Questions from the Cockpit: A colorful question

Stan, a private pilot from Alabama, writes: I just got some quotes for painting my plane. Holy Moses. They want more to paint it than it cost me to buy it in the first place! It got me to thinking I should just do it myself. So the question is: Can I? Can anyone paint a plane, or does it have to be some sort of sanctified, certified, federally-approved individual?

I feel your paint pain Stan. The cost of a quality airplane paint job borders on the astronomical. But, in fairness to the paint shops, that’s because the work involved in doing it right borders on the astronomical.

There’s a ton of prep work, the materials are expensive, the job needs to be done in a temperature and humidity-controlled dust-free environment, there are all kinds of environmental laws to deal with, and the work takes lots of time. Lots and lots of time.

But that’s beside the point. Those rattle cans of Rust-Oleum are on sale at Amazon right now. How many cans could it possibly take to paint a GA airplane?

Now, the experimental crowd can, and does, paint their own airplanes — often with mind-blowing results. That, of course, falls under their privileges as the “manufacturers” of their own planes.

But I take it your question is can you and I paint… well, re-paint… a sanctified, certified, federally-approved aircraft?

And that question turns out to be a lot more complicated than you’d think. Buckle up. It’s going to be a bumpy ride.

The good news is that there isn’t an aircraft painting certificate. So that said, we need to ask ourselves: What kind of activity is painting an airplane?

The bummer is that everyone seems to agree that it is a flavor of maintenance, so for the purposes of our discussion today, the key question now becomes: What kind of maintenance is it? That, in turn, will tell us if we can do it on our own, if we can do it with some help, or if we can’t do it at all.

Some claim that painting a plane is a minor alternation, others that it’s a major alternation. In either of these cases, a sanctified, certified, federally-approved mechanic would have to oversee the work and sign off on it.

But then there’s the Appendix. Specifically, 14 CFR § 43, Appendix A. That’s the regulation that spells out — among a great many other things — what an airplane owner can do to her airplane without need for a sanctified, certified, federally-approved mechanic.

And in (c) (9) it says we can refinish the “decorative coating” of the fuselage, wings, tail group surfaces, fairings, and cowlings. Oh, and the balloon basket, too, if so equipped.

Decorative coating is paint, right?

Well…the regs don’t really define that for us. Nor does the advisory circular on preventative maintenance, nor are there any Letters of Interpretation on the subject. Even the FAA publication, “Maintenance Aspects of Owning Your Own Aircraft,” is absolutely moot on the subject.

I did find one FAA document from the Drug Abatement Division that states that anyone doing preventative maintenance — including “refinishing of decorative coating” — is subject to FAA-mandated drug and alcohol testing.

So don’t decorate your plane stoned or drunk.

But it didn’t say if decorative coating is paint either. Just that you can’t sniff paint while applying decorative coating.

Still, I think most of us would agree that, as worded, decorative coating can be nothing but paint. And that re-finishing can be nothing other than repainting. So you are good to go, right?

Not so fast. That part of the Appendix also has a limitation. It says that refinishing can only be done “when disassembly of any primary structure or operating system is not required.” It also bans us from re-decorating balanced control surfaces.

That, I think, is the source of the confusion about what a paint job is or isn’t. If you are dealing with painting balanced control surfaces, it’s not preventative maintenance. If you are taking the ailerons off, it’s not preventive maintenance.

But if you’re doing a simple no-disassembly paint job — and if you hold at least a private pilot certificate (or a sport pilot certificate working on a light sport aircraft) and are the owner or co-owner of the plane — you can start shaking the rattle can.

Of course, that was a joke. Don’t use a rattle can. Aircraft paint is unique, and some maintenance manuals specify the type of paint that has to be used, as well as the techniques that have to be used to apply it.

Now, I should point out that while you and I might be able to slap some paint on our certificated airplanes, that doesn’t mean that Big Jake from Big Jake’s Paint & Autobody can. The preventive maintenance regs are clear that it is only the pilot-owner who is permitted to undertake the work.

Of course, painting an airplane isn’t just about slappin’ on some paint. This isn’t like re-painting your living room.

Because before you paint an airplane, you really want the old paint gone.

First and foremost, if your old paint has exceeded its service life, putting new paint over the top of it is just asking for trouble. It’s not going to stick right.

More importantly, in my mind, is defending what little useful load my bird has. Paint weighs more than you’d think. Boeing is often quoted as saying that paint on an airliner weighs between 600 to 1,200 pounds.

What about GA airplanes? Of course, our fleet varies in size, but I found some data showing a Cessna 182 carries 19 pounds of dry paint into the sky every time it lifts off.

Oh, and the last reason to strip the old paint before putting new paint on is that the old paint might be hiding old repairs and new problems. Yeah, your wing looks fine, but under the old paint it’s 43% Bondo. And the other 57% has corrosion and hairline fatigue cracks hiding under the paint. This is why most paint shops have 10-hours of “body work” as a standard part of the quote.

Now, getting that old paint off is no easy task, and one thing to remember is that it’s not just the FAA that has our paint-faded feathers in their cross hairs. Down the hall in the federal building is the Occupational Safety and Health Administration (OSHA), which has a lot to say about the nasty chemicals needed to remove the old paint before putting on new paint.

But there you have it, Stan: If you think you can do a good job stripping and re-painting without removing any control surfaces, and none are balanced, it’s legal. Personally, I’m skeptical about the odds of successfully accomplishing a quality strip and paint job with the plane fully assembled, but anything is possible.

What might be more realistic, however, is dolling up what you have, rather than starting over.

Clearly within the prevention regs would be some touch-up paint on the hangar rash on the leading edges of the wings, repainting the faded top cowl, or adding some racing stripes. Or skip all of that and paint a sexy pinup babe or hunky stud, depending on what pleases you, on your bird’s nose.

It will distract the eye from the crummy paint, and leave you with more time and money to fly.

To see what is involved in painting a typical general aviation aircraft, check out this video, “How to paint an airplane in 3 minutes.”

William E. Dubois is an aviation writer, commercial pilot, and two-time National Champion Air Racer. He would love a new paint job on Race 53, but decided to spend the money on, you know, actually flying instead.