Owner Performed Maintenance - Lubrication

True or False, I can change the oil in my own aircraft myself?

We're often asked this question, so we asked Steve Sunseri, the General Aviation Manager for ExxonMobil Aviation Lubricants, for his thoughts.

According to Steve, the FARs provide the guiding light. He also provided us with some specific FAR references pertaining to owner performed maintenance...and a hyperlink to the FARs so you can check them out as well.

Part 91, according to Steve, might send you astray with this regulation:

Part 91
91.403(b): No Person may perform maintenance, preventive maintenance or alterations on an aircraft other than as prescribed in this subpart or other applicable regulations, including Part 43 of this chapter.

But when you dig a little deeper, you find:

Part 43
43.3(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.

So, as an aircraft owner or operator, you CAN perform Preventive Maintenance. Peel the onion back a bit more and you find that Appendix A to Part 43 provides a list of 32 different maintenance activities classified as preventive maintenance. The following pertain to lubrication:

Appendix A to Part 43
(c) Preventive Maintenance (involving lubricants)
(3) Servicing landing gear shock struts by adding oil, air, or both.
(4) Servicing landing gear wheel bearings, such as cleaning or greasing.
(6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings and fairings.
(8) Replenishing hydraulic fluid in the hydraulic reservoir.


Now, you might stop reading and get to work, but, like the saying goes, it's not over 'til the paperwork's done. So keep reading:

43.9(a) Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
(1) A description of work performed.
(2) The date of the completion of the work performed.
(3) The name of the person performing the work....
(4) If the work performed on the aircraft airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and the kind of certificate held by the person approving the work.

OK, so the work also has to be approved for return to service. Who can do that?

43.7(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 43.3(g).

So Steve's answer is: True

FARs allow aircraft owners/operators to perform their own preventive maintenance, including oil changes, using a three-step process:

1. Perform preventive maintenance
   
2. Approve aircraft for Return to Service
   
3. Document in maintenance records

If you have more questions for Steve Sunseri, please feel free to contact him directly at:

Steve Sunseri
General Aviation Manager
Tel: 804-378-0002
Fax: 804-378-1493
email:stephen.m.sunseri@exxonmobil.com

Fly safely!