AOPA Pilot Magazine - September 2019 - 90

P&E

SAVVY MAINTENANCE

safer than private operators (e.g., general
aviation pleasure or business). Pretty commonsense stuff.
Most of us know that the operating rules
are far more stringent for commercial operations under Part 135 or Part 121 than they
are for us Part 91 folks. Aircraft equipment
and operating limitations, weather requirements, fuel requirements, crewmember
qualifications, and recurrent training and
testing requirements (including checkrides
and drug tests) are all vastly more demanding than what we put up with. Less well
understood are the dramatic differences in
maintenance requirements.
FAA MAINTENANCE REQUIREMENTS

90 | 

Although the regulations concerning what
maintenance is required are complicated
and somewhat obscure, the basics are
straightforward:
Part 121/135 operators are required to
comply with both the inspection program
and the maintenance program recommended by the aircraft manufacturer (or

alternative FAA-approved inspection and
maintenance programs).
Part 91 operators of multiengine turbine
airplanes or large airplanes (over 12,500
pounds) are required to comply with the
inspection program recommended by the
aircraft manufacturer (or an alternative
FAA-approved inspection program) but are
not required to follow any particular maintenance program.
Part 91 operators of piston or singleengine turbine airplanes (12,500 pounds or
less) are not required to follow any particular inspection or maintenance program.
They require only a generic annual inspection every 12 months. (If the aircraft is used
to carry passengers for hire or to give flight
instruction for hire, it also requires generic
100-hour inspections.)
To understand what this means, it's
important to understand the distinction
between an inspection program and a
maintenance program. This can get a bit
confusing, because FAR 1.1 defines maintenance as "inspection, overhaul, repair,

preservation, and the replacement of parts,
but excludes preventive maintenance."
Thus, inspection is one sort of maintenance,
but the regs never explain what inspection
means. To unravel that, you must drill down
into some rather obscure FAA orders, interpretations, and memoranda.
Particularly illuminating is a 2017 FAA
national policy notice titled "Clarification
of Inspection and Overhaul Requirements
Under Part 91," which has since been
incorporated into FAA Order 8900.1
(Volume 3, Chapter 15, Sections 1 and
2). This memorandum was intended for
FSDO airworthiness safety inspectors, but
it makes illuminating reading for owners
of Part 91 aircraft and the A&P mechanics who work on them. Here are a few
excerpts from the policy:
* Inspections are generally visual examinations and/or manual checks to determine the
condition of an aircraft, product, or article.
* Inspection programs refer to a list of
scheduled inspection items accomplished
at defined intervals, whose main purpose

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AOPA Pilot Magazine - September 2019

Table of Contents for the Digital Edition of AOPA Pilot Magazine - September 2019
