Avionics News September 2020 - 17

five tasks (inspection, overhaul, repair,
preservation and the replacement of parts) and
excludes preventive maintenance. Why does
maintenance exclude preventive maintenance?
Again, reviewing 14 CFR Part 1, we see
that preventive maintenance is defined as
"simple or minor preservation operations and
the replacement of small standard parts not
involving complex assembly operations." The
two specified tasks defined by preventive
maintenance, preservation and replacement of
parts, are both contained within the definition of
maintenance. Therefore, while the definition of
maintenance excludes preventive maintenance,
it does include the tasks (preservation and
replacement of parts) of preventive maintenance.
It appears that the separation of preventive
maintenance from maintenance is designed
to support sections 43.3 and 43.7 on who can
perform the task rather than to create two
categories of maintenance. A person authorized
to perform preventive maintenance (14 CFR
43.3 (g)) is limited to the two tasks identified
in the definition, while a person authorized to
perform maintenance may perform all tasks
including preservation and replacement of parts.
This leaves three tasks to investigate:
inspection, overhaul and repair.
In FAA Notice N 8900.410, the agency
discusses the term "maintenance" as defined in
14 CFR Part 1, § 1.1 as "Maintenance means
inspection, overhaul, repair, preservation, and
the replacement of parts, but excludes preventive
maintenance." According to the FAA, "while
this definition has been around for a very long
time, differences between some of the elements
that make up maintenance (such as inspection
and overhaul) have not always been clearly
understood." In this notice, it attempts to discuss
the key differences between inspection and
overhaul. The FAA defines inspection as:
"Inspections are visual examinations
and/or manual checks to determine the
condition of an aircraft or component.
An inspection can range from a routine
visual examination to a detailed inspection
involving complete disassembly and/or

the use of complex inspection aids, such
as X-ray, ultrasonic, eddy current, or
magnetic particle equipment."
Overhaul is defined in 14 CFR section 43.2.
§ 43.2 Records of overhaul and rebuilding.
(a) No person may describe in any required
maintenance entry or form an aircraft,
airframe, aircraft engine, propeller, appliance,
or component part as being overhauled unless -
(1) Using methods, techniques,
and practices acceptable to the
administrator, it has been disassembled,
cleaned, inspected, repaired as
necessary, and reassembled; and
(2) It has been tested in accordance
with approved standards and technical
data, or in accordance with current
standards and technical data acceptable
to the administrator, which have
been developed and documented by
the holder of the type certificate,
supplemental type certificate, or a
material, part, process, or appliance
approval under Part 21 of this chapter.
The FAA Notice further clarifies that "overhauls
are maintenance. By definition, overhauls are a
form of maintenance, not inspection, and are not
included in an inspection program. Overhauls are
part of the maintenance program."
The definition of repair is a bit more difficult.
Since the modern federal aviation regulations
lack a current definition, we have to research the
historical records for an appropriate definition. The
civil air regulations (the predecessor to the current
federal aviation regulations) defined repair as:
"Repair means the restoration of an
airframe, powerplant, propeller, or
appliance to a condition for safe operation
after damage or deterioration."
Combining the definition of these five
elements (inspection, overhaul, repair,
preservation and the replacement of parts) we
have a better understanding of the meaning
of maintenance. It is important to note that
if the task at hand does not fall within the
definition of these five elements, it simply is not
maintenance. q

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Avionics News September 2020

Table of Contents for the Digital Edition of Avionics News September 2020
