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Who gets to legally deactivate/placard inoperative equipment?

Asked by: 4818 views Commercial Pilot, FAA Regulations

14 CFR 91.205 (d)(3)(ii) reads: "The inoperative instruments and equipment are deactivated and placarded "Inoperative." If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with part 43..."

14 CFR 43 allows certain preventive maintenance to be done by the pilot. Other types of maintenance cannot be done by the pilot. 

Presumably, if the deactivation and placarding does not involve maintenance as defined in any section of Part 43, a PIC who is not an owner/operator can do as much to fly. Does this also mean that the same PIC can legally deactivate and placard inoperative equipment, provided that it constitutes preventive maintenance? 

I was under the impression that in any case, only the owner/operator can legally deactivate and placard inoperative equipment. 

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1 Answers



  1. KDS on Feb 23, 2020

    That is an excellent question and I’ve seen it debated by people who are more knowledgeable in that area than I am. The best guidance I can find is in FAA Order 8900.1, Volume 4, Chapter 4, Section 2, MEL Operations for Parts 91, 137, and 142 operations, Paragraph 4-650. I’ve included that section below:

    E. Placarding. If an operator elects to operate without an MEL, any inoperative item must be either removed or deactivated and placarded in accordance with § 91.213(d)(3).
    1) Removal. Removal of any items that are not preventative maintenance requires an appropriately certificated maintenance person to:
    · Properly record the removal of the item in maintenance records in accordance with part 43, § 43.9;
    · Properly adjust the aircraft’s Weight and Balance (W&B) information and equipment list in accordance with § 43.7;
    · Placard the cockpit controls, as appropriate;
    · Complete and submit an FAA Form 337; and
    · Approve the aircraft for return to service, as appropriate.
    2) Deactivation. A certificated pilot may accomplish deactivation involving routine pilot tasks, such as turning off a system. These actions fall under the definition of preventive maintenance in part 43 subpart A. In all cases, a person authorized to approve the aircraft for return to service under § 43.7 must make the maintenance record entry required by § 43.9. No person may operate the aircraft without the entry required by § 43.9.
    a) Qualified maintenance personnel should accomplish procedures requiring specialized knowledge or skill, or requiring the use of tools or test equipment. However, the satisfactory accomplishment of all maintenance procedures, regardless of who performs them, is the responsibility of the operator.
    b) If the deactivation procedures do not fall under preventive maintenance, an appropriately certificated maintenance person must accomplish the deactivation.

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