Preventive Maintenance and Records
This article highlights some of the Federal Aviation Regulations related to aircraft maintenance. While much of the required maintenance must be performed by, or under the supervision of a certified repair station, the regulations also permit the pilot to perform some preventive maintenance. These regulations, along with the balloon manufacturer´s Instructions for Continued Airworthiness, or maintenance manual, set out the requirements for the aircraft owner/operator to keep the aircraft physically and legally airworthy.
The FAR´s, written in bureaucratic language; eventually tell you what maintenance operations you are authorized to perform, and what records you are required to keep. Referrals to some applicable FAR´s are at the end of this article. Please refer to your copy of the current FAR/AIM for the complete text.
Preventive Maintenance (as defined in FAR 1.1) means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.
What does this mean to me?
FAR 91.403 require the owner or operator of the aircraft to maintain it in airworthy condition and comply with all applicable airworthiness directives. It also refers to Part 43 which specifies who may perform different maintenance operations and endorsements. After working through the regulations, you will see that the holder of a pilot certificate is authorized to perform preventive maintenance operations, and make an entry in the maintenance records approving the aircraft, appliance, or component part for return to service. Note that the aircraft must be owned (at least in part) by the pilot.
FAR Part 43 Appendix A lists several preventive maintenance operations that the pilot/owner may perform, but it also defers to the aircraft manufacturer´s maintenance manual for specific procedures.
Examples of preventive maintenance items as defined in some manufacturers´ maintenance manuals are as follows:
(1) Removing dust, soot and debris from basket and burner when it does not require disassembly of any basket primary structure or burner assembly components.
(2) Removing dirt and debris from hook and pile fastener tapes on the deflation panel.
(3) Moistening or applying protective materials to basket wicker, or refinishing or applying protective materials to decorative furnishings of the basket such as leather upholstery when that does not require disassembly of any primary structure or interfere with the integrity of the fuel system.
(4) Replacing prefabricated fuel hoses not requiring disassembly of any threaded pipe fittings.
(5) Replenishing methanol in propane tanks.
(6) Replacing instrument batteries.
(7) Interchanging balloon baskets, burners, and cables that are specifically designed for quick removal and installation, and when such removal/installation can be accomplished by the pilot; provided that baskets are not interchanged except as provided in the Flight Manual for that balloon.
(8) Cleaning and inspection of suspension cables.
(9) Limited rattan repair.
(10) Temporary repair of fabric damage not exceeding acceptable damage limits, using adhesive backed patches.
(11) Repair of skirt fabric or envelope fabric below the first horizontal load tape.
(12) Replacement of Velcro tabs on the parachute top or envelope.
(13) Washing the envelope fabric using approved procedures.
(14) Replacing Kevlar cables or carabiners.
Most of the preventive maintenance items are different from repairs that must be performed by a repair station because they normally:
1. Do not require special tools or knowledge.
2. Do not modify the structure of the aircraft.
3. Are similar to operations performed in preparing the aircraft for flight.
Refer to the maintenance manual for your balloon to determine exactly what preventive maintenance you may perform, and how to perform it. If you do not find the answer there, contact your local repair station or the balloon manufacturer for guidance. If an operation is not considered preventive maintenance, you may be able to make arrangements for a repair station to consult with you and observe your work. If you complete the work under the direct supervision of, and to the satisfaction of the repair station, they can inspect it and authorize the aircraft to be returned to service.
After you perform preventive maintenance, make the appropriate entry in the aircraft logbook or maintenance records.
Examples of suitable endorsements are:
Gore 5 panel 7 orange, 3" adhesive patch near top center, per manufacturer´s instructions. TT=240.5 hr. Joe Pilot, Private Pilot Certificate # 123-45-6789 6-1-98
Removed tanks, cleaned basket. Varnished floor. Reassembled system. TT=405.3 hr. Jane Pilot, Commercial Pilot Certificate # 789-01-2345 4-16-98
The maintenance records for your balloon may be kept in your aircraft logbook, but they may be kept in a separate maintenance logbook. Other maintenance records include repair station work orders and 337 forms. Often the details of the repair will be spelled out in the work order. The logbook will contain either an annual/100 hour inspection endorsement, or a return to service endorsement, possibly with a listing of major repairs. It will also contain a reference to a work order number.
Under the FAR´s, a repair station is required to keep work orders for two years. They may be destroyed after 2 years. As a practical matter, I would recommend that you keep a ring binder for photocopies of your aircraft logbook or maintenance logbook, and all of the work orders you have for the balloon. The work orders are especially useful for tracking life limited parts such as fuel hoses, fuel cylinder pressure relief valves, and some suspension cables.
If you take your system to a repair station that has never seen it before, and you do not have the records available, some time consuming and expensive tests may be required, or some parts may need to be replaced that have already been replaced. If the repair station does not have the maintenance records for the system, you can not prove the work was previously performed. When they have any doubt about the required work having been done, they will quite properly do it again. If you can produce copies of the records, you can prevent unnecessary work and expense.
Please refer to the FAR/AIM parts listed below for more details. All of the parts listed below, except for Part 39, are included in the paper FAR/AIM book that most pilots already own. These documents are also available through the Internet at the following URL:
FAR 1.1 General definitions Preventive Maintenance
FAR 91.403 General (a),(b)
FAR 91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration. (a)(1),(2)
FAR 43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations. (a),(c),(e),(g)
FAR 43.5 Approval for return to service after maintenance, preventive maintenance, rebuilding, or alteration. (a)
FAR 43.7 Persons authorized to approve aircraft,... appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration. (f)
FAR 43.9 Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records ... (a)(1),(2),(3),(4)
Appendix A to Part 43 Major Alterations, Major Repairs, and Preventive Maintenance
(c)(5), (6), (7), (9), (10), (11), (22), (24), (25), (26), (27)
Additional Useful Information
If you have Internet access, and would like to know the reasons for your balloon system´s design, look at FAR Part 31 -- Airworthiness Standards: Manned Free Balloons. This is the standard that many of the world´s balloon manufacturers use to design balloon systems for sale in the US. Some foreign agencies have added other requirements to this standard, such as the requirements for higher basket sides.
FAR Reference for Repair Station article
FAR 1.1 General definitions
Preventive Maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.
FAR 91.403 General
(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with Part 39 of this chapter. (See below).
(b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter.
FAR 39.3 General
No person may operate a product to which an airworthiness directive applies except in accordance with the requirements of that airworthiness directive.
Airworthiness directives are issued by the FAA or a manufacturer if a hazard is discovered that may endanger the operation of your aircraft. Compliance methods are specified in the airworthiness directive (AD).
FAR 91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.
(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless --
(1) It has been approved for return to service by a person authorized under Part 43.7 of this chapter, and
(2) The maintenance record entry required by Part 43.9 or Part 43.11, as applicable, of this chapter has been made.
FAR 43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.
(a) Except as provided in this section and Part 43.17, no person may maintain... or perform preventive maintenance on an aircraft... to which this part applies.
(c) The holder of a repairman certificate may perform maintenance and preventive maintenance as provided in Part 65 of this chapter.
(e) The holder of a repair station certificate may perform maintenance, preventive maintenance, and alterations as provided in Part 145 of this chapter.
(g) The holder of a pilot certificate issued under Part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under Part 121, 127, 129, or 135.
FAR 43.5 Approval for return to service after maintenance, preventive maintenance, rebuilding, or alteration.
No person may approve for return to service any aircraft... or appliance that has undergone maintenance, preventive maintenance, rebuilding , or alteration unless--
(a) The maintenance record entry required by Part 43.9 or 43.11, as appropriate, has been made;
FAR 43.7 Persons authorized to approve aircraft,... appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration.
(f) A person holding at least a private pilot certificate may approve an aircraft for return to service after performing preventive maintenance under the provisions of Part 43.3 (g).
FAR 43.9 Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records ...
(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft... appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
(1) A description (or reference to data acceptable to the Administrator) of work performed.
(2) The date of completion of the work performed.
(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
(4) If the work performed on the aircraft... appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.
Appendix A to Part 43 -- Major Alterations, Major Repairs, and Preventive Maintenance
(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations.
(5) Replacing defective safety wiring or cotter keys.
(6) Lubrication not requiring disassembly other than removal of nonstructural items...
(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 manufacturer´s instructions) not requiring load tape repair or replacement.
(9) Refinishing decorative coating of ... balloon basket, ... cabin, or cockpit interior when removal 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.
(22) Replacing prefabricated fuel lines.
(24) Replacing or 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.