In reply to:
So, at least some FAA-types have taken the liberal interpretation in the past. I wonder if they’ve recently gotten more strict?
Yup, in that situation I doubt that the FAA would ever even TRY to raise the issue to a very high level (like a courtroom)… they themselves have set the precedent many times over. I say this not out of any qualification in law, but based on what seems logical - and yes, the little alarm bell in my head is ringing, because by now I should know that “logic” and “legal system”, or "logic and “government”, or "logic and “FAA”, are often incompatible word-pairs.
Here’s another FAA source that quotes the same text for the correct way to log an owner-performed oil-change: The FAA’s Bill O’Brien on Owner Performed Maintenance. They even provide a photo of the authority!
One thing I do recall from one of the FAA-given seminars on Owner-Performed Maintenance that I attended. They pointed out that as owner-pilots, we are allowed to do the 30 specific items called out in Appendix A of Part 43… but that we are also allowed to perform those actions that are inherently included in the listed items. Thus, although removal and replacement of brakes is not specifically mentioned, removal and replacement of tires IS defined in the list, as is servicing of the wheel bearings. Now to remove the tire or service the bearings, you must first remove the wheel; and to remove the wheel, you MUST disassemble - and subsequently reassemble - the brakes. So, said the FAA man, the removal and replacement of brakes is implicitly a permitted element of Owner-Performed Maintenance.
Similarly, he pointed out, we are allowed to replace oil filter elements and magnetic chip detectors. On most airplanes, removal of the main oil filter and (especially) the magnetic chip detector in the sump plug requires the draining of at least some of the oil, it’s fair to include oil changes in the list of permitted Owner-Performed Maintenance activities - provided that none of the work involves “complex assembly”, whatever that vague term means. All this came from an FAA fellow whose name I can’t recall, although now I wish I could.
Here’s the list from Appendix A of Part 43. I’ve highlighted the lines that I referred to in the examples above. To the extent that logic has some place in our aviation lives, I don’t see how anyone could really argue the point very convincingly!
© Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:
(1) Removal, installation, and repair of landing gear tires.
(2) Replacing elastic shock absorber cords on landing gear.
(3) Servicing landing gear shock struts by adding oil, air, or both.
(4) Servicing landing gear wheel bearings, such as cleaning and greasing.
(5) Replacing defective safety wiring or cotter keys.
(6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.
(7) Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. In the case of balloons, the making of small fabric repairs to envelopes (as defined in, and in accordance with, the balloon manufacturers’ instructions) not requiring load tape repair or replacement.
(8) Replenishing hydraulic fluid in the hydraulic reservoir.
(9) Refinishing decorative coating of fuselage, balloon baskets, wings tail group surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear, cabin, or cockpit interior when removal or disassembly of any primary structure or operating system is not required.
(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices.
(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.
(12) Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.
(13) Replacing side windows where that work does not interfere with the structure or any operating system such as controls, electrical equipment, etc.
(14) Replacing safety belts.
(15) Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.
(16) Trouble shooting and repairing broken circuits in landing light wiring circuits.
(17) Replacing bulbs, reflectors, and lenses of position and landing lights.
(18) Replacing wheels and skis where no weight and balance computation is involved.
(19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls.
(20) Replacing or cleaning spark plugs and setting of spark plug gap clearance.
(21) Replacing any hose connection except hydraulic connections.
(22) Replacing prefabricated fuel lines.
(23) Cleaning or replacing fuel and oil strainers or filter elements.
(24) Replacing and servicing batteries.
(25) Cleaning of balloon burner pilot and main nozzles in accordance with the balloon manufacturer’s instructions.
(26) Replacement or adjustment of nonstructural standard fasteners incidental to operations.
(27) The interchange of balloon baskets and burners on envelopes when the basket or burner is designated as interchangeable in the balloon type certificate data and the baskets and burners are specifically designed for quick removal and installation.
(28) The installations of anti-misfueling devices to reduce the diameter of fuel tank filler openings provided the specific device has been made a part of the aircraft type certificate data by the aircraft manufacturer, the aircraft manufacturer has provided FAA-approved instructions for installation of the specific device, and installation does not involve the disassembly of the existing tank filler opening.
(29) Removing, checking, and replacing magnetic chip detectors.
(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder’s approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided:
(i) They are performed by the holder of at least a private pilot certificate issued under part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under Sec. 147.21(e) of this chapter; (2) issued by the holder of the production certificate for that primary category aircraft that has a special training program approved under Sec. 21.24 of this subchapter; or (3) issued by another entity that has a course approved by the Administrator; and
(ii) The inspections and maintenance tasks are performed in accordance with instructions contained by the special inspection and preventive maintenance program approved as part of the aircraft’s type design or supplemental type design.