ELT installed six months after condition inspection, ELT function test is due 12 months after installation.
Transponders are not required equipment except to comply with certain airspace requirements. When a transponder is installed the sign off is every 24 months, not by an A&P but by a certified avionics shop/individual.

I never said that they were tied to the annual condition inspection.
The statement was that the condition inspection is the only required sign off for EAB aircraft.
I stated that there ARE other required sign-offs. The majority of experimental aircraft are NOT single seat, gliders, gyroplanes, etc.
Most experimental aircraft fly in airspace requiring a transponder.
Of course, there are exceptions for everything.
 
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You can do that yourself. All you need an A&P for is an inspection once a year.

As far as documentation, not much is required, but I always ask myself, "What would the person who buys my airplane like to see in the logbooks?"

Mike,

Thanks for the reply, I appreciate it.

I'm wondering if this issue has been beaten to death in the forums in the past. I did a search and came up empty.

Can anyone point me to a thread dealing with this matter: who can do work on EAB aircraft? Or even an interp from the FAA?

Thanks,
Dave
 
Who can maintain a Homebuilt?
FAR Part 43 specifically states that the rules of that part do not apply to amateur-built airplanes. Therefore, any maintenance on an experimental airplane can be performed virtually by anyone regardless of credentials. (This does not apply to the condition inspection previously discussed). Let common sense be your guide as to what maintenance you conduct yourself.


http://www.eaa.org/en/eaa/aviation-...equently-asked-questions/condition-inspection

And FAR Part 43.1 (b) states Part 43 does not apply to aircraft issued an experimental certificate.
 
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Who can maintain a Homebuilt?
FAR Part 43 specifically states that the rules of that part do not apply to amateur-built airplanes. Therefore, any maintenance on an experimental airplane can be performed virtually by anyone regardless of credentials. (This does not apply to the condition inspection previously discussed). Let common sense be your guide as to what maintenance you conduct yourself.


http://www.eaa.org/en/eaa/aviation-...equently-asked-questions/condition-inspection

And FAR Part 43.1 (b) states Part 43 does not apply to aircraft issued an experimental certificate.

Yes anyone can work on an Experimental.

BUT, the Operating Limitations for piston powered aircraft state that the "condition inspection performed in accordance with the scope and detail of 14 CFR part 43 appendix D" so the Condition Inspection uses part 43.

The Operating Limitations also require that the pilot meet other parts of the FAR that Experimentals typically do not require. "The pilot in command also must meet the requirements of 14 CFR ? 61.31(e), (f), (g), (h), (i), and (j), as appropriate."

Just because the aircraft is Experimental does not mean that you can do anything but you can do maintenance. The once a year Condition Inspection and the every two year transponder check must be done by someone that is a certificated person and or shop. You may be the manufacturer of the aircraft but you are not a certificated manufacturer that can do the pitot / static transponder test / inspection.
 
dead horses

OK
To make sure this horse has been adequately flogged:

1. Anyone can work on an EAB.
2. The Condition inspection MUST be signed off
3. The Transponder and Pitot/static checks must be accomplished and signed by appropriately rated persons/shops only if those checks are otherwise required.
4. NO other log book entries are required for an EAB but are highly recommended.
5. Major maintenance/changes may be performed by anyone BUT....refer to your flt limitations to see what effect that has.....In my case, the Air Worthiness Cert is invalidated. Some folks would have to reenter the flt test phase.

What did I miss?????
 
Clarification added in red.

OK
To make sure this horse has been adequately flogged:

1. Anyone can work on an EAB.
2. The Condition inspection MUST be signed off by the holder of the Repairman's Certificate for that particular aircraft or an A&P (no IA required).
3. The Transponder and Pitot/static checks must be accomplished and signed by appropriately rated persons/shops only if those checks are otherwise required.
4. NO other log book entries are required for an EAB but are highly recommended.
5. Major maintenance/changes may be performed by anyone BUT....refer to your Operating limitations to see what effect that has.
 
In the March Kitplanes that I just got there was a pretty good article by Dave Prizio about just this subject. Good read!
 
OK
To make sure this horse has been adequately flogged:
1. Anyone can work on an EAB.
2. The Condition inspection MUST be signed off
3. The Transponder and Pitot/static checks must be accomplished and signed by appropriately rated persons/shops only if those checks are otherwise required.
4. NO other log book entries are required for an EAB but are highly recommended.
5. Major maintenance/changes may be performed by anyone BUT....refer to your flt limitations to see what effect that has.....In my case, the Air Worthiness Cert is invalidated. Some folks would have to reenter the flt test phase.
What did I miss?????

Annual ELT sign-off IAW 91.207

BTW, you do know that you can have your operating limitations amended to the latest version don't you? Then you could put the aircraft back into phase I with a new AW inspection.
 
Condition Inspections done by an A&P

A few points to considered when using an A&P to sign off a condition inspection on an EAB. First, I think we all agree that Part 43 does not include EAB. However when an A&P is asked to do a condition inspection on an AEB that has Operating Limitations that include the "inspect IAW the scope and detail of Appendix D of Part 43" statement, many FSDO inspectors interpret that to also mean the A&P will do that inspection IAW the 43.13 Performance Rules (general) and 43.15 Additional Performance Rules for Inspections. Many A&Ps do not agree that these two items apply to inspection EABs, but its a bit a of grey area. In this wonderful world of instant litigation, maybe the A&P wants to play it safe and agree with the FSDO. It has been said that Part 43 does not apply to EAB, but it may apply in certain respects to A&Ps working on them. Also note, that Part 65.81 and 65.85 and 65.87 may also pertain to A&Ps who work on EAB depending on the FSDO's interpretation.

When A&Ps work on TC'ed Aircraft, they make every attempt at avoiding liability due to negligent performance by complying with these very same regs. If A&P and IA in the TC world plays by these rules, its pretty easy for any A&P to work on any TC'ed aircraft knowing that the previously done work meets some level of performance standard.

Where this can become an issue is when a second hand EAB needs a condition inspection and the A&P sees grossly negligent work or no documentation of it. No worries, fire that worthless A&P and go find another, and possibly another. Word travels fast these days and it may end up that you own an EAB that no A&P is going to sign of the condition inspection due to negligent work or lack of documentation.

Many A&Ps are getting smart and using the Vans drawings and SBs as a tech data package to establish some level of "performance standard" to inspect EABs to that they are used to working to in the TC'ed world.

In summary, all previous posts are correct, on EABs, you can do almost anything you want. But be thoughtful to how you might have to explain to those worry wart A&PS who might not feel comfortable signing off your condition inspection when they see aluminum angle from Lowes on your pristine EAB.

Possibly work with an A&P ahead of time before making the mod and get an idea of how to make a mod that is line with Vans standards of building or maybe even review AC 43.13.
 
BTW, you do know that you can have your operating limitations amended to the latest version don't you? Then you could put the aircraft back into phase I with a new AW inspection.

Mel, does the FSDO have to make this amendment, or can a DAR (I am getting less than optimal results from my FSDO)?
 
A few points to considered when using an A&P to sign off a condition inspection on an EAB. First, I think we all agree that Part 43 does not include EAB. However when an A&P is asked to do a condition inspection on an AEB that has Operating Limitations that include the "inspect IAW the scope and detail of Appendix D of Part 43" statement, many FSDO inspectors interpret that to also mean the A&P will do that inspection IAW the 43.13 Performance Rules (general) and 43.15 Additional Performance Rules for Inspections. Many A&Ps do not agree that these two items apply to inspection EABs, but its a bit a of grey area. In this wonderful world of instant litigation, maybe the A&P wants to play it safe and agree with the FSDO. It has been said that Part 43 does not apply to EAB, but it may apply in certain respects to A&Ps working on them. Also note, that Part 65.81 and 65.85 and 65.87 may also pertain to A&Ps who work on EAB depending on the FSDO's interpretation.

Many A&Ps are getting smart and using the Vans drawings and SBs as a tech data package to establish some level of "performance standard" to inspect EABs to that they are used to working to in the TC'ed world.

In summary, all previous posts are correct, on EABs, you can do almost anything you want. But be thoughtful to how you might have to explain to those worry wart A&PS who might not feel comfortable signing off your condition inspection when they see aluminum angle from Lowes on your pristine EAB.

Possibly work with an A&P ahead of time before making the mod and get an idea of how to make a mod that is line with Vans standards of building or maybe even review AC 43.13.
65.81 is a requirement for A&P's. It refers to aircraft, not type certificated aircraft. That is a bigger bug a boo than 43.13.
An A&P that has not worked on a Rotax is not able to inspect that engine.
Ditto one that only works on aluminum aircraft can't inspect a Lancair.
As far as 43.13, remember that the builder is the manufacturer, NOT Van's.
Some recommendations of the plans, such as control surface travel I would consider very seriously. Each deviation from the kit supplier's plans I would evaluate for effect on "safe flight" since there is no such thing as airworthiness in an amateur built experimental aircraft.
 
Annual ELT sign-off IAW 91.207

I don't see a requirement for a "sign-off". What it says is

The new expiration date for replacing (or recharging) the battery must be legibly marked on the outside of the transmitter and entered in the aircraft maintenance record.

and

(d) Each emergency locator transmitter required by paragraph (a) of this section must be inspected within 12 calendar months after the last inspection for--
(1) Proper installation;
(2) Battery corrosion;
(3) Operation of the controls and crash sensor; and
(4) The presence of a sufficient signal radiated from its antenna.

For the first, I keep my complete checklist with detailed notes and such for each annual condition inspection, including notations on things like ELT battery replacement, and due date for the next one. Each year, I print out the form, update as needed, and due dates for things like batteries and O2 tank hydrotest and such are all verified (and then redlined during the inspection if/as necessary).

TBH, I hadn't actually realized that the inspection sans battery replacement was an *annual* requirement, and have been checking that at 2-year intervals while replacing the batteries, so that's good to know. As a matter of course, I do visually check the installation and activate the ELT via the remote button in the panel each year, but I guess I should take it out and whack it to check the g-sensor, too. Good to know.

In the larger picture, I don't put a lot of things in the aircraft maintenance *logbook*, but I do keep the records, nice and organized. E.g., each oil change, I get the report from the oil analysis company, complete with date, hours on oil, total engine/airframe time, etc., and file them in reverse chronological order in a binder. So that's a maintenance record, and in fact is far more detailed than a simple entry in the logbook.

About the only things in the actual logbook are annual condition inspection sign-offs and pitot/static/XPDR certs. All other maintenance is "logged" via records such as the oil reports, etc.
 
I don't see a requirement for a "sign-off". What it says is



TBH, I hadn't actually realized that the inspection sans battery replacement was an *annual* requirement, and have been checking that at 2-year intervals while replacing the batteries, so that's good to know. As a matter of course, I do visually check the installation and activate the ELT via the remote button in the panel each year, but I guess I should take it out and whack it to check the g-sensor, too. Good to know.

In the larger picture, I don't put a lot of things in the aircraft maintenance *logbook*, but I do keep the records, nice and organized.
About the only things in the actual logbook are annual condition inspection sign-offs and pitot/static/XPDR certs. All other maintenance is "logged" via records such as the oil reports, etc.

You are correct that the 91.207 requirement is for an inspection as you cite.
There is nothing specifying who can do it. For standard airworthiness certificate aircraft it has to be a licensed mechanic because it is not preventive maintenance. For experimental aircraft it would appear that anyone could do it, but would be best recorded by the person doing the annual condition inspection. There does need to be a record of the inspection.
As to "logging" and logbooks....most of you know, there is no requirement to keep anything but "records". Keep them in any format, media, etc that you wish, whether 3 ring binder, notebook, file folder, etc. Just do it in a way that is easily available to prove what has been done and to enhance the resale value should you ever need to sell your pride and joy. Logbooks are a tradition, but have limited flexibility.
 
Sorry I didn't see this sooner.

Mel, does the FSDO have to make this amendment, or can a DAR (I am getting less than optimal results from my FSDO)?

Any DAR with function codes 46 and 33 can amend amateur-built operating limitations.
 
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