Part 24, Doing your own maintenance

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Morph
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Part 24, Doing your own maintenance

Postby Morph » Tue Jun 23, 2009 12:04 pm

I do believe it is time we readdressed this issue on owner maintenance and AMO/AP maintenance. We have already addressed the extended TBO's of the Rotax 2-stroke engines but I still find it unreasonable to expect an AP to do all the maintenance required on the aircraft, especially regular maintenance such as oil/filter changes, airfilter cleaning and plug changes. I mean seriously, this is simple line maintenance, that any reasonable person, should be able to achieve if they have the ability and the inclination. The option still remains to all of them to be able to get an AP to do the maintenance anyway

Looking at the regulations we see

Aviation Volume 2 Service Issue 20, December 2008
Part 24


This section defines which aircraft are covered by this PART,
Applicability
24.01.1 (1) This Part applies to –
(a) Amateur-built aircraft
(b) Production-built aircraft
(c) Veteran aircraft
(d) Ex-military aircraft
(e) Any other aircraft not qualifying, or not longer qualifying for the issue of
a certificate of airworthiness in terms of Part 21 of these Regulations.
(2) The aircraft referred to in sub-regulation (1) are classified in the following
sub-groups –
(a) Aeroplanes, including microlight aeroplanes
(b) Helicopters
(c) Gyroplanes and gyrogliders
(d) Gliders, including self-launching gliders and touring gliders
(e) Manned captive and manned free balloons
(f) Airships
(g) Unmanned aerial vehicles
(h) Hang-gliders, including powered hang-gliders
(i) Paragliders, including powered paragliders and paratrikes
(j) Parachutes
(k) Model aircraft
(l) Rockets
(3) This Part does not apply to any aircraft that, for the purpose of flight –
(a) is to be attached to and towed by a vehicle or vessel travelling on the
surface;
(b) other than a manned captive balloon, is to be moored to the surface or
any construction on the surface; and
(c) is to be flown line-controlled by a person on the surface:
Provided that such aircraft shall not be operated in contravention of these regulations,
or cause to be an obstruction to aviation.
(4) The airworthiness design standards for each sub-group of aircraft referred

Airworthiness
24.01.2 (1) Before a non-type certificated aircraft, other than an aircraft classified
in sub-groups (h) to (l) in sub-regulation 24.01.1(2), is considered to be
airworthy it shall –
(a) have been issued with –
(i) an Authority to Fly or a Proving Flight Authority, as the case may
be, in terms of this Part; and
(ii) a valid certificate of Release to Service;
(b) have been maintained in accordance with the provisions of this Part and
of Part 43, as applicable to the type of aircraft; and

(c) have no known condition which could make the aircraft unsafe for flight.
Maintenance and inspection
24.01.5 (1) The owner of a non-type certificated aircraft for which an Authority
to Fly is required in terms of these regulations shall –
(a) submit to the Commissioner or, if applicable: to the organization designated
for the purpose in terms of Part 149 of these Regulations, as the
case may be, for approval an Approved Maintenance Schedule or similar
document for the aircraft;
(b) ensure that the non-type certificated aircraft is maintained in compliance
with –
(i) its Approved Maintenance Schedule or similar document; and

(ii) to the extent applicable, the requirements of Part 43;
and
(a) take such action as is necessary to ensure the continued airworthiness of
the aircraft.
(Editorial Note: Numbering as per Gazette.)
(2) The format and minimum requirements for the Approved Maintenance
Schedule shall be as prescribed in Regulation 24.03.1.
So our aircraft need to be maintained in accordance with it's approved maintenance schedule having previously been submitted to the commisioner

Approved Maintenance Schedule
24.03.1 (1) A non-type certificated aircraft, specified in sub-regulation
24.01.1(1) and classified in the paragraphs (a) to (g) of sub-regulation
24.01.1(2), shall be maintained in accordance with its Approved Maintenance
Schedule in such a manner that it is airworthy at the commencement of any
flight.
(2) The Approved Maintenance Schedule, referred to in sub-regulation (1)
shall –
(a) prescribe which Approved Person(s) with the appropriate repair rating,
which licensed AME(s) and which approved AMO(s) may carry out

maintenance on the aircraft;
(b) specify the conditions under which maintenance shall be carried out,
including environmental conditions and equipment and tools to be used;
and
(c) be in the format as prescribed in Document SA-CATS-NTCA.
(3) Any non-type certificated aircraft, other than those referred to in subregulation
(1) above, shall be maintained by or on behalf of its owner in such a
manner that it is airworthy at the commencement of any flight. Where the aircraft
manufacturer or any approved organisation has issued maintenance instructions
or guidelines, these instructions or guidelines shall be adhered to.
So this is what it comes down to, the aircraft has to be maintained in accordance with this Approved Maintenance Schedule and this Schedule specifies who can do what maintenance.

Where would this Schedule come from? Well for one, the engine manufacturer and secondly the manufacturer of the Kit/plane

The Approved Maintenance Manual for the Rotax 912 says maintenance is divided up into Line Maintenance and Heavy Maintenance.

It also defines the authorised people as having had "type specific training" on the particular engine which is approved by the CAA,

“OR”

- Experience in performing the task
- Formal instruction from a Rotax authorised training facility or “On the job” instruction by a authorised Rotax representive.

So this is what I believe needs to be done
1. Get the manufacturers to specify the tasks of Line Maintenance vs Heavy Maintenance. Rotax 912 has already done this and has two different manuals
2. Each owner attend a line maintenance course with the engine distributor or it’s representative, this is the type of course Niren has done in the past.
3. Owners who have attended this course can thus sign off this maintenance. Perhaps get issued with a number ala AP scheme.
4. Heavy maintenance can remain the function of the AP or AMO or suitably qualified authorised individual

Line Maintenance on a 912
1. Spark plugs, check and replacement
2. Oil level check and top up
3. Coolant level check and fill up
4. Air/fuel/oil filter replacement
5. Oil/Filter replacement
6. Engine inspections, wiring, pipes, etc
7. Prop bolts
8. safety wires
9. Exhaust springs, check replace
10. Carb setup/balance

Line maintenance 2 Stoke
1. Spark plugs, check and replacement
2. 2 Stroke oil reservoir fill up
3. Rotary valve oil check and fill up
4. Coolant level check and fill up
5. Air/fuel filter clean/replace
6. Engine Inspections, wiring, pipes etc
7. Prop bolts
8. Safety wires
9. Exhaust springs, check replace
10. Carb setup/balance


Anything that requires the splitting up of the motor should be considered "Heavy" maintenance
What do you guys think.
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Re: Part 24, Doing your own maintenance

Postby wiskeyfoxtrot » Wed Jun 24, 2009 6:34 pm

Thanks for the input Morph, I do agree that "heavy work " should be done by an qualified person and ahve no problem with this.
but the small things that we always have done should be allowed.

Thanks again for the input.
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Re: Part 24, Doing your own maintenance

Postby Stephan van Tonder » Thu Jun 25, 2009 2:56 pm

So what do we need to do about this. I agree with your set up schedule - Does Misasa then take this to the carcom?.
Perhaps also include maintenance(removal/replacement) of radiators in that maintenace schedule..
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Re: Part 24, Doing your own maintenance

Postby Morph » Thu Jun 25, 2009 3:35 pm

I would like to get more response from the forum first

We have to draw a line somewhere as to what is Line and what is Heavy

If you build the aircraft yourself then you can do the whole installation as well, including engine, waterworks, electrics, exhaust etc. CAA see the owner builder equivalent to the AP when it comes to inspections etc. As they said to me, you built it, you are the one who knows it best, and as such you are allowed to sign off inspection and maintenance. However I don't think that means the inside of the engine. If you have the acumen to build it, design and install the cooling system etc then you also have the acumen to repair or replace same components.

I am NOT saying that you do all the inspections during the build, this still needs to be done by a suitably qualified AP to ensure that you did i right first time. Thereafter you, as the owner builder, can inspect your own aircraft for annual inspections etc. You cannot inspect your mates, or your one if you sell it. One of the pre qualifying requirements of becoming an AP is having built an aircraft.
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Re: Part 24, Doing your own maintenance

Postby Ian » Thu Jun 25, 2009 8:12 pm

Morph, I agree with your comments, however on the line maintenance course for 912 you also learn how to maintain the gearbox, removal, repair, reassembly, slipper clutch torque test. But I must admit, having built the aerie and done the line maint course, having an AMO refurb the box would be my choice.

I also get an AP to do the annual inspection, a second set of 'eyes' is well worth it..

Maybe the addition of a solo test flight after any owner maintenance is wise ? I always do that... :?

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Re: Part 24, Doing your own maintenance

Postby Dobbs » Sat Jun 27, 2009 6:04 pm

I have today had someone do the 300 hour on my 912S and I asked exactly this question, and apparently, if you are the builedr of the plane you are entitled to work on the engine - cannot vouch for the accuracy of this statment, and secondly, no indication of how much maintenance, such as splittting the block etc.

Secondly, same person told me that the CAA do not recognize Aviation Engines' Line or Heavy maintenence courses :shock:

Sure would support doing my own plugs, oil and filter changes.

Just a note of warning - 2 years ago when I put in an insurance claim for damages done to my plane, before the insurance company even asked for the details of the accident, they wanted to see the log book to confirm that the engine maintenance was done, this for a ground loop!!
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Re: Part 24, Doing your own maintenance

Postby grostek » Sat Jun 27, 2009 9:14 pm

Morph wrote:I would like to get more response from the forum first

We have to draw a line somewhere as to what is Line and what is Heavy

CAA see the owner builder equivalent to the AP when it comes to inspections etc. As they said to me, you built it, you are the one who knows it best, and as such you are allowed to sign off inspection and maintenance. However I don't think that means the inside of the engine. If you have the acumen to build it, design and install the cooling system etc then you also have the acumen to repair or replace same components.
Hi All,
This is for Servicing Rotax/Jabiru/Rotec/Lycoming/Continental etc.

Engine maintenance should be done as per Manufacturers recommendations and as laid out in the Line Maintenance course.

Overhauling an engine (Heavy Maintenance)should be an option for a suitably experienced person that has prior knowledge, the Overhaul Manual and the specialised tools to do the job as per Overhaul Manual.

Rudi Greyling, and others as well no doubt, have overhauled their own engines in the past with no ill effects.

Just as a builder takes extreme care during the build of his aircraft,because he does not want to sit at 8ooo' and worry about a shortcut he took, so the same carefull builder will do the overhaul of his engine with the same care and precision as when he build his aircraft to ensure no undue worry at 8000'after an engine overhaul.

This care and attention to detail on his own engine is in many cases much better than what is available from mainstream official engine repair shops, not all shops but some, as witnessed fairly regularly on this Forum by "had my engine/crank checked/done and 5 hours later it siezes/stops/calves" The same applies to Gearboxes.

I am convinced that he who wants to learn to do a job properly will do an equal or better job than many approved overhaul shops. If CAA have a frame work of regulations for owner servicing not only will it save money for owners, but almost cetainly INCREACE the safety record of Microlight/NTCA types.

This is for engines that do not fall under the above category.
If the builder uses an engine other than the above, or removes the data plate from any such engine and replaces it with a Data plate that says "PG Pieterse Power" 582.5 or 912.5 or 0201 or 2201 or 3301, etc et all and WRITES HIS OWN Maintenance Manual as well as his Own Overhaul Manual submits such Manuals to CAA for approval and assuming such Manuals are accepted, then he can do what he can do his own Line Maintenance/Heavy Maintenace to such engines/gearboxes.

It really comes down to taking responsibility for your actions.

How this all gells out from an insurance point of view I can not say because make no mistake insurance companies are in the business of NOT paying claims(or to be fair, as few claims as possible) hence cases like "Where is the log book entry for your last engine check" for a friggen GROUNDLOOP go figure. (This is my personal opinion). Ja they will deny but its results that speak louder than denials, of hoe?

For those who prefer to have approved organisations do their Inspection/Overhauls , fine that is your perogative.

At least lets consider granting, to those who want to and are technically able to do such Line Maintenace the right to do so.

Starting point may be doing a Line Maintenance course and then doing the next 2 or 3 services under supervision of a suitably qualified AP, before you are on your own.

Thanks for starting this thread Morph.

Kind regards,

Gunter Rostek.
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Re: Part 24, Doing your own maintenance

Postby Morph » Mon Jun 29, 2009 3:14 pm

Wildthing wrote:The issue of owner maintainance is as follows.
24.03.1 A (1) The owner of a non-type certificated aircraft may carry out maintainance on the aircraft, excluding the annual inspection referred to in regulation 24.03.2 provided that such aircraft is operated only in accordance with part 94 (Private) and not Part 96 of these regulations.
This has passed the CARCOM process and is awaiting promulgation; this should be passed very soon.
i.e. NTCA owners may maintain their own aircraft, change spark plugs and oil etc, providing it is not a repair or part of the annual inspection.
The owner builder may inspect and repair his own aircraft that he built himself and obtained an ATF for that same aircraft.
Hope this clears this up.
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Re: Part 24, Doing your own maintenance

Postby kloot piloot » Tue Jun 30, 2009 8:22 pm

After my incident with AZP earlier this year (refer "Accidents and incidents" on this forum) I have been convinced in writing that unless the (Rotax) manual states: "To be performed by a certified Rotax Service agent", you can do it yourselve.

Certified Rotax agents are AMO's and they will have to do 300, 600 hour overhauls etc.

Sparkplugs are on the list of general maintenance checks and can be done by the owner.
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Re: Part 24, Doing your own maintenance

Postby Beaver 550 » Wed Jul 01, 2009 3:29 pm

I think if the owner knows what he is doing, the more he does on his aircraft the better. As long as there are definite guide lines what will qualify as line maintenance. All aircraft owners knowledge and comfort levels are different. Two stroke engine overhaul is not rocket science and if the owner have the confidence to do it correct he should be able to do it . As long as the microlight is not used commercially. Four stroke is a bit more complicated and should be done by an AMO/AP. Annual's should be done by an AP. I have the best AP in Cape Town do the Annual on my microlight. Extra pair of eye is always good.
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Re: Part 24, Doing your own maintenance

Postby ystervark7 » Wed Jul 01, 2009 11:21 pm

My opinion is that people should be allowed to do all their own maintenance if used non-commercially.
Note the following:
- there has been a lot of cases where maintenance by AP, AMO's, both on certified en non certified airplanes, were done incorectly and resulted in engine failures, wheels-up landings etc.
- There are about 250 AP's. I would guess that about 100 who do this for a living and normally they have a second income as well (such as instructor) so they do not do it full time. There are more than 2000 microlights in SA. That means that an AP must service about 20 planes/year, on average about one every 2.5 weeks. I think if you ask them there are few of them who service that many microlights. What happen to the rest? I guess they are either not serviced at all or serviced in the backyard.
- It is often difficult to find an AP that has experience on a particular plane but quite often they are still allowed to do the maintenance (within limits) while the owner probably knows more about the plane and how to service it.
- If I Iook at the statistics for 2003 in this document (sorry could not find more recent numbers)
http://www.caa.co.za/resource%20center/ ... 202003.pdf
and I compare the number of accidents for NTCA with with TCA
NTCA accidents 49/3907 and TCA 74/4496
this does not indicate that more control/rules equate to less accidents

In general there are to many rules like this one that does not contribute to safety, it was made by somebody to feel as if they are doing something to improve safety without proper consideration.
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Re: Part 24, Doing your own maintenance

Postby skybound® » Tue Jul 28, 2009 11:42 am

Any further news on the AIC?
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Re: Part 24, Doing your own maintenance

Postby Morph » Tue Jul 28, 2009 2:38 pm

CAA will be discussing this very subject at our club meeting on Wed evening. I will update the forum immediately
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Re: Part 24, Doing your own maintenance

Postby HENNING JOHAN » Tue Jul 28, 2009 7:21 pm

Hallo!I just want to know if you are a owner of a trike,if that one can do an AP course.About 12 years ago i was a apprentice at an AMO at Rand.Working with differend aeroplanes(DC3,PIPERS,CESSNA'S,MOONEY'S AND YAK 52'S),then i did a course in boilermaker.I been flying for the last 19 years with friends about 3 years ago i bought my very first microlight(ZU-CAI,SCOUT with a 503).It's got 928 hours on frame aswell on the motor.40 hours before i bought the trike,the head has bedone over by aviation engines.Last year it was due for AP,CAA request an inspesion on the crank,this was done and a letter was send that the crank is in tolerance spec.I received the ATF. :lol: I want to replace bolts on the trike( pedals,suspension and manufacture replace as per manual at a 1000 hours)I want to buy it from the manufacture itself,can i do it myself? :roll: Can somebody give me advise,please :roll:
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Re: Part 24, Doing your own maintenance

Postby Morph » Thu Jul 30, 2009 1:24 pm

We had Pierre from RAASA (Wildthing on this forum) and Braam Hechter for CAA at our meeting last night and this is what they told us

An owner can do the maintenance on his own aircraft which includes replacing plugs, oil, filters, adjustment of carbs, replacing batteries, replacing nuts, bolts and wires etc. There is an AIC out, that he will post once he gets back to his office

The heavier stuff, like engine rebuilds should be done by an AP, suitably qualified person or AMO.

If you are the owner/builder of your aircraft you may do all the maintenance, repairs, rebuilds etc and inspect your aircraft yourself. You can only do this on your ownaircraft as long as you own it. Make the relevant entries in the logbook/flight folio, and where it asks for AP licence number write owner/builder

Note I am talking about Microlights and LSA. Not GA
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