June 2005-
If you had to pick the single most misunderstood aspect of aircraft ownership, logbooks would certainly be at or near the top of the list. All owners know they have to have them, but few understand their responsibilities as it pertains to maintaining those records and how those records may affect the operation of your aircraft.
If you want some interesting reading, look up AC-43-9C. This document, titled “Maintenance Records,” offers some insights as to the FAA’s position on record keeping. The following are paragraphs four and five:
4. DISCUSSION. The Code of Federal Regulations state that a U.S. standard airworthiness certificate is effective until it is surrendered, suspended, revoked, or a termination date is otherwise established by the Administrator. In addition to those terms, a U.S. standard airworthiness certificate is effective only as long as the maintenance, preventive maintenance, and alterations are performed in accordance with parts 43 and 91, and the aircraft are registered in the United States. These terms and conditions are further restated, in block 6, on the front of FAA Form 8100-2, Standard Airworthiness Certificate. Qualified persons, who perform the maintenance, preventive maintenance and alterations, shall make a record entry of this accomplishment, thus maintaining the validity of the certificate of airworthiness. Adequate aircraft records provide tangible evidence that the aircraft complies with the appropriate airworthiness requirements. In accordance with the terms and conditions listed in block 6 of the Standard Airworthiness Certificate, insufficient or non-existent aircraft records may render that standard airworthiness certificate invalid.
5. MAINTENANCE RECORD REQUIREMENTS. a. Responsibilities. 14 CFR part 91, section 91.417 states that an aircraft owner/operator shall keep and maintain aircraft maintenance records. 14 CFR part 43, sections 43.9 and 43.11 state that maintenance personnel, however, are required to make the record entries. b. Maintenance Records That Are to Be Retained. Section 91.405 requires each owner or operator to ensure that maintenance personnel make appropriate entries in the maintenance records to indicate that the aircraft has been approved for return to service. Section 91.417(a) sets forth the content requirements and retention requirements for maintenance records. Maintenance records may be kept in any format that provides record continuity; includes required contents; lends itself to the addition of new entries; provides for signature entry; and, is intelligible. Section 91.417(b) requires records of maintenance, alterations, and required or approved inspections to be retained until the work is repeated, superseded by other work, or for one year. It also requires the records, specified in section 91.417(a)(2), to be retained and transferred with the aircraft at the time of sale.
This excerpt makes perfectly clear that the owner/operator is responsible for ensuring the logbook entries have been made and accurately reflect the work performed on the aircraft. So exactly how does that affect operation of the aircraft?
Well, consider the following scenario: you go to pick your aircraft up from the maintenance shop after an annual and you and the mechanic decide to take it up for a test hop. The engine quits on takeoff because he failed to reattach the fuel line after cleaning a fuel screen. You land, run off the runway and damage the aircraft.
You had not bothered to review the log entry to verify that it had been done because the plan was to fly the test hop, address any remaining squawks and settle up the bill and the paperwork.
Guess what? Not only are you in violation of the regulations requiring you to maintain the paperwork, but you also just flew a technically unairworthy aircraft, which if nothing else will get you a suspension of your flying privileges for reckless and unsafe operation, but your insurance company is going to laugh at you because every insurance policy clearly states that the aircraft must be in airworthy condition, and without the logbook entries, the airworthiness certificate is invalid, thus letting the insurance company off the hook.
Think I’m making it up? I’ve seen it happen!
Now I’m not suggesting that every aircraft owner run out and get an A&P license; that would be totally impractical. But a detailed working knowledge of aircraft records and how they should be kept is an education every pilot should seek. There are several systems that work well.
Ad-Log™ comes to mind as a good system for tracking maintenance items for an owner-flown aircraft because they send all the applicable ADs to you in the mail as they are issued, based on aircraft serial number and tail number, and installed equipment. Using this system, you no longer rely on the mechanic to search applicable ADs. It also makes you aware of Service Bulletins, mandatory Service Bulletins and Service Letters.
These documents are dry reading but clearly spell out the acceptable methods of compliance for the issue at hand. This is good knowledge for an owner to have if for no other reason than to verify that the mechanic actually did it. The other obvious reason would be to avoid having to pay for the replacement of a component or part that may have only required a visual inspection to remain airworthy.
A perfect example of this is the fuel pumps used on Janitrol and Southwind gas-fired heaters. Now made by Kelly Aerospace, these little goodies are installed in thousands of light twins. There had been a one-time visual inspection AD that has now been changed to a 100-hour inspection.
If any fuel stains are detected, there is a series of things that need to be done. If any of these steps fix the problem, then the unit can remain in service for another 100 hours before it needs to be inspected again. If not, you must replace it. I can tell you from personal experience that they are not cheap.
But logbook records are not limited to airframe and engine. Accessories like constant-speed propellers also get their own logbooks. If your aircraft contains life limited-parts, the time on those parts must be tracked.
The Parker Hannifin vacuum pump on a late model Cessna is a good example. They have a 500-hour life limit. Other things you are required to have are yellow tags for items repaired and returned to service—or better yet, the 8130 form for the repaired component (interestingly, if a new component is put on the aircraft it won’t have a tag).
Another interesting aside is instructions for continuing airworthiness. Batteries come to mind as something everyone has in their aircraft, and all of the current crop of aviation-approved batteries that are on the market today come with Instructions for Continuing Airworthiness. You should get a copy of them and be sure that your mechanic indicates this compliance with the appropriate logbook endorsement.
In your logbook, the mechanic should have completed an AD list, listing all the ADs applicable to the aircraft and indicating whether or not it applies to the particular aircraft in question and method and date of compliance and when it is due again if applicable.
You are also required to keep a record of all the STC’d components on the aircraft. They require a form 337 to be filed when installed, and it is the owners’ responsibility to verify that it has been done and a copy is in the aircraft records. For work performed before you purchased the aircraft, you can get copies from the FAA of all the 337s on file for your aircraft for a nominal charge.
Personally, I create a three-ring binder for each airplane I own and use a set of divider tabs from the office supply store. I generate a text copy of every applicable AD and SB and put it in one section, 337s and STC paperwork in another and 8130s and tags in yet another.
The AD compliance list for the engine, airframe and accessories goes in with the text copies of the ADs. You can get them from the FAA for free from their website. I subscribe to The Aviation Database™, which you can access at www.airesearch.com. It costs me about $200 a year. I like it because it also gives you access to the manufacturers’ service bulletins and everything else you need to deal with compliance.
Of course, you could probably lay a six-pack on your favorite A&P and get him to run it for you. Every IA is required to have access to a current library of ADs, SBs and service letters.
I also have a section for oil analysis (I do it on all my aircraft) and another section just for work orders. Work orders from a certified repair station are legal documents and can come in handy if you need to recreate a missing logbook or if the FAA or the insurance company has a problem with a log entry at a later date. Don’t throw them away or file them with your tax paperwork!
I maintain a standard airframe log, engine log and propeller log just like most of you do. These are for logbook entries. It is important that the verbiage on the entries is correct or again, you are at risk. An invalid endorsement is as good as no entry at all.
An A&P cannot return an aircraft to service or sign off an annual inspection! He (or she) can, however, sign off a 100-hour inspection. Only an A&P with Inspection Authorization can return an aircraft to service; know the difference. It’s your certificate if you get caught flying an aircraft with an incorrect endorsement in the logs.
Why bother? Other than the obvious reasons and situations I have outlined above, when it comes to selling your aircraft, nothing sells a plane better than a set of logs that no one can dispute. I have now owned 70-some aircraft and I have looked at a lot of logbooks. When I go to sell one of my planes, the logbooks do all the talking.
So while you are stuck in the house next winter looking at unflyable weather out the window, consider sitting down with your aircraft records and putting together a comprehensive package of information that no one can find fault with. The most tangible benefit may come when you decide to move on and sell the airplane. Poor logbooks generally yield lower sale prices, while great logbooks generally yield better sale prices.
Take the extra time to ensure that the logbook endorsements are done correctly, and all of the associated paperwork has been supplied to you. The least this will get you is peace of mind from the knowledge that the records on your aircraft are correct. The benefit of not having to sweat that out if there should ever be an insurance claim or a record review by the local FSDO is worth the effort.
So while you clearly don’t have to be an A&P mechanic, you certainly do need to be both proactive and involved with the record keeping for your aircraft.
Michael Leighton is a 3,400-plus-hour CFII MEI/ATP as well as an A&P mechanic and former FAA Accident Prevention Counselor. He operates an air charter company in South Florida. You can reach him via e-mail at av8tor0414@aol.com.
