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The most confusing thing about replacing the nose gear bolt...

ChiefPilot

ChiefPilot

Well Known Member
With my condition inspection almost completed, I'm down to the most confusing part. The log book entries.

Here's the deal. I took this opportunity to address the nose gear bolt issue by replacing said bolt with a taper pin. Doing so necessitated the removal of the prop, engine, and engine mount from the airframe so that the hole could be drilled and reamed accurately. Everything was then put back together again at which point the FWF portion of the inspection was done, engine run-up and leak checked, and so on.

I'm not quite sure how to document this in the log. One way would be to simply log something like "Replace AN5 bolt on holding nose gear strut to engine mount" and the opposite extreme would be to detail the whole process. I'm leaning more towards the first end of the spectrum, but am interested in others thoughts.

What do you think?
 
Document,document..

In the certified aircraft world, it is absolute must to document the whole process. As an AP/IA, even on my own RV-4 , I would do the full documentation, including leak/systems checks. Besides the "undocumented maintenance" scenario, it just keeps all your records correct and detailed. If you are the builder, acting under your acquired repairmans certificate, your maintenance should be documented in the same basic format as an A/P would use. If you were to later sell, or task an A/P to take over your maintenance, a detailed log would be much better than a "one line" type entry. I am personally involved with maintaining/inspecting several RV's that were not built by their current owners, and while they can work on them, I definitely want to know and see documentation of what they perform.
 
ChiefPilot said:
I'm not quite sure how to document this in the log. One way would be to simply log something like "Replace AN5 bolt on holding nose gear strut to engine mount" and the opposite extreme would be to detail the whole process. I'm leaning more towards the first end of the spectrum, but am interested in others thoughts.

What do you think?
Click to expand...

Because you have the Repairman's Certificate (which means you are the builder):

"Replace AN5 bolt on holding nose gear strut to engine mount". Period.
 
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Depends

Who was the last documented engine installer?
I don't care to much for people who shortcut the paperwork. It leaves me exposed.
"Gained access by removing engine....Replaced bolt, restored access." record that first, then the inspection. The inspection checklist should cover the installation. If it doesn't, record all the work. This is a legal document. We are left alone to make these entries, because as a group of people, we do it right. I would hate to see what the FAA would put on us if they decide we can't be trusted to do it right.
 
Absolutely agree with the above comments!!!
This is how I would do it, something like:

"removed prop, engine and engine mount to access nose gear leg retainer bolt. Reamed upper nose gear leg bolt hole and engine mount for installation of taper pin, installed pin. Re-installed engine mount, engine and prop. Accomplished ground runs, leak checks and systems operational checks with no discrepancies noted."
 
Walt said:
This is how I would do it...
Click to expand...

Walt and Andrew,
Thanks for the examples. Do you know a source for sample maintenance entries? I'd love to see a one page sheet with a bunch of typical entries I could copy and modify.
 
Andrew M said:
Who was the last documented engine installer?
I don't care to much for people who shortcut the paperwork. It leaves me exposed.
"Gained access by removing engine....Replaced bolt, restored access." record that first, then the inspection. The inspection checklist should cover the installation. If it doesn't, record all the work. This is a legal document. We are left alone to make these entries, because as a group of people, we do it right. I would hate to see what the FAA would put on us if they decide we can't be trusted to do it right.
Click to expand...

Not making a log entry that isn't required per regs is not "shortcutting the paperwork". As long as the holder of the repairman's certificate records that the aircraft is in a condition for safe operation it doesn't matter who installed the engine (or how many times). The non-A&P builder is not putting any A&P at risk while maintaining his own aircraft.

Just because a builder doesn't record maintenance the same way as certain A&Ps doesn't mean he is deficient in record keeping.
 
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Sam Buchanan said:
Not making a log entry that isn't required per regs is not "shortcutting the paperwork". As long as the holder of the repairman's certificate records that the aircraft is in a condition for safe operation it doesn't matter who installed the engine (or how many times). The non-A&P builder is not putting any A&P at risk while maintaining his own aircraft.

Just because a builder doesn't record maintenance the same way as certain A&Ps doesn't mean he is deficient in record keeping.
Click to expand...

Yes it is deficient and yes it does matter. For example, if I do a 'condition inspection' but then the owner decides to do the work above but fails to document it, that makes me the last guy to inspect the aircraft. Now (god forbid) an incident happens that the owner caused, guess who would be in the hotseat with the FAA and his family when everyone decides I caused the 'incident' :eek:

Now it would be up to me to prove that "I didn't do it" which can often be impossible unless someone comes forward and tells the whole story.

The job not done till the paperwork is done, and done correctly.

PS:And I don't care what the reg's say or if that gives you a 'legal" out, you have a responsibility to comply with industry standards both as an airman and a maintenance technician, end of story and off my soapbox for now.
 
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N126AR

This aircraft had fatalities. I did not release the aircraft from inspection, nor did I do much of any work through to the last inspection cycle. I was interviewed about the work I did, inspection before last, that had the wing struts removed for eddy current inspection. The FAA will (and did) dig through the paperwork to find out who has direct knowledge about the work performed. This business can, and does kill people. If I screw up that bad, I want to know so I can go back to washing dishes.
 
Walt, you and Andrew are referring to aircraft that you, as A&Ps, maintain.

That is not the scenario I am referring to, and I am assuming the situation with the original poster involves a repairman's certificate. You have responsibilities as a professional to protect you and your business from liability. In order to do so, you need to follow procedures that are above and beyond what is required by regs for a builder who is doing his own maintenance on his experimental aircraft.

Quoting horror stories about how A&Ps have been hung is dramatic, but it has absolutely nothing to do with how I record maintenance for my own aircraft as the holder of the repairman's certificate for that particular aircraft.

I am in no way advocating sloppy maintenance or record keeping, just pointing out that we have freedoms in experimental aviation that are not present in the certificated world. Just as I strongly oppose rogue DARs imposing rules on us that don't exist, I also oppose those in the certificated community imposing their opinions that are above and beyond what regulates us in the experimental, builder-maintained community.

Walt, you stated "And I don't care what the reg's say or if that gives you a 'legal" out..." That is an interesting statement after your emphasis on following standard protocol.

I care very much what the regs say (and don't say!) and I'm not looking for legal outs. It is each builder's choice as to how they record maintenance as long as they follow the guidelines for stating the aircraft is in a condition for safe operation every twelve months.

Guess my libertarian streak is showing a bit.... ;)
 
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I'm with Sam kinda. If you look at entries by the mfg. for things accomplished before delivery or warranty you'll find them to be pretty terse. Rule one, don't leave out required items. Rule two, don't add unrequired items (its ammunition).
 
aerhed said:
Rule one, don't leave out required items. Rule two, don't add unrequired items (its ammunition).
Click to expand...

Very well stated.

I had a highly experienced A&P/IA tell me years ago to be careful and not put too much in the logs of my experimental aircraft that I maintain. A very fat logbook might make the plane look like a maintenance horror show...
 
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Sam,
I understand where you are coming from, I guess we can just agree to disagree on this one.

Please don take my statements out of context:
"And I don't care what the reg's say or if that gives you a 'legal" out, you have a responsibility to comply with industry standards both as an airman and a maintenance technician, end of story and off my soapbox for now."

The point I was trying to make is that IMO you have a moral and ethical responsibility to make log book entries IAW standard practices and FAA guidelines:

Ref CFR 43.9(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.


I don't believe that "replaced nose gear bolt" is an adequite description of the work performed in this case and is not in the 'spirit' of the rules.
 
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Back to the question that was raised by Brad who started this thread, I agreed that ""Replace AN5 bolt on holding nose gear strut to engine mount" adequately states the maintenance performed.

I would differ with those who think it is necessary to write a novel describing this operation in order to meet experimental, builder-maintained regs or even to demonstrate ethical responsibility. My signature in the logs following the condition inspection implies that all maintenance has been performed in a way that promotes safe operation of the aircraft.

Trying to divine the 'spirit' of regs is a slippery slope open to individual interpretation. I much prefer to be directed by what is actually written (or not written).

I'm confident we all are concerned about protecting the welfare of our families, passengers and our hobby. We just have differing opinions on the mechanics of documenting our efforts. :)
 
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Walt said:
............. if I do a 'condition inspection' but then the owner decides to do the work above but fails to document it, that makes me the last guy to inspect the aircraft. Now (god forbid) an incident happens that the owner caused, guess who would be in the hotseat with the FAA and his family when everyone decides I caused the 'incident' :eek:

Now it would be up to me to prove that "I didn't do it" which can often be impossible unless someone comes forward and tells the whole story. ........
Click to expand...

Walt: First, I GREATLY appreciate your participation on this forum.

Second, I always thought that an A&P or an IA signature in a logbook meant that "At the time I signed this inspection or work off, all was well." One day later something could fail on a plane, that was not "discoverable" during the inspection yesterday. IMHO, the FAA recognizes that fact, and doesn't hold A&P/IA's accountable to predict the future. An annual inspection doesn't guarantee trouble-free operation for another year, or any other indefinite time.

AMT's are held accountable to do the work properly, and in accordance with the regulations. And that's for TC'd aircraft.

Experimental aircraft have no TC or set standards. A condition inspection merely means that in the inspector's opinion, the machine is in a condition for safe operation "At the time the CI was conducted."

Am I missing something?
 
Walt said:
PS:And I don't care what the reg's say or if that gives you a 'legal" out, you have a responsibility to comply with industry standards both as an airman and a maintenance technician, end of story and off my soapbox for now.
Click to expand...

But if we had complied with industry standards we wouldn't need the placard on the instrument panel that the FAA mandates? :D. Sorry couldn't pass this up.
 
Why the rules?

I think they are to aid the FAA in determing what happened when things go bad. I have been called to account a few.times in my carreer, and although the law offers some protection in deteriming who is ultimatly resposible, it ( who is legally resposible) does't allways.lead the investigators to exactly why something went bad. The FAA understands that I trust the people who worked on an aircraft before me, and my experiance in this specific matter with an FAA investigation kept them from violating me, even though they legally could. Maintenance history led then to the guy that.actually did the work. My PM with Sam shed some light on th?s topic. I will avoid working on AB aircraft that.do not have enough maintenance history. My expectation has allways been that I need to kn?w whats been done. Besides, I am pulling in a good income in a well supplied shop, and have complete spending authrity. Something that is rare in Part 91 or the AB world.
Like my dad once told me, I'm not charging for this insight, so it's either priceless, or worthless.:)
 
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Wow, thanks for all the great discussion. At the very least, I don't feel bad knowing that even greatly respected folks within the VAF community have different opinions on this topic :)

A further question regarding an alternator belt: should this be a separate entry? Since the prop was off, I thought that I might as well replace the alternator belt since the old one had two years / 390 hours on it. Would you expect to see this as it's own line item, or could this be "Replace mount, engine, and installed new alternator belt Napa PN#xxxx. Installed prop, ..." ?
 
PCHunt said:
Second, I always thought that an A&P or an IA signature in a logbook meant that "At the time I signed this inspection or work off, all was well." One day later something could fail on a plane, that was not "discoverable" during the inspection yesterday. IMHO, the FAA recognizes that fact, and doesn't hold A&P/IA's accountable to predict the future. An annual inspection doesn't guarantee trouble-free operation for another year, or any other indefinite time.

Am I missing something?
Click to expand...

The above is absolutely true, but if Joe Blow pulls the engine and prop and forgets to install the cotter pins in the throttle linkage (or a hundred other things) that I should have inspected, then that ball would be back in my court.

If you are going to work on aircraft then you need to take responsibility for and document the work you performed, "one word" signoffs are not considered a complete description of the work performed.

Been down that road with the FAA and I can tell you that a sign-off like that on a certified aircaft would be a clear violation, and it should be.
 
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ChiefPilot said:
Wow, thanks for all the great discussion. At the very least, I don't feel bad knowing that even greatly respected folks within the VAF community have different opinions on this topic :)

A further question regarding an alternator belt: should this be a separate entry? Since the prop was off, I thought that I might as well replace the alternator belt since the old one had two years / 390 hours on it. Would you expect to see this as it's own line item, or could this be "Replace mount, engine, and installed new alternator belt Napa PN#xxxx. Installed prop, ..." ?
Click to expand...

If it was all done at the same time then it's all in one single entry.
 
Walt said:
This is how I would do it, something like:

"removed prop, engine and engine mount to access nose gear leg retainer bolt. Reamed upper nose gear leg bolt hole and engine mount for installation of taper pin, installed pin. Re-installed engine mount, engine and prop. Accomplished ground runs, leak checks and systems operational checks with no discrepancies noted."
Click to expand...

Not an A&P, but I am an engineer, so the only thing I would add to the above is the process used to do the work. I would add a phrase like "installed taper pin per AC 43-13 1b"
 
I used to be in Walt's camp until a couple run-ins with the FAA. I still agree that a "description of work accomplished" is required, but am very careful with the description. Many years I've done over two dozen annuals and never had to do anything else for recurrency. This year I decided to sit through AMT's online recurrency. A lawyer lady did 3 of the seminars and I started out annoyed with the lawyer talk. Then I started listening. She said things like never sign off "performed SB in accordance with". Instead say " did such and such REFERENCING SB such and such. Words are legal traps that can hang you in todays world. The wrong words can make you legally responsible for things you haven't touched. You can put yourself on the hook for things you never imagined.
 
aerhed said:
I used to be in Walt's camp until a couple run-ins with the FAA. I still agree that a "description of work accomplished" is required, but am very careful with the description.
Click to expand...

Don't get me wrong, I never advocated that you need to write a novel about the work you did, just a clear description of the work accomplished, no more no less.
 
Sam Buchanan said:
Because you have the Repairman's Certificate (which means you are the builder):

"Replace AN5 bolt on holding nose gear strut to engine mount". Period.
Click to expand...
Sam, You keep referring to the "Builder" in these posts. I understand that having the Repairman's Certificate would mean you are the builder, but what is the difference between documenting the same maintenance performed by the builder as opposed to a "non-builder owner"? The ONLY difference I see is that the holder of the Repairman's Certificate can sign off the Condition Inspection.
Thanks. Good dialog here.
 
flytoboat said:
Sam, You keep referring to the "Builder" in these posts. I understand that having the Repairman's Certificate would mean you are the builder, but what is the difference between documenting the same maintenance performed by the builder as opposed to a "non-builder owner"? The ONLY difference I see is that the holder of the Repairman's Certificate can sign off the Condition Inspection.
Thanks. Good dialog here.
Click to expand...

The non-builder owner is going to have an A&P in the maintenance loop, and the A&P is understandably going to have his ideas on inspection and log entries. Most likely those will be driven by how he performs inspections in the certificated environment.

My comments were in regard to a builder who possesses the Repairman's Certificate and is the only individual involved in maintaining the aircraft. In this case, when I sign the logs for the Condition Inspection, no A&Ps are put at risk, all responsibility is on my shoulders due to the unique flexibility we have with EAB aircraft. By recording that the aircraft is in a condition for safe operation I am implying that all maintenance I have performed is such that the safety of the aircraft has not been compromised.

This may come as a shock to many, but EAB only requires one entry per twelve months in a logbook.....the one that states a Condition Inspection has been satisfactorily completed. Anything we add to this requirement is just a memory aid to help us keep up with how long components have been in service, service intervals, etc. Of course, records will be reviewed by a prospective buyer, but the extent of those records are at our discretion.

This is a fine point but one that was getting muddled when A&Ps in the discussion were stating how they felt records should be maintained in order to protect their business, and by extension how EAB records must be created in an identical manner. But I am in a different environment as a non-professional who isn't trying to protect a business. I can meet the recording requirements of EAB without necessarily going to the lengths the professional in the certificated world would find necessary.

The flexibility we have in EAB is daunting to many with backgrounds in the certificated world, but liberating to many of us immersed in EAB. :)
 
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Well said Sam. You have always been a voice of reason on this forum. There are many more A/P's chiming in these days muddying up the EAB waters needlessly.
Thank you!
 
Sam Buchanan said:
.....

This may come as a shock to many, but EAB only requires one entry per twelve months in a logbook.....the one that states a Condition Inspection has been satisfactorily completed. Anything we add to this requirement is just a memory aid to help us keep up with how long components have been in service, service intervals, etc. Of course, records will be reviewed by a prospective buyer, but the extent of those records are at our discretion.

...
Click to expand...

Sam,

Do the usual EAB Operating Limitations specifically excuse the EAB owner from the requirements of tis FAR?

§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.

......


Just for completeness, this is the Applicability paragraph for the above FAR section -


§91.401 Applicability.

(a) This subpart prescribes rules governing the maintenance, preventive maintenance, and alterations of U.S.-registered civil aircraft operating within or outside of the United States.

........


Also note that 91.409 "Inspections" in the same subsection does specifically exclude EAB aircraft by way of their Experimental certificate.


I would think the bold ones above would be applicable to EAB aircraft.

Note also that the word "logbook" is only a convenience we use. The FAA usually uses the term "aircraft records".
 
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Sam Buchanan said:
This is a fine point but one that was getting muddled when A&Ps in the discussion were stating how they felt records should be maintained in order to protect their business, and by extension how EAB records must be created in an identical manner. But I am in a different environment as a non-professional who isn't trying to protect a business. I can meet the recording requirements of EAB without necessarily going to the lengths the professional in the certificated world would find necessary.

The flexibility we have in EAB is daunting to many with backgrounds in the certificated world, but liberating to many of us immersed in EAB. :)
Click to expand...

Good record keeping personifies the professionalism of the person doing the maintenence. The log record that has one stamp in it a year for the "inspection" raises a big red flag.

jthocker said:
Well said Sam. You have always been a voice of reason on this forum. There are many more A/P's chiming in these days muddying up the EAB waters needlessly.
Thank you!
Click to expand...

"Muddying up the waters"... I don't look at it that way, I think many/most folks are looking for what is the "normally accepted" way to maintain aircraft records. Records are a history of the aircraft and ducument the care and maintenance of the machine.

I think the real "muddying of the waters" is the mindset that because its not required by the devil (FAA) I don't/won't do it and the paperwork is really not that important.
 
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az_gila said:
Sam,

Do the usual EAB Operating Limitations specifically excuse the EAB owner from the requirements of tis FAR?

<Big snip>

Also note that 91.409 "Inspections" in the same subsection does specifically exclude EAB aircraft by way of their Experimental certificate.
Click to expand...

Gil, I think the case can be made that because the EAB Op Lims specifically call out an inspection protocol unique to aircraft with experimental airworthiness certificates that FAR 91 is excluded by our operating limitations.

Walt said:
Good record keeping personifies the professionalism of the person doing the maintenence. The log record that has one stamp in it a year for the "inspection" raises a big red flag.



"Muddying up the waters"... I don't look at it that way, I think many/most folks are looking for what is the "normally accepted" way to maintain aircraft records. Records are a history of the aircraft and ducument the care and maintenance of the machine.

I think the real "muddying of the waters" is the mindset that because its not required by the devil (FAA) I don't/won't do it and the paperwork is really not that important.
Click to expand...

Walt, I agree that the mindset you describe is unproductive and I hope you do not think that is what I have been advancing. I also agree that if I was purchasing an RV, a logbook with only one entry per year would indeed raise red flags. But it would be legal.

Having said all this, the RV-6 I built and have been flying for 16 years has a good set of records. When the engine was rebuilt the A&P and I discussed this situation and decided it would be in my best interest for future sale of the aircraft to include a comprehensive recording of the work performed and all the yellow tags. But that was at my discretion, not because it was required by regulation.

Please don't assume that just because I have attempted to explore the regs that govern our aircraft, and because I may have speared a few sacred cows that I am advocating sloppy record keeping or an attitude of cutting corners.

In this era where RVs have almost become a 'certificated' aircraft due to popularity, purchase by non-builders, and increasing maintenance by A&Ps, we must be very careful to not let the camel get his nose under the tent. We don't want to give away the wonderful flexibility we have with the EAB rule.
 
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The key word in all of this is "Experimental"!
At least in this wonderful country, we are FREE to experiment with our aircraft or any other experimental aircraft. I for one have been modifying my aircraft continuously for the 6+ years it's been flying. If I had to "return to service" with the proper documentation every single time I tried something I would need dozens of logbooks and a secretary to keep up with the paperwork.

The Libertarian in me wishes to keep the camel out of the tent.

Excellent and methodical records may very well increase the value of your RV, but they are by no means REQUIRED.
 
Very true!!

"Excellent and methodical records may very well increase the value of your RV, but they are by no means REQUIRED."

To each their own. As a buyer of experimental aircraft, the lack of good well documented records is certainly one indicator I look for during a purchase inspection. If they are well documented and in order, then it is easy to correlate them to the work performed on the aircraft and helps simplify the visual inspection as well. If there is little or only mandatory documentation then it is always problematic in determining what work has actually been performed on the plane and who did it since the DAR signed it off. ie: when and how often was the oil changed? Was the filter changed at the same time? etc.

If you aren't concerned about your resale value, or you are a true experimenter and are always changing things and want to take the minimalist approach that is your prerogative. One helpful thing about a good set of records is that when future maintenance is required you will know the life of the component being replaced, part numbers etc. and even when the last time normal maintenance functions were performed. At my advanced age I tend to forget or loose track of when I actually performed various maintenance functions so a quick scan of the record from the comfort of the office is a heck of a lot easier then removing the cowling to look at the hobbs time or date written on the filter or the trend of cylinder leak down.

I am concerned that in the long run with the ever growing popularity of experimental aviation, especially where folks are having EAB planes built by others with the documents showing otherwise, the lacking or total disregard for good maintenance or the utilization of non-aviation parts in important areas, lacking documentation etc. that we may see this amazing privilege we have in experimental fade away by regulation.

Just my $.02.
 
Sam Buchanan said:
Gil, I think the case can be made that because the EAB Op Lims specifically call out an inspection protocol unique to aircraft with experimental airworthiness certificates that FAR 91 is excluded by our operating limitations.

......
Click to expand...

Sam,

That is stretching an opinion on how to void a specific FAR....:)

Since you make that case, what is the current wording about inspections in typical Operating Limitations.

And yes, the FAR does talk about records retention, but how can you retain them if you don't make them?

91.419 specifically has wording exempting EAB aircraft from the annual and 100 hr inspection requirements.... but that is all...

...
c) Paragraphs (a) and (b) of this section do not apply to--
[(1) An aircraft that carries a special flight permit, a current experimental certificate, or a light-sport or provisional airworthiness certificate;]
...

As far as I can tell, that is the only specific exception to this subsection of FARs on Maintenance...

I tried to get an official word from the EAA on this with reference to one of their web articles but never got a response, despite repeated attempts.

Sam, you said this to Walt...

Walt, I agree that the mindset you describe is unproductive and I hope you do not think that is what I have been advancing. I also agree that if I was purchasing an RV, a logbook with only one entry per year would indeed raise red flags. But it would be legal.

Is your definition of "legal" based on "the case can be made"?
 
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Gil, I have stated my position on these matters. :)

I'm not imposing my opinion on anyone. As far as I am concerned, each builder is free to handle this as they feel is appropriate.
 
jthocker said:
The key word in all of this is "Experimental"!
At least in this wonderful country, we are FREE to experiment with our aircraft or any other experimental aircraft. I for one have been modifying my aircraft continuously for the 6+ years it's been flying. If I had to "return to service" with the proper documentation every single time I tried something I would need dozens of logbooks and a secretary to keep up with the paperwork.

The Libertarian in me wishes to keep the camel out of the tent.

Excellent and methodical records may very well increase the value of your RV, but they are by no means REQUIRED.
Click to expand...

Just to add another wrinkle to the discussion...I keep "records" of pretty much everything, but they're not in a logbook. For example, I do oil analysis at every oil change. The reports include time on the oil, Hobbs time, sample date, etc. It's a nice, comprehensive set of data for a routine maintenance item. A "record", if you will.

Now, given that I keep these electronically and in printed form in a 3-ring binder, I say that ought to be sufficient for that maintenance item.

Likewise, I keep receipts for all repaired/replaced parts; serial numbers and install dates for *every* serialized item on the plane (in a spreadsheet), etc. In fact, I have receipts for every item ever purchased for the airplane (I'm starting the 3rd 3" binder now :eek:).

But my *aircraft logbook* contains only the required entries, nothing more (same for propeller logbook...installation date, required lubrications).

Since I'm never, ever, ever selling my baby, this is good enough for me :)
 
Sam Buchanan said:
Gil, I have stated my position on these matters. :)

I'm not imposing my opinion on anyone. As far as I am concerned, each builder is free to handle this as they feel is appropriate.
Click to expand...

Sam, I'm not trying to pick on you...:)

But it would be nice to get some sort of official ruling or interpretation for such an important issue. I had hoped the EAA would do that.
 
az_gila said:
Sam, I'm not trying to pick on you...:)

But it would be nice to get some sort of official ruling or interpretation for such an important issue. I had hoped the EAA would do that.
Click to expand...

OK, how about this. My long time FSDO inspector that has been certifying experimentals in the Cincinnati area for well over 30 years and is quite well versed in these particular regs. has always advised us that the only required logbook or Maintainance entry is the condition inspection. He advocates keeping and logging whatever else we want, but all that is required is the condition sign off. Period!

Just this fall at The Great Georgia Air Show I was "detained" by an FAA Maintainance inspector who cited the exact regs that Gil is quoting. I told him he was wrong (this really pissed him off), and he immediately called Ok City.
He wound up be severely chastised for infringing on my pre air show routine and also for not knowing the regs as they pertain to Experimentals.

So, if you choose to "over interpret" the regs be my guest
 
probably off topic

Can I specify who and how maintenance is done in the Ops Specs? I could conceivably give any future owner the authority to do the maintenance, AND/OR require records be kept to a more restrictive level (for lack of better term) This could increase the value of my aircraft.
 
Andrew, you are talking terms and concepts that don't apply to EAB. :)

Andrew M said:
Can I specify who and how maintenance is done in the Ops Specs?
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You can specify maintenance and/or records as narrowly as you wish.....but, No, it won't have any regulatory consequences or weight. EAB doesn't have a document called Ops Specs.

I could conceivably give any future owner the authority to do the maintenance, AND/OR require records be kept to a more restrictive level (for lack of better term) This could increase the value of my aircraft.
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ANYBODY already has the authority to perform ANY airframe and powerplant maintenance they want (this is a stunning concept at first glance, but the key to us being able to be experimental), but only a Repairman Certificate holder or A&P can endorse the records for the Condition Inspection.

And I believe we have already discussed the records. :)
 
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jthocker said:
OK, how about this. My long time FSDO inspector that has been certifying experimentals in the Cincinnati area for well over 30 years and is quite well versed in these particular regs. has always advised us that the only required logbook or Maintainance entry is the condition inspection. He advocates keeping and logging whatever else we want, but all that is required is the condition sign off. Period!

Just this fall at The Great Georgia Air Show I was "detained" by an FAA Maintainance inspector who cited the exact regs that Gil is quoting. I told him he was wrong (this really pissed him off), and he immediately called Ok City.
He wound up be severely chastised for infringing on my pre air show routine and also for not knowing the regs as they pertain to Experimentals.

So, if you choose to "over interpret" the regs be my guest
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I don't really want to over-interpret the regs...:)

I just wish it was more defined in writing somewhere - especially since it affects so many owners now the EAB group is getting larger year by year...
 
Sam Buchanan said:
"Replace AN5 bolt on holding nose gear strut to engine mount". Period.
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This is what you advocated at the beginning of this tread and really what started this whole mess.

Sam Buchanan said:
Walt, I agree that the mindset you describe is unproductive and I hope you do not think that is what I have been advancing. I also agree that if I was purchasing an RV, a logbook with only one entry per year would indeed raise red flags. But it would be legal.

Having said all this, the RV-6 I built and have been flying for 16 years has a good set of records. When the engine was rebuilt the A&P and I discussed this situation and decided it would be in my best interest for future sale of the aircraft to include a comprehensive recording of the work performed and all the yellow tags. But that was at my discretion, not because it was required by regulation.

Please don't assume that just because I have attempted to explore the regs that govern our aircraft, and because I may have speared a few sacred cows that I am advocating sloppy record keeping or an attitude of cutting corners.
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But now you say you don't really advocate this, and in any case don't actually follow the advice you gave to others, I'm confused :confused:
 
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This has been a great discussion - thanks to everyone!

So I finally closed out the books on my condition inspection last night. I think I'll refrain on sharing what I ended up doing since there would likely be bricks flying in from some corners of the room :D

In all seriousness, I ended up logging a minimal amount in the log books not because I was trying to save time but because I had written most all the activities down on the condition inspection checklist (which is 10 pages in length, with spaces for notes on each page). The actual entry for the taper pin was along the lines of "Removed prop, engine, and mount. Replaced AN5 bolt securing nose strut to engine mount with AN 4-13 taper pin. Reinstalled engine mount and engine. Replaced alternator belt with NAPA Part 16350, then reinstalled prop. Run up and leak check ok."

There's lots more information in the maintenance records, which include the condition inspection checklist and notes. That the maintenance records include more than just the log books was something I think I knew but had forgotten.
 
az_gila said:
I don't really want to over-interpret the regs...:)

I just wish it was more defined in writing somewhere - especially since it affects so many owners now the EAB group is getting larger year by year...
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Gil,
I spent 3 hours yesterday trying to find a logical sequence in the regs to backup my argument. It is extremely confusing to go back and forth, and I finally gave up. I kept getting pulled back to the one you cited. I knew there was a reason it didn't apply, I just couldn't find it quickly. I'm not interested in looking any further, but I will ask my FAA guy when I see him again.
 
ChiefPilot said:
This has been a great discussion - thanks to everyone!

So I finally closed out the books on my condition inspection last night. I think I'll refrain on sharing what I ended up doing since there would likely be bricks flying in from some corners of the room :D

In all seriousness, I ended up logging a minimal amount in the log books not because I was trying to save time but because I had written most all the activities down on the condition inspection checklist (which is 10 pages in length, with spaces for notes on each page). The actual entry for the taper pin was along the lines of "Removed prop, engine, and mount. Replaced AN5 bolt securing nose strut to engine mount with AN 4-13 taper pin. Reinstalled engine mount and engine. Replaced alternator belt with NAPA Part 16350, then reinstalled prop. Run up and leak check ok."

There's lots more information in the maintenance records, which include the condition inspection checklist and notes. That the maintenance records include more than just the log books was something I think I knew but had forgotten.
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Brad, I'm only going to toss a rocking chair cushion at you! :D :D

I think your log entry is very reasonable. Hope the nosegear gremlin has now been exorcised from your plane. Enjoy!
 
I've followed this thread and I agree with what Jon and Sam has said. I've had the same FAA Inspector as Jon has, and reiterate what he has told all of us in southwestern Ohio. Signed logbook entries are required for condition inspections, or modifications to your original aircraft that would require re-entering phase I, such as replacing your Lycoming with a Subaru engine. Any other general maintenance or repair doesn't require a signed logbook entry for non-type certificated aircraft. He does recommend UNSIGNED logbook entries for routine maintenance, such as oil changes, or tire replacement, but this is just a good idea for continuity and it's not required.

If the only reason for making detailed and unnecessary logbook entries is to enhance resale, I guess I would have to question your reasons for building in the first place. We are not supposed to replace Cessna and Beechcraft in our endeavor to build airplanes. It's supposed to be for our own education and enjoyment. That is the essence of EAB. It's also why we are not required to keep such extensive records. We are not trying to protect the innocent buying public like the certified builders are, because that isn't who we are building our airplanes for....... right?
 
For amateur built aircraft, this subject of logbook entries is covered very well. Your Operating Limitations specify what logbook entries and/or any specific task within the FARs that need to be complied with, as specified in FAA Order 8130.2G, paragraph 4104. Paragraphs 9, 22 & 23 are the ones I have chosen that are more specific to the task that are required for continued airworthiness after Phase 1.

14 CFR Part 43 paragraphs 9 & 11 which covers the contents of what should be contained within logbook entries IS NOT applicable to Amateur Built aircraft. Paragraph 43.1 is very clear and supports what I have said.

The "Feelings" of what should be documented should be stated as such versus making them seem Regulatory.

Personally when I'm complying with an annual on a certified aircraft I do review the logbooks for a historical record, but it is my flashlight and mirror that I'm more concerned with while accomplishing the inspection. I have seen "pretty" logbooks on aircraft that I would not put my name in.

If I have misstated something or overlooked a reference please correct me and provide the reference to the regulation I missed for my own future knowledge.
 
Fantastic Discussion . . . of Titans!

This thread really shows that this forum and the professionalism of the members with very different backgrounds and experiences can have a reasonable discussion with differing, seemingly clashing, points of view.

Sam, Walt, John, and Gil - - thanks particularly for bringing particular points of view to light for us to think about. Sometimes there are clear cut answers, many times not. I know we (forum and industry novices) would always like a black and white answer, but many things deserve discussion to understand the complexity and the simplicity at the same time.

Having served in managing many engineers that worked with many union personnel to complete projects, I found it daunting to step on both sides of the fuzzy lines of "rules" , "intent" and "guidelines". Everybody wanted no rules, (at times) and be allowed to use their judgement instead, then when an unpleasant event occurred, even those of us who wanted to avoid "rules" were magnetically drawn into that line of discussion. It always took differing points of view to see the whole picture.

Throwing out the "rulebook" (Experimental) often leads to the same discussions that resulted in developing the "rules" (certified world). It is refreshing that we can do that and still get along. Imagine the same discussions within the FAA, and yet we still have the experimental category. Those must be some very interesting meetings . . .

Thanks !!
 
curtis said:
For amateur built aircraft, this subject of logbook entries is covered very well. Your Operating Limitations specify what logbook entries and/or any specific task within the FARs that need to be complied with, as specified in FAA Order 8130.2G, paragraph 4104. Paragraphs 9, 22 & 23 are the ones I have chosen that are more specific to the task that are required for continued airworthiness after Phase 1.

14 CFR Part 43 paragraphs 9 & 11 which covers the contents of what should be contained within logbook entries IS NOT applicable to Amateur Built aircraft. Paragraph 43.1 is very clear and supports what I have said.

The "Feelings" of what should be documented should be stated as such versus making them seem Regulatory.

Personally when I'm complying with an annual on a certified aircraft I do review the logbooks for a historical record, but it is my flashlight and mirror that I'm more concerned with while accomplishing the inspection. I have seen "pretty" logbooks on aircraft that I would not put my name in.

If I have misstated something or overlooked a reference please correct me and provide the reference to the regulation I missed for my own future knowledge.
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Thank you.

In 40+ posts that is the first one that actually gives useful references to FAA documents...
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The only question I would have remaining is if this Op Limitation overrides the ones you reference..

(1) No person may operate this aircraft for other than the purpose of meeting the
requirements of 14 CFR ? 91.319(b) during phase I flight testing, and for recreation and
education after meeting these requirements as stated in the program letter (required by
14 CFR ? 21.193) for this aircraft. In addition, this aircraft must be operated in accordance with
applicable air traffic and general operating rules of 14 CFR part 91 and all additional limitations
herein prescribed under the provisions of 14 CFR ? 91.319(i). These operating limitations are a
part of FAA Form 8130-7, and are to be carried in the aircraft at all times and be available to the
pilot in command of the aircraft.


But this is a much closer discussion....:)

Again, I'm still surprised the EAA hasn't helped all of the builders/owners out on this one that affects so many aircraft.
 
Gil,

The paragraph you referenced is paragraph 1 of the Order I referenced. I didn't compare them word for word on my iPad but they looked the same.

Curtis
 
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