Roger Lee Posted January 2, 2017 Report Share Posted January 2, 2017 "Roger no need to call the FAA, the answer is in 91.417. Look it up." I did. Here is what it said. I hadn't looked at this for years, but believe this would set you up for a disaster waiting to happen. (The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. Who would buy such a disaster and how would you defend any thing anyone ever did and didn't do. "(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance." Who do you know that does this. I have never seen anyone list all the time limited parts times on all the above. "(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. You rarely see this. "(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. This paragraph says the records all need to be retained for the sale of the aircraft. Seems contradictory to you can disregard records after one year or after the next inspection supersedes. These are the minimums according to the FAA. Why even worry if you're barely making these minimums. Why not just do a better job. Link to comment Share on other sites More sharing options...
WmInce Posted January 3, 2017 Report Share Posted January 3, 2017 Tom,I think that 91.417 is a good reference.In my experience, many owners are very unfamiliar with their responsibilities in 14 CFR part 91.417.Mx record "fluff" is a pet peeve of mine. Owners can produce the last 30 yrs. of oil changes and inspections records, but can't show me the current status of applicable Airworthiness Directives or Safety Directives. Many can't find records for alterations.In the end, it doesn't matter much to me from a records point,why a certain maintenance task was performed. As an inspector, I only have to confirm the CURRENT condition of the product. As an inspector, do I really care that a tire was changed because it was worn? I don't. I only care about the current condition of the tire. Do I really care what the last 10 years of compressions were? Not much. I only care what the current compression readings are. As an inspector, I don't really concern myself much with what previous inspectors have done or not done because once my maintenance is complete, and I approve the aircraft for return to service, I own it.Like others, I am not suggesting that additional historical info is not valuable, but it does not belong in a maintenance record. I am also not suggesting to an owner that they discard "expired records".I have actually been skeptical of "fluffy" records in the past. You get a two page inspection entry and when you look at the aircraft from across the hangar you can tell that the brakes are installed upside down. Makes me wonder whether the previous inspection was performed with a flashlight and mirror..................or a pen. But at any rate, it really doesn't matter because I willsoon be responsible the my own inspection of the aircraft, and the previous maintenance records will then have effectively "expired".Owners should become very familiar with 91.417, and spend some time talking with their mechanic about the practical reasons why certain records are permanent, and other are not.Doug Hereford You may not care about some of those things in the above post, but from a perspective buyers point of view, they certainly care. IMHO, besides having a good inspection performed, as a seller, I am also very interested in good documentation. Good maintenance AND good documentation make an airplane a lot more attractive (sellable). As a perspective buyer, incomplete or shoddy maintenance records raise a big red flag. Aside from that, it says a lot about the care and attention an owner has given to your future airplane. If the documentation is not thorough and complete, it makes me wonder how it may have been flown and treated otherwise. Poor documentation speaks volumes. No thanks. It is surprising to me, that Roger is getting a lot of pushback on this. I fully support his views on aircraft documentation. Link to comment Share on other sites More sharing options...
Doug Hereford Posted January 3, 2017 Report Share Posted January 3, 2017 Roger, It seems to me that what your are referring to is more about what you would consider good customer service. I mostly agree. When I am performing an inspection however, I have one task..............discover and properly document "unsafe conditions". While I am inspecting, I don't care how many tire changes the aircraft has had or how many oil changes the aircraft has had, or what last year's compression numbers are. I am not interested in bad-mouthing the previous inspector or maintenance facility. I am not preoccupied with going to court or staying out of court. What records I am interested in as an inspector are: 1. Records of total time in service (so that I can confirm any additional required maintenance due on the basis of time in service. 2. Status of applicable Airworthiness Directives and/or Safety Directives. These pertain directly to unsafe conditions, and may have recurring requirements. 3. Records of alterations and in the case of SLSA, documentation of mfg. authorization to have these alterations performed on the aircraft. Also pertaining to alterations, I must see any additional inspection requirements pertaining to the alteration so that I can confirm that I am performing a complete and proper aircraft inspection. These items are very closely aligned to what 91.417 (a)(2) requires of an owner. The "status of life limited parts" is something that I believe is actually important to SLSA, but doesn't seem to have been considered much with regard to the relevant rules. It is possible for an SLSA aircraft to have life limited parts installed, or other items which are known as Airworthiness Limitations pertaining to them. The status of these items are also a part of 91.417(a)(2) PERMANENT records, and are very important. In my opinion 91.417 as well as most other rules, are not minimums or maximums and should not be looked at in that way. I would also never characterize another airman as lazy, bare minimum, or otherwise deficient on the basis of his/her strict compliance with them. Doug Hereford Link to comment Share on other sites More sharing options...
Doug Hereford Posted January 3, 2017 Report Share Posted January 3, 2017 Wmlnce, I understand what you are saying. I can't speak for others here, but my push-back (if you can call it that) comes primarily from a characterization that certain people be perceived as lazy, bare minimum or otherwise a lessor mx provider on the basis of slanted information. I strongly recommend again that owners read and thoroughly understand 91.417, and talk in depth with their maintenance provider about the practical aspects of this rule. You may be enlightened, you may not. No one will ever argue against good documentation, but sometimes, what constitutes "good" is not as simple as we may think it is. As an aircraft buyer, I am concerned about the same things you said. You might be able to look at records like a paint job. Paint might look really good, but be covering up garbage. Fluffy records can do the same thing. One thing is for sure, if the records don't contain all that the rule requires, there is reason for concern whether buying, selling, or just operating. Doug Hereford Link to comment Share on other sites More sharing options...
Roger Lee Posted January 3, 2017 Report Share Posted January 3, 2017 You usually only get one first impression. If all you get is to look back in a logbook and see what others have done that's tends to be the impression of the work they did. When I see a lot of detail I at least feel better that the person that was dedicated enough to document well is also the kind of person that did a good inspection. Since what you did is represented in writing then it would pay to represent yourself well. When I see a 3-4 line annual logbook label that's exactly what I feel they did to that plane. Those people tend to not use checklist and fail to do detailed complete work. If you have good work habits in one area that tends to bleed over in others. If you happen to be lazy or do things half way then that tends to be your style too. I have had to question far too many mechanics about what they did on an inspection due to poor logbook detail. Turns out almost all were poor and incomplete inspections because they didn't know something had to be done and they couldn't remember if they did it and I think that's sad. If all you get is the logbook to judge how well a plane was maintained then that's how your work is judged. Link to comment Share on other sites More sharing options...
Roger Lee Posted January 3, 2017 Report Share Posted January 3, 2017 Hi Buckaroo, This is all your fault. You ask a easy question. (Just kidding). This is just like Andy's questions turn out. He ask about spark plug gap and 20 pages later,,,,,,,, Somehow Andy I think you're psychologically driving this thread. Link to comment Share on other sites More sharing options...
Buckaroo Posted January 3, 2017 Author Report Share Posted January 3, 2017 It's all good! ???????????? Link to comment Share on other sites More sharing options...
Tom Baker Posted January 3, 2017 Report Share Posted January 3, 2017 Roger, I don't think any of us are saying that you shouldn't document what you do, at least that is not what I'm saying. From your comments I know my maintenance entries are less detailed that your, but I do provide a detailed work order to the owner. I think that likely most of the same is being relayed to the owner, but in a different format. Personally I would prefer that the airplane be maintained exceptionally with less documentation on the records that lots of details and poor maintenance. There is a shop in our area that provides exceptional logbook entries by your standards, and I cringe if I have to do the next inspection after they have worked on the airplane. Those exceptional logbook entries also come with a high price tag for the owners. I could make a long list, but here is one example. The airplane was a Piper Cherokee. There was an AD on the control wheel shaft. It required replacement of the universal joint if there was excess wear. It is a pretty major job that requires some precise machining. I have replaced some of these in the past, so I was familiar with the AD. When I was inspecting under the instrument panel I noticed that the taper pin on the universal joint was pulled into the hole beyond what is specified in the instructions for replacing the universal joint. This meant that the installation was done incorrectly. Upon further inspection I found that the area around the hole had been staked with a center punch trying to tighten the hole, so they knew it was not right but did nothing about it. I had to replace the universal with a new on with holes that were properly reamed for the taper pin. This cost the customer about $500 for parts and labor that they had already paid someone else to do. The thing is the other shops work was documented wonderfully. This brings me back to my main point, having a wonderful logbook entry does not make the work that was done on the airplane any better, Link to comment Share on other sites More sharing options...
WmInce Posted January 3, 2017 Report Share Posted January 3, 2017 That's a false equivalent. The quality of the maintenance can be good or poor regardless of the log book entry. I prefer a very thorough entry vs information on a separate piece of paper. What was done, why, and how should become part of the aircraft record, ie. logbook entry.Concur. What's more, it has been my experience that "detailed work order(s)" are nothing more than an inventory of parts and labor charges, and contribute very little to the actual work which was accomplished. I have never seen a "work order" which gives a detailed explanation of a discrepency and its associated corrective action. A parts and labor inventory is a convenient list or break down of the charges, but if used as a "supplement" to the logbook writeup, I surmise it is a crutch, to spending time and effort to construct a thorough and complete logbook entry. Link to comment Share on other sites More sharing options...
Tom Baker Posted January 3, 2017 Report Share Posted January 3, 2017 Concur. What's more, it has been my experience that "detailed work order(s)" are nothing more than an inventory of parts and labor charges, and contribute very little to the actual work which was accomplished. I have never seen a "work order" which gives a detailed explanation of a discrepency and its associated corrective action. A parts and labor inventory is a convenient list or break down of the charges, but if used as a "supplement" to the logbook writeup, I surmise it is a crutch, to spending time and effort to construct a thorough and complete logbook entry. I think you are missing the point. I agree that a logbook entry should be thorough and complete. However I don't think it should automatically be assumed that a comprehensive detailed logbook entry means the quality of work is better. That to me is what Roger has implied. My number one goal is to provide my customer with a safe airplane with all the required documentation to protect the owner and myself. Take a look at the picture of log entry made by Roger on the first page of this thread. Do you see any issues with this entry? I see several, but I am a trained aviation maintenance technician. Link to comment Share on other sites More sharing options...
Doug Hereford Posted January 3, 2017 Report Share Posted January 3, 2017 kcarab amabo, You touch on a good point. It seems like a lot of us are taught to believe that "log books" are the hallmark items of aircraft maintenance records. This is not true in my opinion. Those pesky little green, maroon and black books are filled with expiring maintenance records that really have little to do with aircraft maintenance status or permanent aircraft RECORDS. My advise to owners is to keep all of those "separate documents" like gold. Go page by page through those little "log books" and find records for the status of Applicable Airworthiness Directives and Safety Directives and other service info., and any records for aircraft alterations. Copy, save or transfer those items to an easy-to-read summary. Also find the entries for the latest inspections..............which for SLSA would be: Condition inspection, ELT annual inspection, and alt/transponder, or just transponder inspection. Transfer that inspection status information to a central location and keep it up to date. Retain FOREVER, evidence of any approvals given by the mfg. to alter your aircraft and any FAA form 337s that may exist for major alterations to FAA approved products that are installed on your aircraft. Ensure that whenever a required inspection is performed (Condition, ELT or Alt/Trans) that the aircraft Total Time in Service is noted in the inspection entry and that the proper sign-off verbiage has been used per your operating limitations. Spend less time worrying about the fluff contained in day-to-day maintenance entries and worry more about the actual quality of maintenance that is done. I have seen the same thing as Tom. Really great paperwork written in a lawyerly fashion backed up by an aircraft that looks like a 30 yr. old tractor. My story about the brakes installed up-side-down (like Tom's control yoke story) was not made-up. Three page annual entry for this PA28-235. The same aircraft had had an engine overhaul with a crankshaft AD overflown, and NO baffle seals on the baffles. The previous inspector was very renowned locally and the owner was extremely proud of his paperwork when he came to me initially. Many, many other examples over the years. I personally like to use email for my day-to-day fluff to the owner. I have also found that you cannot be too detailed when it comes to the invoice. Every move I have made goes into it. The owner may not keep it but you can damn sure bet that I will. Doug Hereford Link to comment Share on other sites More sharing options...
WmInce Posted January 3, 2017 Report Share Posted January 3, 2017 "I agree that a logbook entry should be thorough and complete. However I don't think it should automatically be assumed that a comprehensive detailed logbook entry means the quality of work is better." ----------------------------------- Concur. ----------------------------------- "That to me is what Roger has implied." ----------------------------------- You may have missed his point. He did not come off that way to me. My impression was it is about usable information, to all concerned, not just technicality. ----------------------------------- "My number one goal is to provide my customer with a safe airplane with all the required documentation to protect the owner and myself." ----------------------------------- I have know doubt about the sincerity of that, but we hear the same thing with every mechanic out there. ----------------------------------- "Take a look at the picture of log entry made by Roger on the first page of this thread. Do you see any issues with this entry? I see several, but I am a trained aviation maintenance technician." ----------------------------------- Are you talking about the entry dated 12-4-11? As a trained aviation technician, please enlighten us. Link to comment Share on other sites More sharing options...
Tom Baker Posted January 3, 2017 Report Share Posted January 3, 2017 Are you talking about the entry dated 12-4-11? As a trained aviation technician, please enlighten us. Yes, that was the entry I was talking about. I will point out the issues, but will wait until tomorrow to see if anyone else wants to provide enlightenment. Link to comment Share on other sites More sharing options...
Doug Hereford Posted January 4, 2017 Report Share Posted January 4, 2017 I briefly looked over the entry (12/4/11) I don't see any really glaring issues. It raises a couple of questions though. Was the ELT inspected as required by 91.207? I see where the battery replacement date was notated. This inspection is required annually, and is not fully captured by the condition inspection. (Roger this is not your responsibility to do on a condition inspection, but good customer service to remind the owner about). Is the aircraft operated for hire? If not, then the next inspection is not due at 594 hrs. as is noted. Either way, Roger, this is not your call and not a part of a required entry. There are several instances where work was noted but no description of the actual work performed (as required by FAR 43.9): engine was removed and reinstalled, carbs were synced, etc................What procedure (or reference to acceptable procedure) was used? There was a bunch of "fluff". While I don't agree with it being there, it is not contrary to reg. Otherwise it looks ok to me. I did not judge it on technical basis. Doug Hereford Link to comment Share on other sites More sharing options...
WmInce Posted January 4, 2017 Report Share Posted January 4, 2017 I have also found that you cannot be too detailed when it comes to the invoice. Every move I have made goes into it. The owner may not keep it but you can damn sure bet that I will. Doug, You have made one of my points. To me, the "invoice" is exactly that . . . an invoice. A list of parts and labor, billed to and paid for by the purchaser. Just how detailed can you make an invoice when it comes to parts and labor? In my experience (military and commercial), maintenance logbooks were "logs" for recording deficiencies, corrective actions, scheduled, unscheduled maintenance and deferrals (MEL's). "Every move you make" on my airplane, should be documented in the airplane logbooks. If that requires several pages of my logbook, have at it. If it requires an extra page or addendum for a complex operation, that's fine too. They are "logs," an official record of events. Of course, as Tom pointed out, and I agree, there are specific items that should be included. Those invoices may cover your "six," but IMHO, labor costs have no place in the maintenance record. That is nobody's business but mine and yours. But it certainly is convenient, to imply that an invoice is an extension of the logbook. I respectfully disagree with that. Link to comment Share on other sites More sharing options...
Anticept Posted January 4, 2017 Report Share Posted January 4, 2017 Deficiencies (discrepancies) don't belong in an airplane logbook. Those belong on a separate sheet of paper to be provided to the owner. RETAIN A COPY FOR YOURSELF! I'd even recommend considering having them sign it. I think this is far more effective in court as well than just putting it in a logbook. Link to comment Share on other sites More sharing options...
WmInce Posted January 4, 2017 Report Share Posted January 4, 2017 Deficiencies (discrepancies) don't belong in an airplane logbook. Those belong on a separate sheet of paper to be provided to the owner. I disagree with that. But I understand that is industry standard for general aviation. Or is it? Link to comment Share on other sites More sharing options...
Anticept Posted January 4, 2017 Report Share Posted January 4, 2017 Airliners follow their opspecs and do what they say. For everyone else that isn't 121 or 135, discrepancies don't belong in the logs. Link to comment Share on other sites More sharing options...
WmInce Posted January 4, 2017 Report Share Posted January 4, 2017 Airliners follow their opspecs and do what they say. For everyone else that isn't 121 or 135, discrepancies don't belong in the logs. So Corey, does that mean flying clubs rely on "word of mouth" from members, regarding discrepancies? Link to comment Share on other sites More sharing options...
Doug Hereford Posted January 4, 2017 Report Share Posted January 4, 2017 I would add one observation on the 12/4/11 entry. FAR 43.9 requires that when a maintenance entry is made that it be made in the record for the relevant equipment. In Roger's entry, it looks to me like repairs were performed on both the airframe and the engine (which are separate pieces of equipment as is standard). I feel like this is a bit of a gray area where SLSA are concerned. Since in this case, neither the aircraft, nor its engine or propeller are Type certificated, this portion of the rule is arguable to me. Since SLSA must be maintained IAW the "aircraft" manufacturer's procedures, it also mucks up the water. Ideally, engine maintenance should be recorded in engine records, and airframe maintenance should be recorded in the airframe record. Same goes for propellers. The inspection entry is actually a completely separate entry however. Since a "Condition" inspection is a whole aircraft inspection, the most logical place for it would be the airframe record. However, it could/should legally be a stand alone record. Doug Hereford Link to comment Share on other sites More sharing options...
Doug Hereford Posted January 4, 2017 Report Share Posted January 4, 2017 WmInce, Yes, General aviation has no required disposition procedure for discrepancies found during operation. If one is using an MEL, then they would be bound to the procedures in that MEL for deferring inoperative instruments and equipment, but there is no formal process to communicate squawks to maintenance. As Corey stated, other operating rules (121, 135, etc) have more defined requirements/procedures where discrepancies are to be recorded and conveyed to maintenance. In the private sector, an invoice is whatever the customer and service provider agree upon. An invoice most often IS NOT an extension of the aircraft legal records, and I never said that it was. It is in my opinion, a good place to provide detailed documentation of discrepancies, and all actions taken to correct them. My customers feel much better about a labor value when I describe in detail all of the steps that I took to arrive at the corrective action. This is where I would say WHY I performed a certain maintenance task. "Replaced R tire and tube due to it being worn to limits". That might find its way on to my invoice, but would never be stated that way in the aircraft maintenance record, because that is not a correct maintenance entry. I might go into great detail on my invoice about the troubleshooting process that I used to find the root cause of a problem. This justifies the labor, and records every step of my actions...............The maintenance entry however would only contain the actual maintenance that was performed.............ie opened xyz access panel, and repaired 123 interconnect wiring to the outflow valve in accordance with........blah blah blah procedure. A legal "discrepancy list" is an entirely different thing that is required by regulation (43.11) when DISAPPROVING and aircraft for return to service following an inspection. It may be beyond the scope of this discussion, but I would be glad to dive into it on a different thread or whatever works. Also I agree with you that cost is nobody's business but yours and mine. Nothing says that that info. could not be hidden from view if need be. I have used invoices countless times to help confirm prior maintenance. Nothing is more convincing that something has actually been done than knowing that the owner actually paid for it. Doug Hereford Link to comment Share on other sites More sharing options...
Tom Baker Posted January 4, 2017 Report Share Posted January 4, 2017 So Corey, does that mean flying clubs rely on "word of mouth" from members, regarding discrepancies? The discrepancies they are talking about are the ones noted by the maintenance techician. The list is to be provided to the owner, who then needs to decide how to have the discrepancies fixed. In most cases the norm is to have the person performing the inspection fix the discrepancies. Link to comment Share on other sites More sharing options...
WmInce Posted January 4, 2017 Report Share Posted January 4, 2017 The discrepancies they are talking about are the ones noted by the maintenance techician. The list is to be provided to the owner, who then needs to decide how to have the discrepancies fixed. In most cases the norm is to have the person performing the inspection fix the discrepancies. For operations such as charter services and flying clubs, aren't discrepancies also noted by the users (charter pilots and renters)? i.e. nose strut bottoms out or VHF radio inop. Between charter flights and each rental, how are newly discovered discrepancies noted . . . just by word of mouth? Why doesn't the paper trail start there? Let's not stray into the weeds, but from what I am hearing, GA seems a lot more lenient in documentation. Link to comment Share on other sites More sharing options...
Tom Baker Posted January 4, 2017 Report Share Posted January 4, 2017 For operations such as charter services and flying clubs, aren't discrepancies also noted by the users (charter pilots and renters)? i.e. nose strut bottoms out or VHF radio inop. Between charter flights and each rental, how are newly discovered discrepancies noted . . . just by word of mouth? Why doesn't the paper trail start there? Let's not stray into the weeds, but from what I am hearing, GA seems a lot more lenient in documentation. I described what they were talking about. The discrepancies your are talking about could be delivered by a slip of paper, word of mouth, an email to the club maintenance officer, but there is no need to place it in the aircraft records. If you did you would have all kinds of oddball non relivant stuff in the aircraft records. An example iI had happen. Twice a flight instructor who somewhat managed an airplane based at a small airport around here told me the stall warning horn was INOP. The problem was the airplane did not have a stall warning horn, it only had a light. Link to comment Share on other sites More sharing options...
WmInce Posted January 4, 2017 Report Share Posted January 4, 2017 I described what they were talking about. The discrepancies your are talking about could be delivered by a slip of paper, word of mouth, an email to the club maintenance officer, but there is no need to place it in the aircraft records. If you did you would have all kinds of oddball non relivant stuff in the aircraft records. An example iI had happen. Twice a flight instructor who somewhat managed an airplane based at a small airport around here told me the stall warning horn was INOP. The problem was the airplane did not have a stall warning horn, it only had a light. All those points are quite believable and well taken. Link to comment Share on other sites More sharing options...
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