March 2012
Aircraft maintenance records can be a source of confusion for many aircraft owners and pilots. What information is necessary, what inspections are required, and determining whether an aircraft is in fact airworthy according to the maintenance records is important.
Unfortunately, airworthiness is not limited to the physical condition of the aircraft but in fact is a catchall term that can be used to describe the physical condition of the aircraft as well as the records and whether they indicate an inspection is overdue.
Most all aircraft in the General Aviation fleet are issued a Standard Airworthiness Certificate. This certificate remains valid as long as the aircraft meets its approved type design, is in a condition for safe operation and maintenance, preventive maintenance, and all alterations are performed in accordance with 14 CFR parts 21, 43, and 91.
Practically speaking, this statement will require that to ensure compliance the aircraft records will have to be reviewed on a regular basis and compared to the current time on the aircraft to determine if an inspection is due.
Regulation (specifically, FAR 91.417) requires that each registered owner or operator keep certain records. These records would include “maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft” and each “engine, propeller, rotor, and appliance of an aircraft.”
In addition to these requirements, a listing of AD notes and status applicable to the aircraft, accessories, engine, propeller, and rotors is necessary. In addition to listing what ADs apply and when compliance is required, there should be a list of what ADs don’t apply, and why they don’t. Life-limited parts must be addressed as to what parts are life-limited (if any) and when replacement is due.
The status of the altimeter and transponder, and the ELT battery due date, must be recorded “when the transmitter has been in use for more than one cumulative hour.”
A record of VOR checks must be kept if the aircraft is certified for IFR flight. Equipment listings, weight and balance data, major alteration and repair documents (337 forms) are also required as part of the aircraft records.
Notice that nowhere in the FARs is there mention of “logbooks,” but more appropriately “records”—which now can be digital. These records belong to the aircraft and are NOT the property of a mechanic or aircraft owner, and must be “retained and transferred with the aircraft” when it is sold.
Recording of Data
Required information to be described by the person that actually did the work includes: the date of the inspection and aircraft total time in service; and the signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.
After an inspection, the aircraft records will contain the following statement: “I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.” The type of inspection that was completed must be specified and if the aircraft was found to be unairworthy, the statement will reflect this.
Always read the entire entry. Just because an inspection was accomplished, the aircraft may or may not be airworthy. Progressive inspections have a specific statement, but in all cases, each sign-off must identify the type/phase or appropriate inspection that was accomplished. An authorized person must sign for the work performed (or the inspection performed) using the certificate number, type of certificate and list the total time of the aircraft, engine, propeller, etc.
A description of the progressive inspection program should indicate when inspections are required and can be hourly or calendar intervals, or a combination of both. Familiarize yourself with the program so you can determine if an inspection is due or past due.
As a private pilot doing any type of maintenance work on your own aircraft, a record of that maintenance is required listing the date, time on the aircraft, what was done (i.e., replace landing light bulb, etc.) and your signature and certificate number.
You will be held to the same standards as any other authorized person for the maintenance that was actually performed. Ask yourself the following: Was it done in accordance with accepted procedures? Is the light bulb the correct one for the application? Are there any instructions in the maintenance manual that must be followed, such as how the bulb is attached and what position it is in (some can be reversed 180 degrees); and what type of screws (length and diameter) that hold the retaining ring in place are to be used? Is there a torque valve specified, or is it a standard value?
Practical Matters
Time in service as applied to total time is defined as from the moment that the aircraft leaves the earth until it touches down at the next point of landing. Hobbs, tach time, etc. is an accepted method of keeping time, but this time may not be exactly accurate.
If tach or Hobbs time is not accurate—and very often it is incorrect—then the 100- hour or other inspections may be actually not yet due, or may be overdue. Inspections are expensive, especially if you happen to do them early.
It is somewhat troublesome to keep accurate records, but it may just save enough money to make it worthwhile. Air carriers have recorded actual times for years and now it is done electronically, as every minute in error can combine into a huge expense when multiplied over hundreds of aircraft in a fleet. Pilot time is not the same as aircraft time (time in service). Are you cheating yourself when logging pilot time?
Another interesting fact regarding maintenance records is that an “authorized person” may return an aircraft to service. Technically, the aircraft is actually not returned to service until the aircraft taxis for the purpose of flight. As pilot in command, you have the final authority and responsibility to reject a planned flight if anything is not correct before the aircraft is flown.
For example, let’s say you retrieve an aircraft after its annual inspection is completed and you discover an unusual situation such as the alternator not operating correctly. That aircraft—although it was specified that the inspection was completed and the aircraft was airworthy—isn’t airworthy. It is not legal to depart without the alternator working. This is why you must do a complete preflight before you accept the aircraft.
Events happen during maintenance. Circuit breakers are pulled, fuel is shut off, oil is not added after the oil was drained, landing gear circuit breakers are pulled during maintenance and sometimes are forgotten to be reset. Flight controls rigged in reverse is a severe case that most likely will cause a serious accident. It is up to you as a pilot to check that everything is working properly and be aware of what information was recorded. Some maintenance actions require a test flight and a sign-off by the pilot in the maintenance record that the aircraft is okay for flight (returned to service).
Digging a little further, when you receive the aircraft, have you carefully looked over the records and has all the work that you were billed for actually been done and defined in the records? An abbreviated description of work that is in the record can refer to a maintenance manual, an AD note, or other instruction, but it must be clear as to what the reference is such as “Revision 2,” or which manual, page, paragraph, etc. Everything has to be documented and signed.
Don’t wait for the records or bills to appear days after your flight; do it right—do it when you have all the documents in front of you and the records are complete. Don’t rush the process. Spend some time to understand what was actually done and allow enough time to do a proper preflight, preferably during daylight conditions. You as an aircraft owner are responsible for ensuring that the work that was done (and you paid for!) is in fact recorded properly.
Records Management
When an aircraft is purchased, a recordkeeping system will most likely have been established. It is true that after a period of time some aircraft records can be disposed of, and the FARs in fact do reflect this. FAR 91:417 (b) 1 specifies “the records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.” This requirement is the minimum that must be done, however; in the interest of economy, and ease of determination of the aircraft status in the future, I recommend retaining most all records.
As an example, engines in General Aviation aircraft are operated for many years between overhauls and the case is not usually split during this time. For this reason it is important to keep the engine overhaul records just in the rare case an Airworthiness Directive comes out that addresses an internal engine part. Without the records, you or your mechanic may not be able to determine that an AD applies to your aircraft engine.
Often times an engine overhaul facility (repair station) may only keep their records for two years after the work was done and then dispose of them. If you don’t keep the records, you can put yourself at an extreme disadvantage. Major Alteration forms (Form 337s) are required to be kept along with supporting documentation such as STC data, instructions for continued airworthiness, and flight manual supplement(s), if applicable.
Major repairs can be documented on a work order if it was done by a repair station, otherwise a Form 337 must be used. When a 337 form is executed, a maintenance record entry is required, a copy of the form shall be sent to the FAA, and one copy will be retained by the aircraft owner/operator. When a fuel tank is installed in the passenger compartment of an aircraft, the associated 337 must be kept on board the aircraft.
All records should be kept in an orderly fashion and be easy to read, with all documents readily available to maintenance personnel. Records must be made available to government agencies when requested, but do not have to be carried in the aircraft or presented during a ramp check, for example.
Aircraft mechanics and inspectors often complain about how poorly maintained aircraft records are. Messy or incomplete records increase the cost of an annual inspection and also increase the chances that either a mechanic or a pilot will miss some important information, such as an AD note.
AD note listings are frequently in poor condition with information missing such as what was done to comply with the AD, who did it and when they did it, and when it is next due or if the action terminates further inspections. Does the AD note even apply to the application? Every AD note on every engine, propeller, airframe, or appliance that is a part of the aircraft must be addressed. Appliances could be autopilot servos, wheels, transponders, magnetos, fuel shutoff valves, ignition switches… just about anything that is attached to an aircraft.
As an owner you can work with your mechanic or repair agency and print out a complete listing of AD notes. I suggest that you work with the inspector or repair agency, as even though the FAA publishes listings on its website, the format may not be what your inspector is accustomed to, and he or she may prefer a different format that takes them less time to complete the research.
Each AD note corrective action should be listed in the maintenance records, and as an owner you can make a listing referring to each AD note and the log page or recording date of corrective action so your mechanic can see the sign-off.
Weight and balance records and equipment listings are another set of records that over the years become unreadable or incorrect. When your aircraft is updated, the equipment listing and weight and balance data may need to be updated. Ensure that this information is updated at the time the work is done, not years later.
Lost records
Lost or incorrect records can be a big problem depending on the type of aircraft and how it was operated. A few years ago, a fleet of large commercial aircraft were purchased from a foreign air carrier and transferred to U.S. registry for operation by a U.S.-registered air carrier.
Unfortunately, the individuals responsible for the records at the foreign airline did not do their job and not only were records missing, but components that were actually installed on the aircraft (serial numbers and part numbers) did not match the records that they did have. Every component with no history had to be removed and overhauled or replaced.
The anticipated expense to correct the errors was so great that the air carrier had to sell the entire fleet of aircraft to another foreign operator. While you may never intend to operate commercially, the purchaser of your aircraft may have that in mind. The records must be complete and correct, or the valuation of your aircraft may be significantly reduced.
Consider the effect of an AD note that applies to an engine or propeller, for example. With no records, the engine or propeller may have to be disassembled just to determine if the AD note applies.
However, records may be reconstructed, and there is a procedure for this listed in Advisory Circular AC 43-9C. Work orders, individual mechanic’s or repair stations’ records can be utilized to establish the total time of the aircraft, engine, etc. and listed in a new maintenance record. A notarized statement in the new record describing the loss and establishing the time in service based on the research and the best estimate of time in service is also required. While this is a legal remedy, reconstructed logs will decrease the value of the aircraft.
There are several companies that offer electronic recordkeeping and backup of all data. There is a cost associated with this, of course, and there are several options now for AD note advisories and weight and balance calculations. Anything that is on paper can be utilized in a digital format. AC 120-78 addresses electronic records and allows for digital signatures as well as electronic format of aircraft maintenance records.
I suggest that the actual aircraft records not be kept in an aircraft, your automobile, or your hangar unless for brief periods when necessary.
Make copies of important documents such as engine overhaul records, and major repairs, alterations and associated record entries.
Final thoughts
While the joke has been around for years that an aircraft is not safe to fly until the paperwork equals the useful load of the aircraft, it is important that the paperwork be completed and checked before the aircraft is flown. Certainly a piece of paper won’t physically keep a plane from flying, but it is important to know the rules and not deviate from the regulations.
A statement in the records that the aircraft is airworthy can be in error. It is up to you as a pilot to check the paperwork, do the preflight, and don’t accept the aircraft for flight if something is wrong. There are aircraft flown to an FAA office or representative for the purpose of a flight test that are technically unairworthy because the aircraft is out of annual, an AD is past due, etc.
Don’t waste your time, or others’, by being in a hurry and not checking your paperwork before you go fly. Sit down with your instructor the day prior and check the paperwork, aircraft records, and do a complete preflight to confirm that the required documents are on board. If anything is not right, correct the problem before flying off to a checkride event.
If you borrow or rent a plane, are you certain that the aircraft is legal and the paperwork (annual inspection, etc.) is up-to-date? It is your ticket that is on the line, not to mention you and your family that is in the aircraft—not the person on the ground who told you it was okay.
Good planning, accurate records, and a proper preflight will go a long way to making every flight enjoyable and safe.
Michael Berry – ATP multi – 757/727 – commercial single land and sea – 15,000-plus pilot hours – Turbo Jet Flight Engineer, A&P/IA mechanic – former aircraft repair shop owner, airplane owner, 121 Air Carrier Captain. Send questions or comments to editor@www.piperflyer.com.
