On 19-Nov-2005, Mike Spera wrote:

For those who give advice like "just do it", remember, the jury is
forever "out" whenever you yourself do such a thing. At any time, some
A&P or FAA inspector on the ramp may tap YOU on the shoulder and say "I
don't think so" to the very operation you are recommending to others.
Yes, the likelihood of someone KNOWING about some of this stuff may be
quite slim. But, we have all read the horror stories of what happens
when someone is forced to get a "new" mechanic ("hey, nice interior
plastic, where's the paperwork?????"). Remember Jay's wing tip strobe
"adventure".


I think that some common sense is in order here. Remember, the intent of
the regs with respect to maintenance is flight safety, not creating a
"gotcha" situation. The fact is, application of the rules regarding
preventative maintenance (which can be performed by the pilot/owner) leave
quite a bit of room for interpretation. Patch a hole in seat upholstery?
Sure, no problem. Completely recover the seat? It seems like that would be
allowed as "replacing seat parts" but you have to use parts "approved for
the aircraft" whatever that is. On the other hand, one could argue that
recovering a seat is "repairing upholstery" which is allowed without mention
of using approved parts.

My take on repair, painting, or even replacement of simple interior plastic
pieces is that this falls under the category of "repair" of "decorative
furnishings" even if the components in question are involved in cabin
ventilation. My thinking is that such maintenance is far less likely to
impinge upon safety than, say, performing an oil change, which is certainly
allowed.

I would hazard a guess that if some anal retentive FAA examiner wanted to,
he/she could find at least one maintenance violation in just about any
privately owned airplane that is more than a few years old. Here's an
example from our Arrow: It came from the factory equipped with cloth
curtains that could be used by rear seat passengers to shade the sun. They
really don't work very well and are generally a pain in the butt, so we
simply removed them. Now, since they comprise maybe a total of two ounces
of the "official" empty weight and are part of the airplane as certified,
and since there is no mention in the POH that they can be removed if
desired, strictly speaking they have to be there for legal flight. My guess
is that if we ever get a ramp check we will be given a pass on this one.

--
-Elliott Drucker