Maintenance Responsibilities as a Commercial Pilot
Title 14 CFR 91.405 Designated the “owner and operator” as being responsible for the maintenance of an airplane and ensuring it is in airworthy and legal status to fly.
The caveat here is that although you may not own any of the airplanes you are flying as a commercial pilot, you certainly are the pilot flying them, making you the operator.
As the operator, you have the same if not greater responsibility to ensure the aircraft you are flying is in fact airworthy. We’ll go over a few ways below for you of how you can most easily and thoroughly ensure an aircraft is indeed airworthy.
What needs doing…
- Thorough Preflight
- Checking required documents
- Checking ADs
- Checking Maintenance Logs for Inspections
- Ensuring Inoperative equipment is properly documented
Making your determination
Determining airworthiness first starts with a thorough preflight and getting familiar with the aircraft and what equipment is installed on it. Just because an aircraft has passed all its required inspections does not make it legal to fly. If you detect something that is not as it should be on a preflight (such as the landing light being burned out) that just in itself would render the airplane un-airworthy. Despite the landing light not being a required piece of equipment for Day VFR flight, if it is not functioning, then the aircraft is not as the manufacturer intended it to be. You can still fly the airplane with a burned out landing light, but there are a few steps to take first. Let’s continue with the rest of our steps and deal with the landing light at the end.
Next I would make a note of any equipment installed on the airplane that did not come with it (i.e., newer radios, transponder, or maybe a Garmin 430 GPS unit, etc.), as well as note the serial number on the airplane on the data plate (generally located somewhere on the left tail section of the plane). Per 14 CFR 45.
The reason for noting the serial number and any new equipment is we need to search for ADs (airworthiness directives). Not only do we search for ADs on the specific aircraft by serial number, but we also have to search for ADs on any additional equipment that has been installed over the years. You won’t find ADs that apply to a Garmin 430 GPS unit listed with all of the other ADs for that serial number airplane since the FAA website has no way of knowing what “additional” equipment people have installed on that airplane over the years.
While you are doing your walk-around on the airplane, you also want to make sure you have your required documents physically on board the aircraft.
- Registration (that is still valid)
- Radio License (if flying internationally)
- Operating Handbook (POH or AFM depending on how old your airplane is)
- Weight and Balance information
If any of the above are missing, you’re going to need to find them or you can’t fly.
So now we search for ADs that apply to our aircraft and its “appliances”. Once we pull up the inevitable long list of ADs we should either save it to an EFB (electronic flight bag / tablet), or print it out so we can make some notes on it. Generally, you will find ADs that apply to your serial number airplane and appliances, and some that do not.
At this point, you will have at least a few ADs that apply to your airplane and you need to now verify that they have been complied with. If the last IA that did the annual inspection on the plane was a nice guy, you’ll have a full itemized list of all of the ADs that apply to the airplane and the appliances in the maintenance logbooks. You should then find where he indicated which ADs applied or did not apply and when they were last complied with.
You can then reference the applicable logbook (airframe, powerplant, etc.) to see the mechanic’s signature and AD number complied with, and the method of how they complied with it (now you get a nice picture of what has been going on with your airplane over the years). After you have verified no new ADs have become due since the last annual and all applicable ADs have been complied with, you can then move on to the required inspections.
Any GA airplane will need at minimum:
- Annual Inspection (12 months)
- Transponder Cert (24 Months, or part of the Pitot Static Cert if you get the IFR cert done on the plane)
- ELT tested (12 months)
- 100hr (if used for hire, i.e. flight instruction)
- Pitot Static (24 Months IFR)
- VOR (30 day IFR)
Once you are satisfied the airplane has all it’s required inspections, you can now move onto inoperative equipment.
Let’s assume the only thing not functioning as intended to on this airplane was the landing light. Since we intend to only fly this airplane today under day VFR, let’s see if we need it or not.
First, is it required by the regulations (91.205)?
If not, then ask is it required by the manufacturer? You will find this information most likely in the POH weight and balance section. Next to each piece of equipment, there will be its weight, arm (or moment), and often times an “R” or an “O” (required or optional). The FAA says even if it’s not required by 91.205, if the manufacturer requires you have it, then you gotta have it. Note: people often confuse that weight and balance list as a “MEL” list or minimum equipment list. Little airplanes like we fly generally do not have true MELs. A true “MEL” is an FAA approved document for a specific aircraft of what can and cannot be broken, and what steps must be taken if something is broken. Here is an example of a true MEL for a 76 seat Regional Jet flown by American Eagle. It is unlikely you’ll find any documents that look like this applying to your 1975 Cessna.
Lastly, since we could not find anywhere in the weight and balance list or in the POH where the manufacturer says that we have to have a working landing light, the only other way we could have to have it operating is if it was required to be operating for day VFR flight by an AD.
Since we just checked the ADs and did not notice any that said “landing light must be bright and working” or “all exterior light must be bright and shiny”, then we can safely say having it operational is not required by an AD. Now that we have checked the three means of which it could be required to be operating, we can safely say it is not required for this day VFR flight. Yet we still have just a few more steps before we can legally go fly the airplane.
To comply with 91.213, we will need to either have the inoperable equipment removed, or deactivated and placarded. We as pilots could go ahead and make a little “INOP” sticker to place over the landing light switch, we could even pull the circuit breaker and put a clamp or zip tie on it so that it could not be pushed in to supply power to the landing light circuit.
What we can’t do, is sign the log book stating the inoperative equipment has been removed, or placarded and deactivated in accordance with bla bla bla service manual and the airplane is airworthy for flight. This is where we will need an A&P mechanic to finish up the rest of the work for us. Once the mechanic has finished making the maintenance log entry and ensuring the equipment (landing light in this case) is placarded and deactivated appropriately, then you will finally be good to fly!
Now that may seem like a ridiculous amount of work to do every time before you go fly, and you’d be correct to say most pilots do not go through all of those steps each time prior to flight. However you are legally required to do all of this, and once you have done it fully one time for a particular airplane, it will be much easier and quicker for you the next time when you go to fly it when you are simply searching to ensure nothing new has been published as it relates to that airplane and it’s appliances.
In fact, ADs are only published once every two weeks, so you could potentially skip everything except the thorough preflight and ensure required documents are on board if you just flew the same airplane the day before.
Ultimately, we expect commercial pilots to be the epitome of a professional pilot, and conduct themselves accordingly. While the standards should be just as high for private pilots, the reality is what you get away with as a private pilot will not fly (pun intended) as a commercial pilot. Take pride in your new commercial certificate that you will have here very soon!
- POH / AFM
Weight and Balance (updated per 337’s)
Radio / FCC (if app)
Required Inspections (annual, etc)
Additional Equipment Installed Listed in logs (337)
Yellow tags in logs or folder
AD’s on Airframe
AD’s on Engine
AD’s on Prop
AD’s on extra equipment
All extra pages in AFM / POH required to be there from extra equipment