Good & Legal Documentation USA & FAA vs a Mechanic’s Documentation

[Roger Lee]

Good & Legal Documentation

USA & FAA vs a Mechanic’s Documentation

Piloting, being an owner or a mechanic takes responsibility and attention to what’s legal or the “the best practice” in maintenance and that helps keep us all safe and away from bad legalities.

  Watch what you write it can and will be used either to support you for the good or cause you bad legal issues. I’m writing this in the hopes to help owners and mechanics to not be a target in case of an issue and it doesn’t have to be something you did wrong to become that target. As an owner / pilot make sure the mechanic or yourself does the right thing and document’s so you aren’t hanging out on a limb. You’re also paying good money for an inspection and it should be done the way you need it done and not always the way some people do them. I spent 30 years in the field and watched countless times when people from all walks of life got burnt to the ground in court or legal issues all because of either poor or no documentation. The other issue with poor documentation is getting Rotax or the aircraft’s MFG help. If you didn’t ever do your Rotax 25 hr. warranty inspection or you have poor logbooks you may not get help during warranty or at other times. You’ll be ask to fill out a Customer Service Information Report and send in your logbook entries.

  In the last few years I have seen more and more SLSA logbook entries state they were inspected in accordance with FAA part 43 checklist. The SLSA Mfg’s must provide a maintenance manual and inspection checklist and you must use it over the FAA part 43 checklist. If you inspected an SLSA or an SLSA that was turned into an ELSA and you used a part 43 checklist then you missed half of what the MFG has listed for their specific inspection. Now you’re hanging out on that proverbial limb for trouble. SLSA aircraft have maintenance manuals with inspection checklist in them. It’s easy to just print the fuselage and Rotax maintenance checklist and use it. If your mechanic doesn’t do it print it out and give it to them. I print a checklist for the Rotax and one from the aircraft Mfg when I inspect aircraft and fill it out. I sign off everything and if I touch, tweak, torque or change something it gets annotated in the margin. Then I give this checklist to the owner. I do the same thing with a Rotax maintenance checklist and the owner gets this. A normal inspection logbook for me is usually a full logbook page long and typed in #9 font so it all fits and of course it’s more readable than many hand written entries. A Rotax rubber change and an annual is usually two pages long. This shows you followed the SPECIFIC aircraft Mfg’s and Rotax’s inspection items and didn’t use a general FAA general part 43 checklist and missed many items. I see some only doing 100 hr. inspections and no mention ever of an annual condition inspection and vise versa in the logbooks. You could just write you are doing the 100 hr. and annual condition inspection at the same time.

  I see too many three liner logbook labels. This is just being lazy. The FAA says this is the bottom of a barely legal logbook entry depending on your wording. They usually say they inspected this aircraft IAW (In Accordance With) the aircrafts maintenance manual and then “put it back in service”. Bad idea for any LSA. When you wrote you did an inspection IAW the maintenance manual that means you did everything on that checklist and we know many times that doesn’t happen. Very few actually use the real checklist. So if anything happens to that plane or engine you better be able to prove what you did and the numbers associated with it because you put in writing that you did it “IAW” the manual. I’ve had a few companies ask me to call mechanic’s and ask what they really did. 100% of those failed to even do half the proper inspection for that aircraft or even have a clue to what any numbers were  i.e. gearbox friction torque check or plug gaps or compression test, ect... Then they write they put the SLSA back in service. You can’t do that for LSA. You must “find it in a condition for safe operation”. This is not a certified aircraft so it doesn’t just get returned to service. Plus the bottom line in court is “if you didn’t write it you didn’t do it”. Complain all you want, but that’s what the courts and lawyers standards are for any trial and so does the FAA and insurance companies.

  This is like the Internal Revenue Service at tax time. You can claim anything you want until you get caught or audited. You don’t need to be Earnest Hemingway to document. All you are is a secretary and write it any way you want, just write it down. If you did something then write it down. i.e. oil change or spark plugs or gearbox friction torque, ect…. Example only: You replaced all spark plugs with new NGK DCPR8E plugs, gapped them at .025 and applied thermal paste. You performed and oil change. You drained the oil and installed 3 liters of Aero Shell Sport Plus 4, installed a new Rotax oil filter, Inspected the magnetic plug and found it clean then safety wired the mag plug and oil tank plug back in place. Removed, cleaned and oiled the K&N air filter. You did a gearbox friction torque check and it was 480 in/lbs.  You say why write that I put safety wire on the magnetic plug or oil tank plug. Because in let’s say 6 months the plane goes down because of an engine failure and they find the magnetic plug gone. Then you’ll know it wasn’t you and someone else was in there after you and they failed to apply safety wire. Protect yourself.

  So now the owner knows you did a complete job, knows what you did and for the next inspection has information to compare trends happening. It’s so easy to protect yourself and the owner. Plus it makes the next mechanic’s job easier because he’ll know what was actually done or not done or what SB’s were followed. Good documentation also makes the plane easier to sell and keeps its value up higher. Last, but not least. If someone writes a three liner for an annual condition inspection and says that the rest is on file then they must have it already done. Then why didn’t they just reach over and hit the print button and give you the additional logbook entry information? What happens if their system gets wiped out by hackers or a total system failure. Make them print out and give you what they just said they have. You paid for it.

And here it is. Just remember: If you didn’t write it you didn’t do it and there is no way you can prove it especially after it’s way down the calendar time.

Fly safe, have fun and be all you can be!

 Here’s another documentation article.

https://www.rotax-owner.com/en/rotax-blog/item/22-good-documentation-its-everything

 

 

 

 

 

[Tom Baker]

How does CFR 107.140 apply in this case? It has nothing to do with the maintenance of light sport aircraft.

[Roger Lee]

Hi Tom,

Thanks for the catch. I crossed two papers and messed the document up. I deleted the 107 part.

[Bill3558]

Interesting write up.
After having 2 awful incidents after SLSA annuals, I have gone ELSA and attending Rainbow Aviations Light Sport Repairman class this weekend. So I can do my own annuals. 

[Roger Lee]

3 hours ago, Bill3558 said:

Interesting write up.
After having 2 awful incidents after SLSA annuals, I have gone ELSA and attending Rainbow Aviations Light Sport Repairman class this weekend. So I can do my own annuals. 

Make sure you also take some Rotax classes. It's important.

[Jim Meade]

I see in the example the notation of NGK DCPR8E plugs and Aero Shell Sport Plus 4 oil.  When changing rubber hoses on an SLSA, should one note the specifications of the hose, such as if you replace the return oil hose from the bottom of the crankcase to the oil tank, should you say replaced with DIN 73379, 7.5X3.0, or is it enough to just say replaced oil hoses?

[Roger Lee]

You can add and be as specific in detail as you want. The FAA says that what's in the FAR's as a legal logbook entry is the bare minimum and they say they encourage people to document more. So however detailed you want to be is up to you, but at least log the general items. If you touch it, tweak it, torque it or change it take the extra minute and just write it down. You don't have to be Earnest Hemmingway you can write it anyway you want, just write it.

[Jim Meade]

I'm personally OK with an entry that says a mechanic did something by a commonly available checklist, because someone else can refer to the checklist.  What I'm not OK with is if a mechanic working on an SLSA changes an OEM item and doesn't write that down.  For example, if one uses a non-OEM hose and doesn't describe it.   Since the owner (not the mechanic) is responsible for maintenance, the mechanic who changes an OEM item for a non-OEM item and makes a generic entry like "changed hose" is hanging the owner out to dry.  I don't need to see changed oil with Aero Shell Sport Plus 4 because that is what Rotax calls for, but is one uses Rotella 10-40, it certainly needs to be written up.  Same with using a Gates Hose us-spec hose when Rotax calls for a specific DIN.

 

[Roger Lee]

Rotax used to and still may use Gates hose Mfg'ed in Europe. They even had a recall on one of their Gates hoses on the fuel pump a while back. The difference tends to be MM vs US standard I.D.

[Tom Baker]

Rotax no longer supplies new engines with automotive type fuel hoses, they come with Teflon hoses. When the did use Gates hoses my recollection is that they were SAE sizes and USA manufactured.

[Roger Lee]

We're getting off topic about documentation.

 

Hi Tom,

That is correct now, but there are tens of thousands of Rotax engines out there since around the 1990 era that still use rubber hoses. Many of the rubber hose were metric. It was stamped right on them.  

[Tom Baker]

8 hours ago, Roger Lee said:

We're getting off topic about documentation.

 

Hi Tom,

That is correct now, but there are tens of thousands of Rotax engines out there since around the 1990 era that still use rubber hoses. Many of the rubber hose were metric. It was stamped right on them.  

I have only been working on them since 2007, and my first rubber replacement was late 2010. I only recall SAE sized hoses factory attached hose on Rotax supplied fuel pumps. Flight Design of course used metric hoses for anything they factory installed.