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Owner Assisted Annual Inspections

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Although an owner cannot perform any part of the annual inspection, even under an IA's supervision, there is absolutely no reason why an owner cannot participate in the maintenance portion of the inspection.

One responsibility of an aircraft owner is to ensure that all required maintenance and inspections are conducted on his (or her) aircraft. Federal Aviation Regulation 91.403(a) says that "The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition ..." and FAR 91.405 says that "Each owner or operator of an aircraft (a) Shall have that aircraft inspected as prescribed in subpart E of this part .?"

Now that you own - or hope to soon own - an aircraft, you need to know just what those regulations imply, require, and allow.

The purpose of any aircraft inspection is to ensure the continued airworthiness and safety of the aircraft. Private aircraft that are not operated for hire need a complete inspection only once every calendar year, regardless of the number of hours the aircraft has flown. This inspection is called an Annual Inspection (most pilots refer to it informally as an annual) and is specifically required by FAR Part 91.409(a)(1). FAR Part 43, Appendix D defines the scope and detail of an annual.

Only two entities can legally perform an annual - an airframe and powerplant (A) mechanic who holds an Inspection Authorization rating (IA), or a properly certificated repair station operated under FAR Part 145. No one else can do an annual, even under an IA's supervision.

Although an owner cannot perform any part of the annual inspection, even under an IA's supervision, there is absolutely no reason why an owner cannot participate in the maintenance portion of the inspection.

FAR Part 43.3(d) says "a person working under the supervision of a holder of a mechanic ... certificate may perform the maintenance ... that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation. However, this paragraph does not authorize the performance of any inspection required by Part 91 .?"

Because FAR Part 43 specifically excludes the performance of any inspection by other than the certificated person signing it off for return to service, it's important to know what the FAA considers to be maintenance and what it considers to be part of an annual inspection. Advisory Circular 65-19G, "Inspection Authorization Study Guide," says that "routine servicing is NOT part of the annual inspection. The inspection itself is essentially a visual evaluation of the condition of the aircraft and its components and certain operational checks. The manufacturer may recommend certain services to be performed at various operating intervals. These can be done conveniently at this time, and in fact should be done, but are not considered to be a part of the inspection itself."

In short, with the IA's approval and supervision, an owner can perform any or all of the maintenance and routine service functions that accompany an annual inspection, but the IA cannot delegate the actual inspection to anyone.

Some IAs make the majority of their living by performing annual inspections and prefer not to become involved in significant maintenance functions. These IAs may encourage owners to "preinspect" their aircraft for obvious defects and problems before the IAs start the inspection. It's important to note that the preinspection is not in any way part of the annual inspection process. You - the owner - are only helping yourself and your IA by finding and correcting problems prior to the annual inspection. Any problems you find and remedy will be that much less maintenance work for the IA, will very likely be less expensive for you, and will increase your knowledge of your aircraft and how it operates.

As the aircraft's owner/operator, you are entitled to perform various maintenance functions without being under the direct supervision of an A FAR Part 43, Appendix A, Paragraph C, "Preventive Maintenance," lists these functions. You can "preinspect" these items entirely on your own and correct any problems found before your IA begins the annual inspection. You should be aware, however, that depending on your relationship with your IA, he may repeat some or all of these maintenance items to ensure you've performed them correctly and in an airworthy manner.

If you desire to work beyond the items listed in Part 43, Appendix A, Paragraph C, you must work under the direct supervision of an A, as required by FAR Part 43.3(d). It's important that you work out your participation in the annual inspection process with your IA before you do any work on the aircraft. The IA is legally responsible for the completed inspection and will want to be clear on exactly what you will be doing and on your ability to do the work competently. Together you should identify specific tasks and establish check points in advance so that you and the IA will both know when and where the IA will want to inspect the work accomplished.

examples abound of maintenance items associated with an annual inspection. General items include the removal and installation of all cowlings, fairings, inspection panels, wing tips, etc., cleaning the aircraft and engine, and the removal of the aircraft interior.

Engine service items include draining and refilling the engine oil, cleaning the engine oil screen, changing the engine oil filter (if any), and cutting apart the oil filter to inspect the element for metal particles. All of the spark plugs (two per cylinder) must be removed, cleaned, gapped, and fire checked in a pressurized plug tester. The engine ignition timing will have to be checked and verified to meet the engine manufacturer's specifications.

The intake air filter will need to be cleaned or replaced as necessary. Check all engine primer lines for security and leakage. Broken and/or leaking primer lines are a common problem as aircraft age. Be sure to inspect the muffler and the cabin heat muff for leaks. Carbon monoxide entering the cabin through the cabin heat system is dangerous. If the engine has a carburetor instead of fuel injection, check the carb heat control for proper operation. The engine and everything in the engine compartment will be checked for security and proper movement, travel, and adjustment.

Airframe maintenance items include cleaning and greasing all wheel bearings, changing tubes and/or tires as required, replacing landing gear shock chords as required, checking and replacing brakes as required, and servicing the nose wheel shimmy damper (if any). If the aircraft has retractable landing gear, an annual inspection requires a gear retraction test and checking the emergency gear extension system. Check the tension and lubrication of all flight control cables and check all control cable pulleys for ease of operation and for flat spots.

If you're 6-foot-5 and weigh 250 pounds, crawling into the tail cone of a Cessna 150 to adjust the rudder cable tension will be an "interesting" experience - as will getting back out! Check all flight controls for damage and security of mounting. Turn on everything electrical and check it as best you can on the ground. If you don't know how to operate some piece of equipment, find someone who does, or get the operation manual.

Aviation is a constant learning experience, so take advantage of all the opportunities you get to know your aircraft better. Don't forget to try all the lights. Check your seat belts and shoulder harnesses (if any) for proper operation and for frayed belts. You can wind up the airframe maintenance with a bit of cosmetic work by touching up paint, repairing upholstery, and routine cleaning.

Your IA will have and use a model-specific checklist for the annual inspection and will have many more specific items to check out.

Participating in the annual inspection process can be an educational experience and can save money, decrease the down time on the aircraft, and give you an opportunity to monitor and understand the maintenance process and any specific concerns with your aircraft.

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