Elementary Maintenance

[cgartly]

I would like to do my own oil changes on my 172N with the good ol' O-320-H2AD engine.

Standard 625 Appendix A lists the following:

(7) cleaning or changing of fuel, oil, and air filters, on small privately operated aircraft;
(8) draining and replenishing engine oil, on small privately operated aircraft;
(29) repetitive visual inspections or operational checks (including inspections and tests required by airworthiness directives) not involving disassembly or the use of visual aids, performed out of phase with the aircraft’s scheduled check cycle at intervals of less than 100 hours air time, provided the tasks are also included in the most frequent scheduled maintenance check.
(ii) Tasks referred to in (29) above are elementary work when performed out of phase, but require a maintenance release when done as part of a scheduled maintenance check.

Based on the above I have always thought it was ok.

There is an AD on the particular engine that states the following:

2. Within the next 50 hours in service after the effective date of this AD and at every subsequent oil change thereafter, not to exceed 100-hour intervals, inspect lubrication system for metal contaminants. Inspection of the lubrication system consists of visual examination for minute particles of metal suspended in the oil, examination of the engine oil suction screen for presence of metal particles and the inspection of the external full flow oil filter for metal particles by cutting it open so that the pleated element can be unfolded and examined. If ferrous metal contaminants are detected during the above inspections, the camshaft lobes and all hydraulic lifters must be inspected for wear or loss of metal. Replace the camshaft and hydraulic lifters found to have such indications.

I have the proper tool to cut the filter open to inspect the filter media for ferrous metal.

However I am wondering if the regulations allow to me to make that inspection or not. Oil changes are performed every 50 hours or sooner. I'm thinking that I may have to have an oil filter cut open every 100 hours by an AME to be legal.

What do you guys think?

[Hedley]

IMHO change the oil, cut open the filter, make the entries in the logs.

[cgartly]

How does this look for a log entry:

November 2, 2010 C-XXXX CESSNA 172N S/N 172-XXXXX TT - XXXX.X
SMOH - XXX.X
1. ENGINE OIL CHANGED, 6 QUARTS OF AEROSHELL 15W50 ADDED, C/W AD 80-04-03R2
2. ENGINE OIL FILTER CHANGED, OLD FILTER INSPECTED, NO CONTAMINANTS FOUND, NEW FILTER P/N
CH48103-1 INSTALLED
3. AIRCRAFT GROUND RUN AND LEAK CHECKED C/W SATISFACTORY

THE MAINTENANCE DESCRIBED ABOVE HAS BEEN PERFORMED IAW CARS PART VI STANDARD 625
APPENDIX A - ELEMENTARY WORK

With a date and signature?

[John Bull]

You are not changing your engine oil. You are signing out an Airworthiness Directive as completed. Don't confuse the two.

If you can find that under elementary tasks fill your boots.

[Cranium]

CAR 625 appendix A - information notes.

[i](ii) Tasks referred to in (29) above are elementary work when performed out of phase, but require a maintenance release when done as part of a scheduled maintenance check.[/i]

You can do the check on your oil change as (29) included checks required by A/Ds, as long as an AME signs it out on the next scheduled inspection (your 100 hour inspection).

I don't know how much you're flying, but if an AME isn't doing an inspection at least every 100 hours / annually (possibly every 50), you're probably not legal anyway.

[Heliian]

Please do not use the term "maintenance", it's elemetary work and servicing. If it's not on the list, you can't do it. Nor does it require a maintenance release and since you don't hold any type of maint. signing authority, it's illegal if you put a release on it. You can just write your entry saying that you checked an a.d. that's out of phase but here's the kicker, since you have to use tools to comply with that particular A.D., it requires an engineer. Please read the following link regarding elementary work in it's entirety:

http://www.tc.gc.ca/eng/civilaviation/r ... a-2458.htm

I'm assuming you have a regular C of A.

Cheers,

I

[Hedley]

if an AME isn't doing an inspection at least every 100 hours / annually (possibly every 50), you're probably not legal anyway

Not on a privately-registered aircraft. All it needs is an annual inspection. You're probably thinking commercially-registered.

[hangarline]

John Bull had it right. You are not signing for an oil change, you are signing the compliance with an AD. That requires a maintenance release. And in the case of that particular AD, every 50 hours for the addition of the additive and every 100 hours for the inspection of the filter.

[Hedley]

Assuming that the private owner flies less than 100 hours a year, and uses either Aeroshell 15w50 or 100Wplus, both of which have the LW16072 (or equivalent) additive ...

If the owner changes the oil between annual inspections, and cuts the filter open, makes the above logbook entry, then at his annual inspection has his AME sign off the AD (by inspecting the cut-open filters) is he in contravention of any CAR?

How would Enforcement allege that the AD was not being compiled with, if his AME inspects his cut-open oil filters at less than 100 hour invervals?

[Heliian]

The AD has to be complied with at every filtre change. 50hrs is what the manufacturer states for oil change intervals, if you don't want to have the maintenance done then you can register it in the owner maint cat. or amateur built. I would assume that most people don't bother with any maintenance until they have to do an annual, I heard of some owners who don't even bother with that or have a current license. Since there is no more enforcement, you can do whatever you want really, the only time you'll be asked to provide tech records or even a license is when you crash and TSB comes out to investigate. The other downside is that insurance companies will try to find any little technicality to not pay out a claim.

Now if you were really keen, you could actually apply for an Alternate Means Of Compliance and you could most likely be in compliance if you had an AMO sign it out every 100hrs or Annual.

[cgartly]

Its not that I don't want to have the maintenance done, I just enjoy putting a bit of elbow grease into my pride and joy and want to become as familiar with my aircraft as possible. I did the first oil change with the AMO we use for maintenance and have done others since on my own. I did not previously have the proper tool to cut the filter open so I have always had our AMO cut the filter open and inspect it for me, after the verbal OK from them I have made the above log book entry. I have not however had the AMO sign off that they inspected the filter. They never charged or invoiced me to do the filter inspection.

I recently purchased the tool to cut open the filter myself for the next oil change and that is when it occurred to me to check into whether or not I had the authority to do so.

Our aircraft is privately owned and flies about 125-150 hours per year so far.

The Cessna POH actually states that on aircraft with an oil filter that oil change intervals can be extended to 100 hours after the first oil change. I do not have any desire to do this, we change the oil every 50 hours and may start changing even sooner. I don't see why anyone would extend the interval as the lycoming additive that you must add no matter what oil you have been using by extending the service interval is about $30 per bottle. It just doesn't make sense.

In some ways I think the way 29 (i) is written would allow me to do the filter inspection as I am not disassembling anything, I am cutting open a filter. You do not need visual aids to inspect the filter. To disassemble implies that you could reassemble, you can't reassemble a filter that is cut open. The only disassembly is the removal of the filter which is allowed under elementary maintenance. It also states inspection "required" by an AD. The AD does not specify who must do the inspection, although I know some AD's specify that holder's of a pilot's certificate can and by that omission probably means an A&P or AME needs to.

I suppose it is difficult to write regulations that apply to every situation or AD. If you read it word for word you could probably argue that I am not permitted to safety wire the oil filter because it does not specifically say I can.

[Hedley]

The AD has to be complied with at every filtre change

re-read my above posting.

OP: Please don't extend your oil change intervals to 100 hours or 1 year to please the mechanics here. That's not good for your engine. Please continue to change your oil at 50 hours or 6 months, whichever comes first. Cut open the filter, and inspect it yourself. Invest in a tupperware container and save the filter so that your AME can inspect it at the annual and sign off the AD. As long as you don't fly more than 100 hours per year, you are in strict compliance with the AD.

[Heliian]

This is definitely not clear cut either way. That's one of the problems with older AD's and SB's, they were pretty vague and left a lot to interpretation. Nowadays, the manufacturers have to be more specific in regards to who can do it and when it's req'd. Some manufacturers have now released 50 page documents on metal found and what to do about it. Not the case here though. I don't think you'll be doing anything wrong by signing the elementary task and stating that you looked at the filtre. I've only ever been in the commercial/helicopter side and we have to abide by every little technicality whether warranted or not.

Whatever you do, remember you are not signing a maintenance release and don't need a statement. Just write in the log:
--
Nov.4/2010 @ 1752.3hrs ACTT
50hr oil change c/o, Oil replaced with Fancyshell 15W50 and filter p/n #### replaced. filtre insp. c/o iaw AD-80-04-03R2 pt.b(2) no defects found.

Then add your signature and pilots license number, that's it.

Some people add references to the a/f or engine manual but that is usually assumed and accepted by TC if you don't.

[hangarline]

OK, go back and read the AD again. It states that at every oil change you must add a six ounce can of LW16702 and inspect the filter for contaminants. Untill you can obtain an alternate means of compliance from TC, then you are not complying with the AD by not having a maintenance release for this work. I know it sucks but insurance companies can have a nasty way of finding loopholes to not pay a claim to you for any reason, so having an invalid CofA is too easy for them. Hedly, it does no good to save the filter media for another 50 hours and have it inspected at the annual inspection to satisfy the owner. The idea is to inspect the filter and determine if there are contaminants present that will damage the engine if continued in service. If somebody brought me a filter that was 6 months and 50 hours old and asked me to sign the AD for them, I would say no. To the OP, just have your AME sign the maintenance release when it is due and pay for it. You can find plenty of other ways to put in "a little elbow grease" on your "pride and joy" and still remain legal.

[Big Pistons Forever]

First off the bottom line: The filter inspection is required by an AD and you as a non AME can not sign off AD's

However I think you could look at this from two different points of view.

The first one concerns whether in fact you have the knowledge to fully read the filter entrails. Some signs of engine distress can be rather subtle. Are you able to correctly install and lockwire the filter ? An overtorqued or improperly lockwired filter can fail in flight which will invaraibly lead to the total loss of engien oil, not good. Finally with the lid off and the engine exposed any good AME will visually inspect the rest of the engine compartment and posibly pick up incipient or actual problems. The above argues for AME involvement in every oil change.

The contrary view is changing the oil and filter is not very complicated which is why it is permitted under the elementary maintainance provisions and any reasonably intellegent person should be able to figure out when there is oil filter debris that requires a look at by an expert. If you are comfortable with the later than the AD permits up to 100 hrs between oil changes on engines fitted with full flow oil filters. The easiest way to stay legal is to go ahead and change the oil at 50 hrs , cut open the filter and if you find it is clean go on your merry way with no entry in your log book. When you hit a 100 hours change the oil again and get an AME to inspect the filter and sign out compliance with the AD. One of the purposes of the journey log is to be a usefull snap shot of what the status of the aircraft is and to alert pilots to any problems. This is important when many different pilots fly the aircraft, however if you are the owner and the only pilot then you know the status of the machine so there is no practical advantage to putting more than the legally required minimum entries. It is also important to know that TC use the JL to prove regulatory compliance. If you make an entry that TC deems you were not qualified to make, like signing off an AD which is what you are proposing, than you are opening a can of worms for a TC fishing expedition that you are probably not going to enjoy. You do not want anything written in the JL that can be used against you by TC and the insurance company.

[iflyforpie]

This is what I would do as well. Change own oil at 50, check filter, have an AME do it at 100 and sign out the AD.

Just be sure that you don't go over 100 hours because as an AD, you cannot extend it.


I also echo the statements of having an experienced AME 'read' the filter debris. Ferrous filings are a no brainer, but I've seen guys get overly concerned over carbon blow-by (it hardens and magnetizes, squish it with a flat screw driver to identify it) and seen people miss non-magnetic brass or babbit that signals bearing failure.

[ourkid2000]

Excellent post Big Pistons Forever!

[Heliian]

Does the AD require disassembly or visual aids? That is the question.

From the elementary work schedule:

29) repetitive visual inspections or operational checks (including inspections and tests required by airworthiness directives) not involving disassembly or the use of visual aids, performed out of phase with the aircraft’s scheduled check cycle at intervals of less than 100 hours air time, provided the tasks are also included in the most frequent scheduled maintenance check.

[Cranium]

It's a grey area:

Here's an alternate means of compliance that shows which oils have (or are equivalent to) the Lycoming oil additive:
http://rgl.faa.gov/Regulatory_and_Guida ... -00-22.pdf

Here's part of the AD:

[i]b. To prevent excessive wear and oil system contamination associated with hydraulic lifters spalling on O-320-H, and O-360-E, LO-360-E, TO-360-E and LTO-360-E series engines, accomplish the following:

1. At the next engine oil change but no later than 50 hours in service after the effective date of this AD, and at each subsequent oil change or 50-hour interval, whichever occurs earlier, add one 6-ounce can of Lycoming P/N LW-16702 oil additive in accordance with Lycoming Service Bulletin No. 446B.

2. Within the next 50 hours in service after the effective date of this AD and at every subsequent oil change thereafter, not to exceed 100-hour intervals, inspect lubrication system for metal contaminants. Inspection of the lubrication system consists of visual examination for minute particles of metal suspended in the oil, examination of the engine oil suction screen for presence of metal particles and the inspection of the external full flow oil filter for metal particles by cutting it open so that the pleated element can be unfolded and examined. If ferrous metal contaminants are detected during the above inspections, the camshaft lobes and all hydraulic lifters must be inspected for wear or loss of metal. Replace the camshaft and hydraulic lifters found to have such indications.[/i]

So you either have to change your oil every 50 hours or add the additive in between oil changes.

As for disassembly, here's part of 625 appendix A:
[i](7) cleaning or changing of fuel, oil, and air filters, on small privately operated aircraft;
(amended 2004/03/01; previous version)

(8) draining and replenishing engine oil, on small privately operated aircraft;
(amended 2004/03/01; previous version)

(29) repetitive visual inspections or operational checks (including inspections and tests required by airworthiness directives) not involving disassembly or the use of visual aids, performed out of phase with the aircraft’s scheduled check cycle at intervals of less than 100 hours air time, provided the tasks are also included in the most frequent scheduled maintenance check.
(amended 2004/03/01; previous version)

(ii) Tasks referred to in (29) above are elementary work when performed out of phase, but require a maintenance release when done as part of a scheduled maintenance check.
(amended 2004/03/01; no previous version)[/i]


You are covered (7) and (8) for disassembly, but (29) is the kicker. This only covers out of phase tasks. I doubt Transport considers an oil change as an out-of-phase task. I'm sure this was intended as a way for private owners to get out of (for example) requiring (and paying) an AME to perform this:
http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/ ... -17-04.htm

[Big Pistons Forever]

My guess is cutting open the filter, would count as "disassembly" as it requires a special tool, thus it would not be covered under elementary maintainance. It is a bit of a grey area.

Pie, what do you think ?

[cgartly]

Ensuring that I don't go over 100 hours is easy as there is a seat rail AD that has to be complied with every 100 hours as well. I keep very close track of times and never go over any. It is a partnership plane so there are 4 people total including myself flying it.

Our engine is about 130 hrs SMOH and so far on every change has had some brass in the filter media, so far my AME has said that it is normal break in. The overhaul was a field overhaul stateside prior to us purchasing the plane. The same engine however was field overhauled by the same A&P/IA twice previous to the current overhaul and made TBO each time. If there is such a thing I think it was a higher quality field overhaul. Logbook entry states the following:

"Eng disassembled & cleaned alm. parts zyglo insp steel parts magnaglo insp. all parts visual insp + dimensional ck'd cleaning & inspection accomplished by Ly-con rebuilding visalia, ca w/o xxx see 8130 forms. crankshaft assembled, balanced & s/b 505b c/w by lycon see 8130 form. Crankcase repaired - overhauled by divco inc. w/o xxx see 8130 form installed following new parts: main + rod bearings, rod bolts & nuts, camshaft, cam gear bolts, nut-oil ump drive shaft, key-oil pump drive gear, roll pin - tac drive shaft, oil pressure relief ball & spring, lifters, 4 ea 05k21119 lyc. factory new cylinder kits (includes valves, pistons, rings & piston pins), rocker arms, rocker arm seats, eng reassembled with new seals & gaskets iaw Lyc 76 series o/h manual, overhaul & install magnetos, install new ign harness, new spark plugs, overhaul & install carb, overhual & install starter & alternation, vac. pump reinstalled as removed, repair eng baffles as needed & reinstall, replace carb ht. box brg's & shaft, insp exh system & reinstall as removed eng installed cessna 172 nxxxx install new alt belt, new starter ring gear, prop reinstalled, eng ground run & ck'd for leaks, adjust oil pressure & idle rpm & mixture ad 79-10-3r2 eng mounting bolts c/w by torque ad 98-02-08 crankshaft bore c/w s/b505b by lycon ad 02-12-07 oil filter converter plate c/w new gasket installed iaw lyc. service instruction no 1453a ad 05-12-06 box mag impulse c/w by insp. ad 80-4-3 c/w oil additve lw16702 added eng released for test flight only."

Hopefully my AME is correct in stating the brass is part of the break in.

Thanks for all of your opinions, it does seem to be a bit grey.

[c170b53]

I didn't think that an import was possible with a field overhaul. Wrong again I guess.

[cgartly]

I didn't think that an import was possible with a field overhaul. Wrong again I guess.

It wasn't a problem because the log entry above was satisfactory and were supported by 8130-3's, it is a pretty big stack of 8130's!

It may also be different for a private vs commercial import, I'm not sure.

[iflyforpie]

My guess is cutting open the filter, would count as "disassembly" as it requires a special tool, thus it would not be covered under elementary maintainance. It is a bit of a grey area.

Pie, what do you think ?

(29) repetitive visual inspections or operational checks (including inspections and tests required by airworthiness directives) not involving disassembly or the use of visual aids, performed out of phase with the aircraft’s scheduled check cycle at intervals of less than 100 hours air time, provided the tasks are also included in the most frequent scheduled maintenance check.

It's not a grey area. It doesn't say 'special tools', it effectively says 'any tools or visual aids'. If disassembly is required (regardless of whether the disassembly itself is elementary work), then you can't do it.

This Elementary Task was introduced primarily for repetitive visual inspections of helicopter tail rotors by pilots. Note also that this particular AD is 100 hours air time, not 'less than 100 hours'.

Like you and I said before, it's okay to effectively do the check at 50 hours for the warm and fuzzy feeling, but an AME must do it at 100.

[iflyforpie]

You are covered (7) and (8) for disassembly, but (29) is the kicker. This only covers out of phase tasks. I doubt Transport considers an oil change as an out-of-phase task. I'm sure this was intended as a way for private owners to get out of (for example) requiring (and paying) an AME to perform this:
http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/ ... -17-04.htm

Adding fluids (ie, the additive) only constitutes 'servicing' rather than 'elementary work' I believe...