Roger Lee Posted April 8, 2015 Report Share Posted April 8, 2015 Bob, "The issue at hand is the merits, or lack there of, of logging more than the required inspection sign-off into the aircraft logbook" You are right I'm not always right and to learn is how well we are will to commit and have a passion of learning and for us here it is respecting each other and sharing our many years of accumulated knowledge. These guys I have been debating with (on any subject actually not just documentation) I highly respect their knowledge and believe these guys are all sharp and have something to contribute, but none of us got here without questioning ourselves and others and and then sharing those ideas. I have never been mad at a single sole here. There are minimum standards (that's your requirement) that the FAA has posted, but there is no cap and does in fact encourage more. So this becomes a personal preference. For example: Even though Tom and I don't share the same documentation style I have the upmost respect for him and and he's is one of the sharper LSA people in the field and I always enjoy our debates or information sharing. The same holds true for Eddie and many others here. Great people. We are all made better by the sum of our knowledge and our existence here on our forum. Don't confuse passion and commitment for anger, resentment or condescension. Link to comment Share on other sites More sharing options...
Roger Lee Posted April 8, 2015 Report Share Posted April 8, 2015 Hi Eddie, There was this mechanic in either Washington or Oregon that was my hero. He always bought his clients a 3 ring binder. If he did anything to fix something, take it apart or it had a flaw he took pictures. He then put all these pictures in the binder with an explanation of each picture and fix. It was unbelievably well documented and professionally done. Compared to this guy we are all slackers. Link to comment Share on other sites More sharing options...
Tom Baker Posted April 8, 2015 Report Share Posted April 8, 2015 Even though Tom and I don't share the same documentation style I have the upmost respect for him and and he's is one of the sharper LSA people in the field and I always enjoy our debates or information sharing. The same holds true for Eddie and many others here. Great people. Roger, my point of view is that you shouldn't dog people for having a short inspection signoff, because that is what the CFR's call for. What you should be dogging them about is logging maintenance as required by the regulations. I have never said maintenance items performed shouldn't be logged, just that they shouldn't be logged in an inspection signoff. Again this is based on the regulations. Bob, CFR 43.9 requires that any maintenance performed on a aircraft be logged. This is separate from the required inspection signoffs, which the regulation say should be brief. Link to comment Share on other sites More sharing options...
Roger Lee Posted April 8, 2015 Report Share Posted April 8, 2015 Hi Tom, I'm not trying to dog them per say, but get some mechanics that ONLY use three liner annual logbook entries to add more meat and detail. I don't actually care if they want to use two or more entries or labels. It's the 3 liner without any other entries that bugs me. When I was researching an article the FAA didn't care either so long as someone has some detail. One FAA top LSA person told me they would love to change the minimum required standard that was written years ago, but that won't happen. Too much work and politics. Sometimes I think we want to pick apart and try to dissect a rule or code way past the point of it's spirit and original intent. Over the last 10 years I get these planes in with only that three liner and minimally required logbook statement. It says IAW, but you have no idea what was done. So I tend to call these guys and ask if certain procedures were done. Number one answer is "I didn't know I had to do that" or I didn't know about that bulletin or what check list." So it really wasn't done IAW. At least when you see a detailed entry you have some clue to what might have been done or addressed. So for people like you and I now we have to go back and look up everything and question all the other work and even how it was done. Link to comment Share on other sites More sharing options...
FastEddieB Posted April 8, 2015 Author Report Share Posted April 8, 2015 Hi Eddie, ...If he did anything to fix something, take it apart or it had a flaw he took pictures. He then put all these pictures in the binder with an explanation of each picture and fix. It was unbelievably well documented and professionally done. Compared to this guy we are all slaggers. Well, I do tend to take a lot of photos when I do maintenance - sometimes to post here, sometimes to remember how something looked before disassembly, the nature of a repair or issue - that sort of thing. Then, in iPhoto I give it a keyword of "Sky Arrow" and have a smart album of those. Just a few here: (click to enlarge) Not to say I'm not still a slagger! Link to comment Share on other sites More sharing options...
Anticept Posted April 8, 2015 Report Share Posted April 8, 2015 To be honest roger, that sounds like the FAA needs to do some counseling for those mechanics. I don't think changing the logging requirements will do anything; it's an attitude problem at it's core. People like them are going to end up getting type ratings on our mechanic certificate, which means a lot more overhead. Anyways, I think the regs for logging are fine the way they are. When we start tacking on extra requirements, it puts limits on entries and such that really are just a simple 3 liner. Link to comment Share on other sites More sharing options...
Roger Lee Posted April 8, 2015 Report Share Posted April 8, 2015 Hi Corey you nailed it on the head. Bingo! "it's an attitude problem at it's core." Link to comment Share on other sites More sharing options...
Doug Hereford Posted April 8, 2015 Report Share Posted April 8, 2015 I don't mean to belabor this point (wanted to start a new thread but apparently don't know how). Record creating vs record keeping......... It is worth mentioning, that there is a difference between what records we as maintainers are required to create (43.9 and 43.11), and what records owners are required to retain (91.417). If one reads the latter rule, you might be surprised at how abbreviated this requirement is when compared to the tribal knowledge that is out there. I have to disagree just a little bit with the notion that perceived poor record keeping is mostly about attitude. At least I don't think it is about poor attitude from mechanics and repairmen (owners maybe). If one really studies the requirements for what, when, who, and how long with regard to maintenance records, they make a lot of logical sense. Do I as an owner, or prospective buyer, or maintenance provider really care about the last ten years of oil changes? Do I really care about the last ten years of compression check results? Do I even really care about the last ten years of condition inspections? What I really care about is the aircraft's current maintenance status. All that said, two things that I have advocated for with my customers over the years is routine oil analysis and vibration spectrum analysis (by product of propeller balance procedure). Mind you, that these items are rarely ever a regulatory requirement in the standard world, and not at all (as far as I know) in the LSA world. These are in my opinion, two exceptions where trend data has some legitimacy (so long as a base-line can be referenced to). I can count on one hand the number of times in the last 25 years, that I have called a previous maintenance provider, and gotten information that was actually useful and relevant to what I was doing, and the question I had. Even when I did, it was still just hearsay at that point. It was still my judgment that was to prevail in the specific situation When an aircraft is sitting in my shop for a required inspection, do I really care whether the last one was overflown, or what the previous inspector had to say? I personally don't, because I am about to embark on my own fact finding expedition to make my own determination as to the aircraft's current ability to be "approved for return to service" (yes, SLSA aircraft are also approved for return to service). I do get very frustrated with the general lack of record keeping regarding Alterations, Airworthiness Directive, Safety Directive and Airworthiness Limitation status (these are owner responsibilities by the way, 91.417). As an inspector however, even if the previous mechanic or repairman created the most beautiful compliance status sheet for these items, I will never trust that it is correct, because the regulations won't let me (and more importantly, my honor won't either). As far as the use of the abbreviation I.A.W. ("in accordance with" is the popular definition). I have absolutely no problem with its use, and find myself employing it most of the time. My reason for this is as simple as understanding 43.9, 43.11 and 43.13. If we are performing maintenance, we must be performing it I.A.W. a procedure. Unless that procedure was passed on verbally from someone (accepted source) or skywritten, or written in the sand, then it must be documented somewhere. Why would I waste my time transcribing this procedure, when the regulation gives me full latitude to REFER to it. Also, much less liability in my opinion (previous post mentioned omissions). If I used the manufacturers maintenance/inspection procedure (as I must do in SLSA), then the reference is also some evidence that I have complied with my part 65 requirement (65.107 repairmen, 65.81 mechanics) to understand the manufacturer's instructions and manuals for the operation concerned. I also somewhat disagree on the position that merely complying with the regs. puts one at additional liability in an incident or crash. We are in a performance based system. If you do something improperly, or not at all, it will not matter much whether you record was just legal, or "went the extra mile". If it turns out that you are to blame, there will be consequences (as there should be). I understand if someone is just stuck in their ways, and has no plans to change, but I would challenge anyone who is interested, to spend some time and read 43.9, 43.11, and 91.417. Then think about why these rules might be written the way that they are (from a practical point, not legalese), you know.................................................."the spirit of the rule". I have said before, and I will repeat. I am not advocating for discarding any records (even through 91.417 allows the owner to do this). All I am saying is that while everyone is entitled to their opinion, I do get a little "back on my heels" when an authoritative tone is taken, and more importantly if blatant misinformation is given without clarification or correction. Doug Hereford Link to comment Share on other sites More sharing options...
Roger Lee Posted April 8, 2015 Report Share Posted April 8, 2015 The one thing I see here is just what the aviation instructor at our college told me a few hours ago when I talked to him about this was; Old teachings versus new teachings. One instructors philosophy versus the other. Like he said neither is right and neither is wrong. Link to comment Share on other sites More sharing options...
Doug Hereford Posted April 9, 2015 Report Share Posted April 9, 2015 Roger, I don't think that the positions I outlined are "old" teachings. They are not really teachings at all per se. Just well understood interpretation across the industry. Still waiting on a clarification for your "return to service" comment earlier to Fast Eddie. How is it that LSA aircraft are not "returned to service" exactly? What did you mean by that? Doug Hereford Link to comment Share on other sites More sharing options...
Roger Lee Posted April 9, 2015 Report Share Posted April 9, 2015 Hi Doug, After an annual condition inspection you can not return the aircraft to service. It must be found in a safe condition for operation. The sentence structure can vary some, but this is all over the web and has been for years. There are examples from all the aviation industries and the FAA. Something similar to this, but doesn't have to be exact. This is taught in all LSA schools, but not all A&P's know this. "I certify this aircraft has been inspected within the scope and detail of the Gobosh and Rotax maint. manuals and it was found to be in a safe condition for operation." Here is Eddie's logbook entry. (see his top page) He has it right. This is what I find many A&P's don't know. Link to comment Share on other sites More sharing options...
Anticept Posted April 9, 2015 Report Share Posted April 9, 2015 Appendix D is not legal to use with S-LSA (I don't have an airworthiness limitations section for an E-LSA, so I can't comment), and I wouldn't put that in there. Not even with the "or manufacturer's inspection procedures" statement. It implies that you MIGHT have used App D. As for the similarly worded statement, this actually is known for years Roger, and is taught that it CAN vary for any aircraft certification, in any A&P School worth it's salt. As an example, 43.11 (a)(4) for standard certificated aircraft: "Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.” With that said, I do often find small little customizations to the statement, but the bolded words are very often considered the most important parts and cannot be left out. Most mechanics tend to just write it the way they have been taught. The problem, Roger, is that a lot of the A&Ps that you are referring to are taught on the job that "This is how it's always been done", so habits, both good and bad, are being passed down. This is especially unfortunate since competition is fierce between maintenance shops, and in some of those said shops mechanics are being rushed to get it done for the cheapest rate possible, or the owner will find someone else. So, things like taking the time to read and familiarize oneself with the manual and the procedures contained within is sometimes pushed off in favor of "just get it done and figure it out as you go". On another note, you can become an A&P by going to school, OR working in the field for ~3 years and then go and take the tests. To my knowledge, you must take schooling to be an LSA repairman. This might also be where some of these bad habits develop too. You've got a hell of a reputation, Roger, and because of that, you are only seeing one side of the spectrum. You have safety conscious people coming to you from everywhere because they want it done right. But, I'd be so bold to say, for every person who wants it done right, there's 5 who just want it done cheap, and because of that attitude, it allows crappy mechanics to continue thriving in the field. Therefore, as owners, what we are get is what we deserve. Basically, if I want to be safety conscious, it's going to cost me more, but I get the safety that comes with it. If I cut corners, then it's my fault if I get hurt (hope no one else gets hurt though). This is, after all, the motivation that both of us had to become mechanics per our phone conversation: we both want to do it right, not just what is quick! I see people who want it done cheap a LOT. There are quite a few airplane owners who should NOT own airplanes, in my opinion. If I may ask, Roger, I know you don't mean to bash some of the A&Ps here that do try to do things right, but you do repeatedly imply it's because they are an A&P, they are somehow inferior. I've seen repairmen who do crap jobs too. Instead, I'd say that you should refer to the group of people causing problems in the first place by referring to them as "bad mechanics". It's not just A&Ps who develop bad habits, even if it might be disproportionately high when it comes to LSAs Link to comment Share on other sites More sharing options...
Doug Hereford Posted April 9, 2015 Report Share Posted April 9, 2015 Roger, I thought that is what you meant. You are actually (and I think accidently) partly correct. 1. Approved For Return to Service: what a mechanic or repairman does when he/she certifies an aircraft after any inspection where discrepancies were NOT found. 2. Returned (or Return) to Service: what a pilot does when they actually operate (fly) the aircraft. LSA aircraft ALWAYS get "approved for return to service", or disapproved for return to service after maintenance (inspections are maintenance). It is just the they will be approved for return to service in a "condition for safe operation", as apposed to an "airworthy" condition. This may seem nit picky, but it is very important to understand what all these little words and phrases actually mean. In this particular case here is an example of why it is so important: 14 CFR part 91.407 (a)(1). Excerpt from GPO website: §91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration. (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless— (1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and (2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made. I am sure Edsel Ford can explain it better. Roger you may want to ask him about it. Please feel free to cut and paste my responses though if you plan to reference them. Doug Hereford PS, GO ROYALS!!!!!!! Link to comment Share on other sites More sharing options...
Roger Lee Posted April 9, 2015 Report Share Posted April 9, 2015 Hi Doug, This isn't how they had us do it in the FAA approved LSA school or how the FAA explained it to me. Give the LSA division at the FAA a call. After an inspection (100 hr or Annual condition) it has to be found in a condition for safe operation regardless of what you find. Link to comment Share on other sites More sharing options...
Tom Baker Posted April 9, 2015 Report Share Posted April 9, 2015 Hi Doug, This isn't how they had us do it in the FAA approved LSA school or how the FAA explained it to me. Give the LSA division at the FAA a call. After an inspection (100 hr or Annual condition) it has to be found in a condition for safe operation regardless of what you find. What do you do if you find one item during the inspection that makes the aircraft unsafe? For whatever reason the owner doesn't want to fix the problem in your shop, and the airplane can safely be ferried to the owners home airport to take care of the item. What do you do? Link to comment Share on other sites More sharing options...
Anticept Posted April 9, 2015 Report Share Posted April 9, 2015 This has actually been a question of mine. If i do an inspection, is there an unairworthy signoff version in the LSA and experimental world as with standard aircraft? Link to comment Share on other sites More sharing options...
Tom Baker Posted April 9, 2015 Report Share Posted April 9, 2015 I know what I think the answer is based on the regulations, but I am going to wait for others to chime in. Link to comment Share on other sites More sharing options...
Doug Hereford Posted April 9, 2015 Report Share Posted April 9, 2015 Tom, Anticept, I will fall on my sword.................my answer is going to seem evasive on this one. My approach to this situation has fallen back on 14 CFR part 43.11(a)(5). I will cut and paste from Government Printing Office Title 14 §43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter. (a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information: (5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator.” Now, if I read item 15 of the SLSA operating limitations however, there is not option to find the aircraft in anything other than a "condition for safe operation". As a practical matter, this does make some sense to me because if during a condition inspection, an unsafe condition is discovered, the aircraft should not be ferried anyway. Where I see a dilemma is when during an inspection, an unauthorized repair or alteration is found (aircraft does not meet specifications). One might also argue about an overflown airworthiness directive (approved data?). Since SLSA MFG's seem to be reluctant to address ADs or airworthiness limitations, it is a question to me also. Don't know if this passes the litmus test or not, but it is where I have ended up when contemplating this scenario. Chime in please Doug Hereford Link to comment Share on other sites More sharing options...
Roger Lee Posted April 9, 2015 Report Share Posted April 9, 2015 I agree with Doug, "Now, if I read item 15 of the SLSA operating limitations however, there is not option to find the aircraft in anything other than a "condition for safe operation". As a practical matter, this does make some sense to me because if during a condition inspection, an unsafe condition is discovered, the aircraft should not be ferried anyway. Where I see a dilemma is when during an inspection, an unauthorized repair or alteration is found (aircraft does not meet specifications)." This I'm sure is personal turmoil for some, but if you have any pride in your work and don't want the lawsuit or disciplinary action headache better to do the next best thing. I'm not going to roll the dice with my personal life and retirement because someone wants to take a chance on my dime and then hold me responsible. If that were the kind of owner I was working for time for them to look for a new mechanic. Thankfully I have all and I mean all great clients and friends and go out of my way to try and protect them to the best of my ability. Average isn't good enough. There is doing the right thing and doing things right. For me if it truly is unsafe I won't sign off the inspection unless it gets fixed before I sign. If you want to fly it home without an inspection sign off then that's the owners decision. If you sign off and inspection with an in flight unsafe condition and let that pilot leave after you signed it off you are hanging on a lawsuit if something happens. When I used to go to court years ago it is easy to defend doing the right thing and trying to protect someone, but if you sign that off saying it's safe for flight and let them go maybe they get home okay and maybe not. If the maybe not happens there is no recourse for you as the mechanic because the FAA and lawyers said they will hold the mechanic to a higher standard over the owner since you saw it, thought it was unsafe and signed it off anyway, not to mention you have the training and are supposed to be better educated. If it is just something that isn't an unsafe in flight condition, just something that needs to be addressed some time soon in the future then I document it on the check list and possibly on the logbook label depending on what it is. Strictly a personal preference. This way it is a reminder for owner, myself or the next mechanic and then they know to look to see it it was done or just neglected. The lawyers always told me if you are going to error always error on the next step better. Better to justify trying to do the right thing and protect someone than trying to explain why you didn't. Remember after the problem occurs and you end up in front of the FAA and or court they will bring in 5 armchair quarterbacks taht are top mechanics that will all say you should have done better and they would have done it right. That's all a sympathetic jury or judge needs to hear. Link to comment Share on other sites More sharing options...
Doug Hereford Posted April 9, 2015 Report Share Posted April 9, 2015 Roger, You can bet the farm that if I do a condition inspection and find an unsafe condition, I will not approve the aircraft for return to service as I understand your reply to state. Also, I will not be contacting the FAA for guidance on the subject. At this point, I am comfortable with my current interpretation until someone gives me compelling information not to be. Remember too that it is likely members of this area of the FAA that got it so wrong on the whole Rotax thing several years ago. Doug Hereford Link to comment Share on other sites More sharing options...
Anticept Posted April 9, 2015 Report Share Posted April 9, 2015 The purpose of ferry flights is to relocate aircraft, generally for the purpose of sending it to a properly equipped shop. I can understand there is a difference between the terms "unairworthy" and "unsafe". But, we have a quandry then. How would we relocate an LSA, if it needs a repair that I am not equipped to do, I feel it is a large enough problem that it needs to be addressed, but may not be bad enough to consider it unsafe for a ferry flight? I think I will direct this question to the FAA. Link to comment Share on other sites More sharing options...
Doug Hereford Posted April 9, 2015 Report Share Posted April 9, 2015 Anticept, I think your scenario is the same as a standard airworthiness. It has to be either safe or unsafe. If it is safe certify it, if it is not, you can't certify it, and a pilot should not fly it. You seem to be talking about convenience issues. There are tons of mobile maintenance teams that travel for this very kind of thing. If it is unsafe, it cannot fly. Doug Hereford Link to comment Share on other sites More sharing options...
Roger Lee Posted April 9, 2015 Report Share Posted April 9, 2015 Hi Doug, "You can bet the farm that if I do a condition inspection and find an unsafe condition, " You may have misinterpreted my post I never thought or suspected you would do anything different. I fully believe you're a very conscientious person. There is just too much at stake on a personal and professional level. "Remember too that it is likely members of this area of the FAA that got it so wrong on the whole Rotax thing several years ago." That was several years ago while we all felt our way around the legal LSA landscape, but since all the legal interpretations most of that is gone. Link to comment Share on other sites More sharing options...
Doug Hereford Posted April 9, 2015 Report Share Posted April 9, 2015 Anticept, I realize that my answer has a lot of blue sky. Do you have a specific situation? Doug Hereford Link to comment Share on other sites More sharing options...
Anticept Posted April 9, 2015 Report Share Posted April 9, 2015 Anticept, I think your scenario is the same as a standard airworthiness. It has to be either safe or unsafe. If it is safe certify it, if it is not, you can't certify it, and a pilot should not fly it. You seem to be talking about convenience issues. There are tons of mobile maintenance teams that travel for this very kind of thing. If it is unsafe, it cannot fly. Doug Hereford I disagree. Let's say I have a retractable gear aircraft, and the gear swing is showing an anomaly. It's in the gearbox, which I am not comfortable working on and send it to another shop. I would not consider this aircraft safe for normal operation as the gear could get stuck up. So, i give the aircraft an unairworthy signoff and provide the discrepancy sheet for the owner. I pin the gear in the down and locked position, and fill out a ferry permit with the restriction that the gear must stay down and locked so it can be ferried. For the LSA world: let's say the top window in a CT is showing signs of separation. It's not fit to fly in normal operation, but it will fly fine for a ferry flight. I need to relocate it to a shop with composite experience, as the local airfield shop has not performed work with a composite aircraft, or in the case of repair stations, are not approved to do so. It is also unreasonable to attempt repairs for such an involved process by a mobile team, as proper environmental conditions for composite repair work should be maintained. Anyways, I know this one was a bit of a stretch, but i haven't encountered anything yet to need to ferry an LSA that wasn't unsafe enough to prohibit the ferry... In both of these scenarios, A ferry flight would be reasonable, but signing off as airworthy or safe operation would not be a good idea. Link to comment Share on other sites More sharing options...
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