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Minimum Equipment Lists (MEL) and Operations With Inoperative Equipment (Part One)

in Flight Manuals and Documents

Minimum Equipment Lists

14 CFR requires that all aircraft instruments and installed equipment be operative prior to each departure. When the FAA adopted the minimum equipment list (MEL) concept for 14 CFR part 91 operations, this allowed operations with inoperative equipment determined to be nonessential for safe flight. At the same time, it allowed part 91 operators, without an MEL, to defer repairs on nonessential equipment within the guidelines of part 91.

The FAA has two acceptable methods of deferring maintenance on small rotorcraft, non-turbine powered airplanes, gliders, or lighter-than-air aircraft operated under part 91. They are the deferral provision of 14 CFR section 91.213(d) and an FAA-approved minimum equipment list (MEL).

The deferral provision of 14 CFR section 91.213(d) is widely used by most pilot/operators. Its popularity is due to simplicity and minimal paperwork. When inoperative equipment is found during preflight or prior to departure, the decision should be to cancel the flight, obtain maintenance prior to flight, or to defer the item or equipment.

Maintenance deferrals are not used for inflight discrepancies. The manufacturer’s AFM/POH procedures are to be used in those situations. The discussion that follows assumes that the pilot wishes to defer maintenance that would ordinarily be required prior to flight.

Using the deferral provision of 14 CFR section 91.213(d), the pilot determines whether the inoperative equipment is required by type design, 14 CFR, or ADs. If the inoperative item is not required, and the aircraft can be safely operated without it, the deferral may be made. The inoperative item shall be deactivated or removed and an INOPERATIVE placard placed near the appropriate switch, control, or indicator. If deactivation or removal involves maintenance (removal always will), it must be accomplished by certificated maintenance personnel and recorded in accordance with 14 CFR part 43.

For example, if the position lights (installed equipment) were discovered to be inoperative prior to a daytime flight, the pilot would follow the requirements of 14 CFR section 91.213(d).

The deactivation may be a process as simple as the pilot positioning a circuit breaker to the OFF position, or as complex as rendering instruments or equipment totally inoperable. Complex maintenance tasks require a certificated and appropriately rated maintenance person to perform the deactivation. In all cases, the item or equipment must be placarded INOPERATIVE.

All small rotorcraft, non-turbine powered airplanes, gliders, or lighter-than-air aircraft operated under 14 CFR part 91 are eligible to use the maintenance deferral provisions of 14 CFR section 91.213(d). However, once an operator requests an MEL, and a Letter of Authorization (LOA) is issued by the FAA, then the use of the MEL becomes mandatory for that aircraft. All maintenance deferrals must be accomplished in accordance with the terms and conditions of the minimum equipment list (MEL) and the operator-generated procedures document.

The use of a minimum equipment list (MEL) for an aircraft operated under 14 CFR part 91 also allows for the deferral of inoperative items or equipment. The primary guidance becomes the FAA-approved MEL issued to that specific operator and N-numbered aircraft.

1 asdf November 20, 2010 at 5:45 pm

I’m not sure I understand what “deactivation” means. In the inoperative position light example, let’s say I don’t have a position light circuit breaker that I can pull (as is the case for most aircraft I’ve flown). Is it possible to deactivate the position light? Does simply keeping the switch in the OFF position constitute deactivation? Else, it seems like a burned out position light would ground a daytime flight, which seems a bit silly.

2 Matt February 7, 2011 at 1:22 am

@asdf You are right to be confused. As it is written in the FARs, a pilot can deactivate the inoperative item as long as it is prescribed in part 43 appendix A (c) as being preventive maintenance. Since pulling a CB or simply switching off the item does not constitute preventive maintenance as outlined, the discovery of a position light inoperative would indeed ground the aircraft. You can, however, replace the bulbs if you have some, but as for just turning them off, not preventive maintenance. You can thank the FAA for that! As they say at the FAA, “We’re not happy until you’re not happy”.

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