Required Signatures, and Where to Record

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Stacheair1
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Required Signatures, and Where to Record

As a maintainer, I used to be confused at times, about where to record different types of maintenance I performed on U.S. aircraft. I am sure in the past I made some mistakes in my record keeping. The FAA does provide guidance in how and where to record maintenance and inspection for Airframe and Powerplant (A&P) mechanics as well as others.

The guidance for maintenance and inspections performed is found in two FAA regulations part 43 and part 91. Keep in mind that maintenance and inspections is recorded different and require different ratings and authorizations to perform some tasks.

Advisory Circular (AC) 43.9C describes methods, procedures and practices that have been determined to be acceptable means of showing compliance with the general aviation maintenance record making and record keeping requirements of Title 14 of the Code of Federal Regulations ( 14 CFR) parts 43 and 91. This material in ACs is not mandatory, nor is it regulatory and acknowledges that the Federal Aviation Administration (FAA) will consider other methods that may be presented. It is issued for guidance purposes and outlines several methods of compliance with the regulations.

A quick review of what a mechanic can perform and sign off in accordance with part 65 mechanic limitations. An A&P can perform maintenance in accordance with part 65 Subpart D, §65.81 General privileges and limitations, §65.83 Recent experience requirements, §65.85 Airframe rating; additional privileges, §65.87 Powerplant rating; additional privileges, and §65.95 Inspection authorization: Privileges and limitations. I will not go into detail on these as I will assume the person performing maintenance or preventive maintenance holds the proper ratings.

First, let’s define maintenance in accordance with CFR 1.1. Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.

Second, Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations. Preventive maintenance is what pilots can do in accordance with part 43 Appendix A Preventive Maintenance, however it should be recorded in the same manner as part 43.9(a) describes for mechanics. 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 Certificate.

Part 91, 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. In other words, the owners are responsible that maintainers make the correct record entries in the proper place. Section 91.7 also makes the owner responsible for the airworthiness of the aircraft NOT the mechanic. Aircraft records is the only way of showing compliance with maintenance and to determine the airworthiness of the aircraft for the work performed.

There are two FAR/CFRs that maintenance people should understand part 43.9 and part 91.417 these two rules read similar, but are different.

§43.9 Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records (except inspections performed in accordance with part 91, part 125, §135.411(a)(1), and §135.419 of this chapter).
(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
(1) A description (or reference to data acceptable to the Administrator) of work performed.
(2) The date of completion of the work performed.
(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

§91.417 Maintenance records.
(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

To sum up the two rules part 43 and part 91 requires A&P mechanics to record maintenance they perform in the aircraft records. Section 91.417(a)(l)(i). Requires the maintenance record entry to include “a description of the work performed.” The description should be in sufficient detail to permit a person unfamiliar with the work to understand what was done, and the methods and procedures used in doing it. When the work is extensive, this results in a voluminous record. To provide for this contingency, the rule permits reference to technical data acceptable to the Administrator in lieu of making the detailed entry. Manufacturer’s manuals, service letters, bulletins, work orders, FAA AC’s, and others, which accurately describe what was done, or how it was done, may be referenced. Except for the documents mentioned, which are in common usage, referenced documents are to be made a part of the maintenance records and retained in accordance with section 9 1.417(b).

Aircraft records can be airframe, engine, propeller, avionic logbooks or binders. Part 91 was changed many years ago that changed for the term logbooks to aircraft records. What this means is aircraft records can be any document that meets the requirements of Section 43.9 such as a repair station work order or individual documents the meet the requirements of Sections 43.9.

Questions continue regarding multiple entries for 100-hour/annual inspections. Neither part 43 nor part 91 requires separate records to be kept. Section 43.11, however, requires persons approving or disapproving equipment for return to service, after any required inspection, to make an entry in the record of that equipment. Therefore, when an owner maintains a single record, the entry of the 100-hour or annual inspection is made in that record. If the owner maintains separate records for the airframe, powerplants, and propellers, the entry for the 100-hour inspection is entered in each, while the annual inspection is only required to be entered into the airframe record.

There is a growing trend toward computerized maintenance records. Many of these systems are offered to owners/operators on a commercial basis. While these are excellent scheduling systems, alone they normally do not meet the requirements of sections 43.9 or 91.417. The owner/operator who uses such a system is required to ensure that it provides the information required by section 91.417, including
signatures.

Many Aircraft Owners and Operators have expressed a concern about whether or not there is a requirement for maintenance record entries to be legible.

If we review Title 14 Code of Federal Regulations (CFR) Part 43, Section 43.9, we will see that the regulations does not have specific guidance concerning legibility requirements. However, if we look at Amendment 43-23, 47 Federal Register (FR) 41085, Sept. 16, 1982, we will find the following statement from the FAA: "Since legibility is a practical necessity and entries which are not legible do not satisfy the purpose of Section 43.9."

Therefore, it seems that when we look at maintenance records, the entries, including signatures and certificate numbers, should be legible.

What is important to understand is the signature makes the aircraft record a legal document. Section 43.9 required the mechanic NAME and SIGNATURE; the signature constitutes the approval for return to service only for the work performed.

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n14ky
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Denny, Can't argue with all but the last paragraph. 43.9 only requires the NAME of the person doing the work if that person is other than the one returning the item to service. So to return to service (if you did the work) all you need is signature, type of certificate, and certificate number. Now I know that nobody can read my signature, but I can be traced by my number, so adding my name legibly is redundant.

The biggest problem I see is owners doing "Preventive maintenance" and not recording it. Pilots and owners need to learn that when they perform preventive maintenance, they are still required to make a 43.9 entry.

The concept of computerized records is interesting. There still isn't any real way for a GA owner to do it easily. AC 120-78 provides the necessary info for the acceptance of digital signatures. Kind of a cumbersome system. About 10 years ago FAA instituted the e337 service, and to use it you need to buy a secure signature from their approved vendor. I would think that an IA that uses the e337 service should be able to use the same electronic signature to sign computerized maintenance records. I don't know if anyone has tried to have FAA approve that or not.

If you haven't tried the e337 system yet, I would highly recommend it. Makes filing 337s and getting Field Approvals much easier.

David

whitefaced
whitefaced's picture

I am interested to hear thoughts or opinions regarding signatures on an AD compliance list. Like many inspectors I am sure, I use a commercially available (not ATP................sorry) AD research/compliance tool. It spits out a compliance list from all of the data I input as a result of my pre-inspection records research. A person can select from various different reports including ones that are structured to include all aspects of a required maintenance entry as defined by FAR. I choose this report typically. In addition to other information, there is a place generated for signature and certificate number and type. Once the report is generated (usually 20 or so pages for older or complex aircraft) I print it off, and include it with the rest of the maintenance records.

In my experience, any of these products will to include within the generated compliance list, a great deal of AD's that actually prove to be not applicable to the specific product. On any aircraft that is new to me, I spend a considerable amount of labor reading each and every AD to determine for myself whether or not it does apply, and if so, the status of that AD. Once this is all done. I feel confident that the list I have created meets the requirements of FAR 91.417 for the owner (in my opinion, it actually exceeds the requirements of that rule).
Where applicable ADs have been previously complied with by earlier maintenance, on the signature and certificate lines of my report, I insert the phrase "see maintenance record entry". The compliance section of the record shows the date and time in service so that anyone can refer back to the actual sign-off which is usually embedded chronologically within the stack of records for the product. I use the same phrase in the "method of compliance" area of the report for the previously complied with AD.

For AD's that I actually comply with myself, I insert the actual method of compliance details, and include my actual cert number and type, along with my signature. I consider this procedure to meet the requirements of FAR 43.9 and 91.417. I also duplicate this AD sign-off in the traditional records (green, maroon, and black books).
Where I have had numerous lengthy discussions with FSDO inspectors is with regard to the voluminous list of non-applicable ADs that show up on my reports. My FSDO seems firm on the notion that when an inspector determines an AD to be non-applicable, that a notation must be made, and a FAR 43.9 signoff executed. They further state that once this is done, if the aircraft is subsequently inspected (say by a new inspector), that these non-applicable AD signoffs can be legally looked at as put-to-bed in a sense, and further research on these ADs need not be performed by the next inspector.
While I partially agree that the non-applicable AD sign off might hold some weight in a civil court, I firmly disagree with two things:
1. I don't know of anything in the rules that requires a signature from anyone for non-applicable stuff.
2. The notion that a subsequent inspector can rely on previous research of non-applicability because it has been notated as such, and signed off is in my opinion completely wrong, and could potentially set one up to miss an AD that actually does apply, and was mis-read, or ignored by a previous inspector(s).

I have personally observed this situation on numerous occasions when receiving an aircraft new to me for the first inspection.

In conclusion, while I disagree with signing for non-applicable stuff, I am doing so on the FSDO's request. This has been an on-going discussion for about ten years. Recently we received some "soft pressure" from my ASI to start signing. I am not in the habit of caving to requests just because it is the FAA, but in this case, I did it.

Doug Hereford

n14ky
n14ky's picture

Doug,
When looking at the records required for an aircraft, one needs to identify those records a maintenance provider is required to make (43.9 and 43.11) and those an owner is required to maintain (91.417). Take careful note of who has the responsibility!

43.9 tells us we have to make an record entry for return to service. In essence we are required to provide (1) A description (or reference to data acceptable to the Administrator) of work performed.
(2) The date of completion of the work performed.
(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

43.11 is similar but for inspections and requires time in service.

When we perform the maintenance requirements of an AD, we are only REQUIRED to record that maintenance as directed in 43.9. AC43-9C goes a little further and says we are required to include the items listed in 91.417(a)(2)(v), but that is not what the regulation says, and we know ACs are not regulatory in nature. There is absolutely NOTHING in 43.9 that even ALLOWS us to sign and use our certificate number for something we didn't do!

91.417 requires the OWNER to maintain records, and as it pertains to Airworthiness Directives, the OWNER is required to keep the items identified in 91.417(a)(2)(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the
next action is required.

There is NOTHING in 91.417(a)(2) that requires a mechanic to sign anything! 91.417(a)(1) requires signatures, but not (a)(2).

In short, as maintenance providers, there is no regulatory requirement for an AD listing. An AD listing is a good method for an OWNER to comply with the requirements of 91.417(a)(2)(v). There are no requirements for signatures identified in 91.417 other than for maintenance record entries (a)(1), so if you did the work to comply with an AD you have a requirement to comply with 43.9, but nowhere does it say you have to make multiple entries, one in the records(log book) and one in an AD listing. In fact, it would be totally inappropriate for you to sign for an AD you did not comply with on an AD Listing. It is not work you performed, and signing it could be construed that you actually returned it to service after work was performed.

All that said, it is a service to the Owner for the maintenance provider to give him the records he is required to maintain. Lots of owners are unwilling to pay for this service, so they pay each year for a completely new AD search, and hours of log book research. Our product is labor, so I have no problem charging an owner to perform his job if he is too cheap or lazy to have an adequate AD listing prepared for his aircraft.

When I complete an AD listing, my signature will only be on those items I complied with at that shop visit. I will usually identify date, time, and who performed the work by name (if I can read it) and certificate number, but will NEVER sign for work previously accomplished (even if I was the one that did it), and I will NEVER sign for an AD that is Not Applicable. Many times in the 43.9 record, if new ADs have come out since the previous inspection, I will note that the AD is not applicable, but I won't sign on the AD listing.

If there is no adequate record that complies with the requirements of 91.417(a)(2)(v), like no method of compliance (typical "complied with AD XX-XX-XX") and there are possible alternatives on method, I will tell the customer that the AD needs to be done again, and charge him for the labor and parts to accomplish it. If he doesn't want to pay for his failure to maintain adequate records and keep his aircraft "airworthy", he will get an "unairworthy" inspection sign off with a list of discrepancies identifying what issues there are. All my lists of discrepancies go in the log book, 43.11 only says it has to be provided to the owner, it doesn't say where, and in my opinion, the log book is the most appropriate place.

As to your last paragraph, any time an ASI gives me pressure to do something that has no regulatory basis, I ask first for him to provide the regulatory requirement. If he can't, and I know I'm right (thoroughly researched the position) I will flat out refuse and ask him to file a Letter of Investigation, and I simply tell him I'll see him at the hearing with the ALJ. They generally don't like doing paperwork (and a Letter of Investigation requires LOTS of paperwork), so that ends the discussion.

whitefaced
whitefaced's picture

n14ky,
Sounds like we are in agreement. I create the AD list as a service to the customer, but also as a data base for future inspections that I myself may perform. I think I fully understand the owner's record keeping requirements vs my record creating requirements. That is why I believe that the list I create actually goes further than 91.417 requires.
I feel that I am on firm legal (and practical) footing. I am disappointed with my FSDO position on this because, as I alluded to above, the philosophy that signing for non-applicable stuff provides some relief to future inspectors, is not only wrong legally, but wreckless from a practical stand-point.
I made a purely business decision to sign the stuff. I have spent countless hours over the years, discussing this issue with one of the ASI's assigned to my operation.
As of the last time we spoke about it, his parting words were to the effect that if we did not start doing it, he would move to the next level for legal involvement. Normally I would do as you suggested, and invite him to go ahead. It did not seem like money well spent in this case.
I did call the FSDO manager (whom I have found to be very reasonable in the past). His words were that if I am going to create a list like I do, then the non-applicable ADs must be signed. Dumbfoundedly, I hung up the phone.

Doug Hereford

n14ky
n14ky's picture

Doug,
So for your purposes, I would create the list for my own purposes and not provide it to the customer. That way you don't have to worry about the ASI or the FSDO manager giving grief about not applicable AD not having a signature. Here is a clear case of the ASI making an environment that is less safe and contrary to the regulation by insisting on having signatures for work not performed.

By chance are you working a Repair Station? If so check what is written in the Repair Station Manual or Quality Manual relating to AD Listings or AD sign offs. AS I recall, when I was DOM at a repair station, I had specific wording in my manuals that addressed this very issue. My AD listings would ONLY have signatures on items that were completed on the Work Order that caused an AD listing to be generated.

Some additional info, Order 8900.1 (FSIMS) Volume 6 Chapter 1 Section 3 states "A. Current Airworthiness Directives (AD) Status. The owner must keep a record showing the current status of applicable ADs.

1) This record must include the following:

· The current status of ADs applicable to the aircraft, including the AD number and revision date,

· The method of compliance, and

· The time‑in‑service, or the cycles, and/or the date when the next action is required for a recurring AD.

2) An acceptable method of compliance should include a reference to either a specific portion of the AD or a manufacturer’s service bulletin, if the bulletin is referenced in the AD.

3) The document that contains the current status of ADs/method of compliance may be the same as the record of AD accomplishment. The record of nonrecurring ADs must be retained with the aircraft indefinitely. If selling the aircraft, the records must be transferred to the new owner. Part 91, subpart K has specific requirements for the transfer of aircraft records when an aircraft is removed from the fractional ownership program and sold."

Again, in the ASI Handbook (FSIMS), there is no requirement for signatures on any AD listing! Again, even if it was there, an Order is not regulatory in nature, but we have the regulation, an Oder, and an AC all of which don't identify that a signature is necessary for an AD listing.

My experience with FAA Inspectors is that if you give up and turn over because "They say so" they will take advantage of you. If you challenge them, they will respect you for it. I remember once when I was going for a banner tow waiver, the ASI gave me grief because my 45.11 placard for model and serial was Dymo labelmaker Tape. I showed him other Dymo labels on the airplane that had been there 20 years. He still didn't like it and said he wouldn't give me a waiver. I told him that if I wasn't in compliance with 45.11 because of the placard, I was going to go fly the airplane in his presence. When I got down, I wanted either a Letter of Investigation, or my Waiver. When I landed, he handed me the Waiver!

Don't let them push you around! It makes it harder on all the rest of us. If they question something, ask for the specific regulatory reference. If they can't provide one, there is no need to do what they ask. I would accept a comment of I need to research this, but I would not accept them telling me I had to do something unless they can support it.

Don't get me wrong, If I'm in error and they can support their point of view I will comply, and most likely thank them for showing me the error of my ways. But I don't accept the "Because I said so" attitude that many inspectors have.

David

Stacheair1
Stacheair1's picture

Just for the record, I have my own Inspection Authorization (IA) 8-hour renewal course I teach in the San Francisco Bay Area and here in Japan as well. In my class the most popular section is when I open the floor to discussion about records and sign offs. At times, this becomes a lively discussion as we are having now, but a healthy discussion. I think the sharing of ideas of how each of us learn and for me being on both side of the fence provides me with some insight how the FAA inspector would look at things.

It is important that as mechanics we understand part 43 and part 91 rules for maintenance records. There is a difference between maintenance records part 43.9 and part 91 Subpart E for maintenance, alterations, and inspections. As a maintainer and IA holder myself we are expected by the FAA to understand and know the rules and how they apply. Also, I know this can be and often is a highly charged issue. What I can say is when an aircraft has an incidence or accident the FAA takes possession of all the aircraft records and goes through then with a fine toothcomb so to speak.

From the record inspection, the FAA finds many mistakes make by mechanics and pilots. These mistakes can and often lead to investigations and violations only because the incident or accident brought them to light and may have nothing to do with what happened.

Because the FAA will do a complete record inspection at certain time it is important that we mechanics know what part 91.417 says about how to record maintenance and inspection and well as part 43.9 and 11 for inspections. The only time we share responsibility with the owners for the airworthiness of the aircraft is during inspections that we perform.

In my IA class,I cover mechanic responsibility in detail and how we can and should protect ourselves in making proper aircraft record entries. Since there is so much information a mechanic should know in my classes I provide each attendee with a reference CD-ROM that I have prepared to help the mechanic after the class is over. The FAA expects each IA to stay current of FAA regulations and procedures and know them. I know this can and is difficult to do at time and rules and regulations is not taught in some programs as well as they should be. This is why discussion like this are important for us mechanics to learn from each other.

I will be in the San Francisco Bay Area February 11th through February 18th, if anyone would like to get together informal or in a formal setting I would be happy to arrange my schedule to have discussions on aircraft records or other subjects. I know this is short notice, but sometimes face to face is a great way gain knowledge. I happen to work with two A&P colleges in the Bay Area and may be able to arrange for a room at one of the colleges if anyone is interested.

n14ky
n14ky's picture

Denny,
I'd love to get together some time to banter about the regulations, but I'm on the east coast so not likely unless I'm out that way on business.

Like so many things, for all of us, if we don't like the regulations, take advantage of Part 11 and petition to change them. Likewise, when an NPRM comes out concerning maintenance, be sure you comment on it. Even if you agree with the proposed regulations make comments! This is how we make things better for all of us.

David

whitefaced
whitefaced's picture

n14ky,
One of my biggest customers is a 141 flight school, and 135 charter operator for whom I am the DOM. I provide them the AD lists because it stream-lines their maintenance record audits on the ops side. Again, this is a business decision. What is good for them is good for me.
I am not interested in winning a pissing contest with the Feds. Anyone who is smart acknowledges the reality that an FAA inspector can directly and immediately effect an operator or maintenance provider's ability to make a profit. Whether they are correct or not. Also, anyone in the industry or the FAA who knows me knows that I have never let the FAA push me around. I assure however, that I do it to protect myself and my customers, and not to make life easier or harder on anyone else. My respect with the local FSDO is firmly intact.
Anyway, it sound like we agree on signatures at least.

Doug Hereford

Stacheair1
Stacheair1's picture

David, I get out to the East Coast now and then, but I can always be reached by e-mail 24/7. I think it is import to share ideas with other mechanics that is why my inbox is all ways full with questions from mechanics. Being a former FAA inspector, I try to pass on what I have learned and did the same when I was still working for the agency.

If anyone has a question, they would like to ask in private you could always contact me by e-mail. As an FAA inspector I would often have mechanics say "OFF THE RECORD", there is nothing off the record with the FAA. However, I did work with several mechanics that had asked me to assist with a situation they found themselves in. As a FAA inspector, we/they can use some discretion as I did and I know many inspectors do this as well. The FAA only wants compliance and the last thing a FAA inspector wants to do in an enforcement action, but there are a few that thrive on enforcements. I often tell mechanic in aviation their best friend is the FAA inspector. I know many would say never talk to the FAA inspector, but I think that is wrong.

FAA inspectors are mechanics and still have a grease rag in their back pocket; I kept on my office desk to keep me grounded and remind who I worked for. However, there are a few FAA inspectors that you need to keep your distance from and those are easy to spot.

Keep in mind I do NOT work for the FAA anymore and I cannot give legal advice, as I am not a lawyer. However, I do know the mechanic rules and requirements very well and as an inspector, I have been involved in many situations. In addition I have a vast aviation library that I share such as the CD-ROM I hand out at my IA renewal classes. I still have my A&P certificate and I am still learning that is what this forum is all about sharing ideas and learning for others.

Stacheair1
Stacheair1's picture

Doug, I had to smile when I read your post. FAA inspectors have a saying they are like pigs and enjoy rolling in the mud. As a former FAA inspector and even when I work for the agency, I enjoyed the mechanic that would challenge me. Inspectors are not some god as some think they are. However, some have a power trip when they walk into your facility. When I was first in the agency I was like that as well, but soon learned that was the wrong attitude to have. I made many mechanic friends in the district I worked and was the one they could contact for help when needed.

I took a lot of grief in the office I work in when I would stand up for the mechanic in the field and gave them the benefit of the doubt. In most cases the mechanics were right and may of made a few mistakes, but I considered it all learning and used those mistakes as a learning experience. I was fortunate enough to have a say in my replacement when I retired and chose one of the mechanics that did make some mistake I knew. I am happy to say this new inspector is walking in my footsteps working with mechanics and not burning them.

On the flip side of the coin being an inspector mechanics can work with I was also feared by some. If a mechanic intentionally committed fraud with a record entry, I would and did come down hard. I have no place for mechanics that make false record entries when people lives depend on what we do. As an inspector, I was a first responder at accident sites as well and it’s not a good feeling when you find a mechanic made a false entry that caused an accident. This happened to me and changed me forever as an inspector, picking through the pieces of a burned aircraft and seeing people’s lives destroyed.

We do agree about the signature it means everything for record entries. Thanks for the great comments and feed back.

whitefaced
whitefaced's picture

I have another issue that has challenged me from time to time. The best way to present it might be with an actual situation.
We used to perform maintenance on a Cessna 340A which was on a customer's 135 certificate. At the time I was designated as (still am) the certificate holder's director of maintenance. The aircraft was new to the certificate, and as such, we had done some pretty extensive maintenance to bring it into conformity. One of the maintenance tasks was R&R of the propellers and overhaul.

A number of Cessna piston twin aircraft are subjected to the complex AD that deals with unsafe conditions on the exhaust system. This AD can be a tracking nightmare in my opinion. This aircraft's records were poor by my standards, but I would say that they were average for industry standards. This exhaust AD had records of compliance that seemed to move from airframe to engine(s) records. Compliance requirements for this AD span 12 yrs, so there was alot of page turning, and jumping around on my part to verify conformity. Several of the individual requirements of the AD had to be performed by us because I simply could not find record of compliance.
To me, this is a good example of why is can be so important to physically locate maintenance entries in the records of the relevant equipment as required by 43.9. Obviously in this case, the subject exhaust system is not an engine part. And rightfully so, the AD was written as a Cessna AD (not a Continental).

The props came back from overhaul and we installed them. A short time later, the FAA came out to inspect the plane and records so it could be added to the 135 certificate. After looking at the plane, the ASI started with the records. I happened to be present when he was paging through one of the propeller records. I saw him shrug his shoulders, say Huh, and toss the book across the desk to the new "inspector in training" that was with him. He said "look at this, prop was overhauled, but never installed on the aircraft". I politely interupted and asked him to look in the airframe log for the record of installation of the propeller(s). An arguement insued which resulted in him storming out of the hangar with minion in tow.

I had spent a great deal of time pondering where to place the prop R&R record. I believe that it is niether propeller or airframe maintenance, but "aircraft" maintenance. To me, the most appropriate place for the record was the airframe records. That is the way I have always done with prop or engine changes. Some other rational I used............The procedure to R&R the propeller comes from the aircraft maintenance manual, not the prop manual. The propeller is a part of the aircraft's type design, not the other way around.
To me the simple R&R of a propeller is airframe maintenance, and as such could be accomplished by an "airframe" rated mechanic.
This incident happened a long time ago, and the inspector and I are still working together today. I thought he was extremely unprofessional at the least, and showed a poor example to the trainee. It did not help the situation when the trainee agreed with me about where to put the entry.
Any thoughts would be appreciated.

Doug Hereford

n14ky
n14ky's picture

Doug,
I tend to agree with you that the R&R of the prop, or an engine would be an airframe maintenance task. The 91.417 requirement is for records, not log books. What you did satisfied both 43.9 and 91.417. That said, when I do an engine or prop install, and if there are individual log books for each item, I do make entries in each book indicating total time of the item, time since overhaul of the item, and total time of the aircraft at time of installation. Makes life easy when you next pull the prop or engine, and then install a different one. There is no requirement for this, but like your comments on the AD listing, it makes it easier for future maintenance and record keeping.

That Cessna exhaust AD is a real killer for record keeping! When I have them, my AD listing has multiple instances of the same AD, for each paragraph, and each engine. That's the only way I've ever been able to keep the compliance of that AD in line.

Your comment about physically locating the record of compliance for ADs is something I always try and do. I really hate when a customer only brings the current log book when asking for an inspection. I usually send him home and tell him to bring ALL maintenance record to include all log books or records, all 337s, and copies of all STCs. On top of that, I almost always get the record from AFS-750 and compare the 337s the owner has to those filed with FAA. It's amazing how many times a customer doesn't have the 337s, and how many 337s they have that never were filed with FAA. Whenever I find this, I make copies and send them off to AFS-750 to complete the records. It's also amazing how many Major Alterations I find on airplanes that were never documented. This is always fun, trying to explain to a customer why his airplane might be tied up for 6+ months while I sort out the engineering and documentation for something that was done to an airplane 20+ years ago!

David

The Piper lift strut AD is almost as bad. For some reason the FAA doesn't understand that having multiple items with different compliance times in an AD has a 100% probability of someone doing it wrong.

n14ky
n14ky's picture

Denny,
I work at NAS Pax River, and live north of DC, so if you are ever in the area give me a shout at [email protected].

I agree with you that when you challenge the ASI and you have done your homework, they generally respect you for it. That's how I was able to get appointed as a DAR from the FSDO, and a DER from the ACO. There are several times a year that an ASI will actually call me to ask for my ideas on how to handle an issue and what regs are the ones that provide a clear path to the answer. They usually follow it up with a comment like "You guys are out there living this every day, you mechanics know this stuff better than we do, we are just paper pushers."

Like you, I do a number of IA seminars, and have made a number of my powerpoint presentations available for anyone that wants.

Good discussion with both you and Doug!

David

Stacheair1
Stacheair1's picture

Doug, you were and are correct the proper entry for R&R of the propellers goes in the airframe records. If the ASI had their act together and just referred to the TCDS for the airframe, it would indicate what props and engines are install on the airframe. The airframe maintenance records is the main/master record for any aircraft and AC 43.9C even states you can have one record “Airframe” then everything is logged in that record.

In my FAA career, I have had this same discussion with other inspectors about logging components, but the T/C is tied to the airframe regardless and any R&R goes in the airframe records for tracking as the master record.

My second book I wrote called “Gray Matter” I had as many mechanics write down questions and give me and I looked up the answers and reference where I found the answers. I had this in a 3-ring binder for many years as I added to it. I did publish it as a book to help mechanics know where to find the answers to their many questions. I must admit it took about seven years to put together, but I wish there was a database we could submit questions and have the answers as a public service. Now that would certainly be a useful database.

I have such a database for myself as certain questions still come up, I am good at research and finding the answers. Maybe I can discuss this with my web daddy and see if there is a excel program or some other program I could place on my web site that would allow us to submit question and log the correct answers kind of like Wikipedia does. Everything on my web site is FREE to download and some of it is not current, but still good information.

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