Preventive maint.

[Roger Lee]

Copied from another site and written by Carol Carpenter of Rainbow Aviation who teaches the 120 hr. LSRM courses and is involved in comities national for the LSA aircraft. Here is an exert from a discussion on who can do preventive maint on and SLSA. If other ion develops I'll let you know. This has always been this way and there is nothing new here.

 

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Carol Carpenter • The proper approach is to use the manufacturer's manual for preventative maintenance –

This is what I believe, as LSRMs, you should be encouraging.

 

There are two issues here- First the letter of the law and will I be violated?

The second, which is the perception of the rule and the intent.

 

To begin- an SLSA is a non FAA approved product. This makes it a very different aircraft from a certificated aircraft. The FAA does not approve the product and the standards direct the manufacturers to support and provide direction for the continued airworthiness of their fleet. For the maintenance requirements we have the regulations, the aircraft operating limitations, and we refer to the preamble on issues like this for the intent of the rule.

 

It is an accepted fact that if the manufacturer tells us to do something outside of the regulations – that the regulation stands and in this case does trump the manufacturer. However, as long as the manufacturer is within the limits of the law - his manuals are the preferred source for the preventative maintenance items. He can not add items to the list that are not in line with the regulations.

 

If, on the other hand, the manufacturers manual is more restrictive and you, as an owner were to perform a PM item on the Part 43 Appendix A list- which is not in the manufacturer’s manual- would you be violated? No – it would not be wise, but there isn’t a regulation to violate you. – except- keep in mind that 43 Appd A calls for an owner who is a private pilot or above. . .

 

There is a lot of stuff that is being done- that is not spelled out in the regulation in regards to light sport and much work is being done to update both the standards and the regulations.

The FAA accepts the standards and are working to bring the regulations and the standards into agreement -

 

We as the professionals in this industry should be encouraging the intent of the rule which is clarified in the preamble. Also remember that the regulations and standards are being revised and updated regularly to match the preamble and the intent of the light sport rule.

 

This issue warrants a much more detailed discussion- but I am crunched for time this morning. Gotta run. C