When it comes to Continuous Airworthiness Maintenance Programs (CAMP) under Parts 135 and 91K, one of the most common questions operators ask is: Can flightcrews legally perform maintenance under the air carrier’s certificate?
It’s an important question, and one that carries real operational and compliance implications. Misunderstanding the answer can lead to non-compliant practices, audit findings, or even safety risks. Fortunately, the FAA provides clear guidance on where the boundaries lie, outlined in FAA Order 8900.1 Vol. 20 and regulations such as §43.3(f) and §135.437(a).
The FAA does not prohibit flightcrews from performing maintenance under an air carrier’s certificate. However, that permission exists only within a narrow legal and procedural framework.
Two key regulations define this pathway: §43.3(f) authorizes pilots to perform maintenance under specific conditions, and §135.437(a) allows maintenance to be performed under the air carrier’s certificate, provided it follows the procedures outlined in the carrier’s approved manual.
When flightcrews conduct maintenance, it must always occur under the direction of the air carrier’s manual and within the limits of the CAMP authorization. Flight Standards recognizes that some carriers include procedures allowing pilots to perform certain minor maintenance tasks, but these must be carefully documented and controlled.
The FAA allows limited, well-defined maintenance actions that fall within a flightcrew’s normal scope of operations. Examples include replacing burned-out indicator-lamp bulbs, operating engines or auxiliary power units as directed to verify indications, or pulling circuit breakers and positioning switches under maintenance supervision per MEL or manual procedures.
Other acceptable actions include applying circuit-breaker collars or “inoperative” stickers as required by MEL, checking fluid quantities or system pressures as part of normal preflight duties, and turning off galley or lavatory water-supply valves.
These activities are permitted because they do not require tools, specialized mechanical knowledge, or physical access beyond a crew member’s usual duties, and because they are performed under the direction of a certificated mechanic or maintenance controller.
The FAA is equally clear about what flightcrews cannot do under a CAMP:
Flightcrews also cannot sign the airworthiness release required under §135.443. In addition, before any authority to perform limited maintenance is granted, flightcrews must meet competency and training standards established in the operator’s CAMP.
For operators, understanding these boundaries is essential to maintaining compliance and avoiding unnecessary audit exposure. Clearly defining when and how flightcrews may perform maintenance helps prevent regulatory violations and ensures all work is traceable through proper documentation under §43.9(b).
Incorporating these procedures directly into the CAMP not only strengthens oversight but also demonstrates a proactive compliance posture. Training programs should explicitly outline competency requirements for any flightcrew member authorized to perform maintenance, ensuring consistency and accountability across the organization.
Sky Safety Solutions works with operators to ensure their maintenance delegation procedures and CAMP language align with FAA expectations. Our team reviews manuals and CAMP provisions for compliance accuracy, designs training modules that meet Flight Standards criteria, and conducts audit-readiness reviews to confirm that flightcrew-performed maintenance is properly documented and verifiable.
Sky Safety Solutions helps operators interpret FAA guidance accurately and implement procedures that keep maintenance tasks compliant, efficient, and verifiable.
Need help ensuring your CAMP covers flightcrew-performed maintenance correctly? Contact Sky Safety Solutions for expert guidance or schedule a compliance consultation with our FAA documentation specialists.