AOPA Pilot Magazine - September 2019 - 91

is to determine the condition of the aircraft
and its components (e.g., airframe, engines,
propellers, rotors, appliances, survival
equipment, and emergency equipment) to
ensure continued serviceability.
* An inspection program should not be
confused with a maintenance program. An
inspection program will capture a list of
scheduled inspections which are completed
at designated intervals. A maintenance program should encompass all the elements
of maintenance, to include inspections,
overhaul requirements, repair schemes,
[corrosion prevention], and the scheduled
replacement of parts.
* Since Part 91 operators are not required
to comply with a manufacturer's entire
maintenance program, overhauls are not
mandatory for Part 91 operators who
operate strictly under Part 91 (with some
possible exceptions for Part 91 subpart K) in
most situations....[T]he definition of maintenance "...means inspection, overhaul, repair,
preservation, and the replacement of parts,
but excludes preventive maintenance." In

the definition, overhaul and inspection are
separate elements, which shows that they
are both unique forms of maintenance.
Overhauls are a maintenance process.
* Part replacement is a part of the overall maintenance program and should not be
included in an inspection program [unless
the inspection destroys a part, such as cutting open an oil filter].
* With some exceptions...compliance
with manufacturer service bulletins is not
required to be accomplished on any specific
timetable for Part 91 operators.
So, if you fly a Part 91 piston airplane or
a single-engine turboprop or jet, you don't
have to comply with any of the manufacturer-specified inspection or maintenance
intervals if you don't want to. If you fly a
multiengine turbine (such as a Beechcraft
King Air or Cessna Citation) or a large airplane (such as a Douglas DC-3) under
Part 91, you are required to comply with
the manufacturer's inspection program
(typically consisting of various phase
checks) but you don't have to comply

with the manufacturer's maintenance
program (including TBOs and scheduled
parts replacement) if you don't want to.
For any kind of Part 91 aircraft, you don't
have to comply with manufacturer's service bulletins.
There are a few exceptions. If the
FAA issues an airworthiness directive mandating compliance with some
manufacturer-specified inspection or
maintenance item or service bulletin,
then you must comply-ADs are nonnegotiable. Also, if you fly a newfangled Part 23
aircraft, such as a Cirrus or Diamond or
Corvalis/TTx, whose maintenance manual
contains an FAA-approved airworthiness
limitations section, then you must comply with anything in that section-such
as the 10-year chute repack and rocket
refit for the Cirrus SR22-provided it was
in effect on the date your airplane rolled
off the assembly line. (Revisions to the
maintenance manual are not retroactively
compulsory for aircraft manufactured
prior to the revision.)

| 91

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AOPA Pilot Magazine - September 2019

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