AD logging questions for the A&Ps

[boxorox]

Some background, I'm a student pilot about to take my check-ride (6/5!) and I own a 1968 PA28-180D. One item on my check ride todo list, is to get organized on the ADs and aircraft logs. I'm anticipating a little additional scrutiny on aircraft maintenance as an owner. Based on positive reviews here I decided to purchase ADLog for the plane and spent a couple hours past weekend getting it all put together and reviewing all the adNotes to document prior compliance. Overall I'm very happy with the content and format but, there were some discrepancies between the ADs provided with ADLog and those signed off in the Logs and AD records. Generally these fell into three categories:

1. ADs signed off in the logs but not included by ADLog. These were all N/A for some reason or other. I'm planning to request these from ADLog just to have the adNote's for all ADs documented in the logs. - No question here
   
2. ADs included by ADLog but not addressed in the Logs or AD records for the plane. After reviewing these all but 1 (see #3 below) are N/A either by serial number or the make/model component not being installed. Question One: as an owner can I just note that this AD is N/A based on Serial Number/Not installed or does it require an A&P to notate this and signoff?
   
3. I have one AD 2017-14-04 which supersedes AD 95-26-13 and is a recurring inspection of oil hoses which can be terminated by replacement of hoses compliant with TSO-C53a Type D. I have documentation of terminated compliance of AD 95-26-13 by replacement with appropriate hoses. AD 2017-14-04 (i)(3) documents the same terminating condition. Question Two: Do I need an A&P to sign-off AD 2017-14-04 or does the prior sign off of 95-26-13 cover this?

Sorry for the long winded post, appreciate the tribes wisdom!

 

[drjcustis]

Others wiser than I will be along soon.

I got ADLog and love it and did the same as you.

For ADs that someone thought was applicable to my plane but weren’t and are signed off as complied with in the log, I got those ADs from ADLog and notated it. Same as you.

For ADs that don’t apply to my airframe, I did nothing with those in ADLog. There are literally tens of thousands of ADs that don’t apply to your plane, you don’t review every one. However, if there is any discussion or decision about whether or not it applies, I get the AP to look at it and mark it as applicable or not. (Brief story: had a checkride and the examiner thought an ADapplied to my plane and would not give me the checkride unless the mechanic showed it was not applicable)

Finally, if you had the lines replaced and that terminated an AD then that info should be in your log somewhere. If it’s not, then you’ll need your mechanic to review the installation and sign it off.

The initial pain of ADLog is easily recouped in the organization and ease in the future.


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[Tom-D]

Question Two: Do I need an A&P to sign-off AD 2017-14-04 or does the prior sign off of 95-26-13 cover this?

Yes you do need the AD signed off.

 

[boxorox]

For ADs that don’t apply to my airframe, I did nothing with those in ADLog. There are literally tens of thousands of ADs that don’t apply to your plane, you don’t review every one. However, if there is any discussion or decision about whether or not it applies, I get the AP to look at it and mark it as applicable or not. (Brief story: had a checkride and the examiner thought an ADapplied to my plane and would not give me the checkride unless the mechanic showed it was not applicable)

The initial pain of ADLog is easily recouped in the organization and ease in the future.

My only concern about the ADs provided that are N/A for one reason or another is that they appear on the index page also provided. Ideally I'd like to keep these adnote pages with appropriate notes about why it is N/A as part of the record. I'm just unclear if my notes would be sufficient.

Yes you do need the AD signed off.

Thanks @Tom-D I suspected this would be the case!

 

[Johnbo]

What is the most efficient way to screen ADs for a particular airplane? When shopping for planes, almost all sellers say “all ADs complied with”; is there an easy way to find which ones apply?

I hope this isn’t a hijack of the thread; it seems relevant.

 

[k9medic]

For my airplane, I pull down the active AD list from the FAA’s website.

I then put that list into a spreadsheet with a hot link to each A.D. if the A.D. was signed off I notated the spreadsheet where it was signed off in the lock box and the date. If it was superseded I also referenced that.

When my plane went to annual, my mechanic pulled his list and compared it to mine. He was then able to go directly to the page in the logbook to see what was actually done or applicable.

This significantly cut down on his research time as all of the references were there for him in one place.




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[alfadog]

What is the most efficient way to screen ADs for a particular airplane? When shopping for planes, almost all sellers say “all ADs complied with”; is there an easy way to find which ones apply?

I hope this isn’t a hijack of the thread; it seems relevant.

Why would you want to go to that effort? If the a/c is in annual then the signing IA has certified that all ADs are complied with. If the seller says they are and you have that in writing then you have recourse, IMO and IANAL. What I might like to see if I wanted to pick nits would be supplemental logbook entries at the date of sale signed off by an A&P or IA stating that, as of that date, all ADs were complied with, just in case something came out after the annual (obviously, folks will say this is never done; OK, just thinking out loud).

edit: talking about shopping here. If you are to the point of a pre-buy then your mechanic will do that work and perhaps you can assist or look over his shoulder.

 

[drjcustis]

Why would you want to go to that effort? If the a/c is in annual then the signing IA has certified that all ADs are complied with. If the seller says they are and you have that in writing then you have recourse, IMO and IANAL. What I might like to see if I wanted to pick nits would be supplemental logbook entries at the date of sale signed off by an A&P or IA stating that, as of that date, all ADs were complied with, just in case something came out after the annual.

edit: talking about shopping here. If you are to the point of a pre-buy then your mechanic will do that work and perhaps you can assist or look over his shoulder.

I had the same thought process but changed. The FAA holds the pilot responsible for AD compliance. And, after purchase, you are stuck with the plane, AD complied with or not. You’ll find little relief in the court system for a missing AD.

Additionally, I’ve seen mechanics that are absolutely anal about ADs and others that do a quick search and done. My thoroughness is different than many of them. It’s amazing at how many noncomplied with ADs you’ll find on an airframe that has had all ADs complied with all of which leaves your certificate in jeopardy and the life of you and your family on the line. YMMV.


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[alfadog]

I had the same thought process but changed. The FAA holds the pilot responsible for AD compliance. And, after purchase, you are stuck with the plane, AD complied with or not. You’ll find little relief in the court system for a missing AD.

Additionally, I’ve seen mechanics that are absolutely anal about ADs and others that do a quick search and done. My thoroughness is different than many of them. It’s amazing at how many noncomplied with ADs you’ll find on an airframe that has had all ADs complied with all of which leaves your certificate in jeopardy and the life of you and your family on the line. YMMV.


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I was only responding to the post about shopping, not the OP. Obviously, once shopping moves toward buying, we are going to get a lot more interested. I do not see any reason to go in-depth on AD's whilst "shopping" unless there are particular nasty ones that you need to watch out for e.g. prop AD's on Apache's. Again, IANAL, but I would think that if a seller represents all AD's as complied with and the purchaser finds that not to be the case then they should have recourse to recover damages. Obviously, their pre-buy should have caught it but if it not, I still think they can go back to the seller.

 

[Bell206]

What is the most efficient way to screen ADs for a particular airplane?

Just to add to the above comments, prior to reviewing a potential aircraft purchase I print out a aircraft specific historical AD list from a 3rd party software. I also print out a copy of the current FAA AD Bi-weekly list. If an AD appears on my list that is not in the aircraft records it gets flagged. At the end of the review I usually give the seller an opportunity to look into that discrepancy which is usually taken care of that day or shortly there after.

 

[Bell206]

It’s amazing at how many noncomplied with ADs you’ll find on an airframe that has had all ADs complied with

I don't quite follow your statement on "many non-complied...ADs." It's been my experience that at most there may be 1 or 2 ADs overlooked or not updated, but to have "many" ADs not complied with on an actively flying aircraft with a current annual would be an exception. Now if you are describing a situation where there might be 50 ADs issued to PA-28 aircraft and your aircraft has only 5 of those ADs signed off, that wouldn't necessarily mean the others were "non-complied" with. Technically, only aircraft that fall specifically under the AD applicability statement are required to have the AD complied with. There is no requirement to make make an entry on the others. Is it a good habit to get into, sure. But it's not regulatory requirement.

 

[boxorox]

So steering back towards the open question: as an owner can I just note that this AD is N/A based on Serial Number/Not installed or does it require an A&P to notate this and signoff?

Digging through the FARs a bit on maintenance responsibility and logging:

91.403 (a)

The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter.

So owner is responsible for maintaining aircraft in an airworthy condition including compliance with part 39 which covers ADs

91.417 (a)(2)(v)

The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required

Only "applicable airworthiness directives" need to be part of the logs. So I guest the question hinges on if the owner is able to make a determination based on the applicability section of the AD. It seams to me that on things that are cut and dry, i.e. S/N is not covered then your good to go. In this case I'd make a note as a future reminder and move on with life.

Thoughts?

 

[alfadog]

I am sure that, as the owner, you are free to make whatever notations and records that you care to to ensure that YOU are in compliance. The IA will do likewise for himself at annual and will not rely on what you have done. So whether you mark something as N/A will have no bearing on the IA's actions; he will verify that for himself.

 

[Tom-D]

I am sure that, as the owner, you are free to make whatever notations and records that you care to to ensure that YOU are in compliance. The IA will do likewise for himself at annual and will not rely on what you have done. So whether you mark something as N/A will have no bearing on the IA's actions; he will verify that for himself.

Hopefully

 

[Tom-D]

So steering back towards the open question: as an owner can I just note that this AD is N/A based on Serial Number/Not installed or does it require an A&P to notate this and signoff?

Digging through the FARs a bit on maintenance responsibility and logging:

91.403 (a)

​

So owner is responsible for maintaining aircraft in an airworthy condition including compliance with part 39 which covers ADs

91.417 (a)(2)(v)

​

Only "applicable airworthiness directives" need to be part of the logs. So I guest the question hinges on if the owner is able to make a determination based on the applicability section of the AD. It seams to me that on things that are cut and dry, i.e. S/N is not covered then your good to go. In this case I'd make a note as a future reminder and move on with life.

Thoughts?

Only ADs that apply are required to be complied with.. But.. It sure makes it easy to do a compliance check when they all noted as to requirement.

AD compliance must be signed off as the AD requires, If the AD does not state that the owner/operator can do it, then AD must be complied with by at least an A&P

 

[Bell206]

Thoughts?

To add to the above, why not sit down with your mechanic and go through this initial setup with ADLog? It may cost you a few bucks but it could present a good learning experience on this subject and present the ability to update your list/logbook at the same time with his signatures.

 

[boxorox]

I am sure that, as the owner, you are free to make whatever notations and records that you care to to ensure that YOU are in compliance. The IA will do likewise for himself at annual and will not rely on what you have done. So whether you mark something as N/A will have no bearing on the IA's actions; he will verify that for himself.

Makes sense!

Only ADs that apply are required to be complied with.. But.. It sure makes it easy to do a compliance check when they all noted as to requirement.

AD compliance must be signed off as the AD requires, If the AD does not state that the owner/operator can do it, then AD must be complied with by at least an A&P

This was exactly my thinking, keep the N/A ad's with the records including notes on why it is N/A to make future compliance checks a breeze.

Understood on the sign-offs it was annoying when 2018-07-03 for fuel selector placards was issued. My plane was not affected but since I don't have my private certificate yet had to deal with the logistics of getting an A&P to look and sign.

To add to the above, why not sit down with your mechanic and go through this initial setup with ADLog? It may cost you a few bucks but it could present a good learning experience on this subject and present the ability to update your list/logbook at the same time with his signatures.

The setup seams fairly straight forward, but I do plan to review everything with an A&P before the ride to make sure everything is above board.

Thanks all for the input!

 

[alfadog]

...
Understood on the sign-offs it was annoying when 2018-07-03 for fuel selector placards was issued. My plane was not affected but since I don't have my private certificate yet had to deal with the logistics of getting an A&P to look and sign.
...

Not sure I get this one. You are not required to do anything with a non-applicable AD. When the next annual comes round, the IA may (and probably will) make a note to the effect that it is N/A. Until then, fuggeddaboutit.

 

[boxorox]

Not sure I get this one. You are not required to do anything with a non-applicable AD. When the next annual comes round, the IA may (and probably will) make a note to the effect that it is N/A. Until then, fuggeddaboutit.

So the trick with this one is that the AD was applicable to my aircraft per section (c). Section (g) required a Preflight check of the fuel selector placards before further flight which may be preformed and logged by an owner holding at least a private pilot certificate.

AD 2018-07-03

(g) Preflight Check of the Fuel Selector Cover
Before further flight after April 20, 2018 (the effective date of this AD), check the left and right fuel selector cover placards for proper installation using the Appendix to this AD. If the fuel selector placards are properly installed, no further action is required. The preflight check of the fuel selector cover may be performed by the owner/operator (pilot) holding at least a private pilot certificate and must be entered into the airplane records showing compliance with this AD in accordance with 14 CFR 43.9 (a)(1)-(4) and 14 CFR 91.417(a)(2)(v). The record must be maintained as required by 14 CFR 91.417, 121.380, or 135.439.

 

[John Adams]

I am trying to figure out how to send a copy???

 

[Hang 4]

So the trick with this one is that the AD was applicable to my aircraft per section (c). Section (g) required a Preflight check of the fuel selector placards before further flight which may be preformed and logged by an owner holding at least a private pilot certificate.

AD 2018-07-03

That one came out right before my checkride. It is applicable and requires a log entry whether or not the stickers are in the right place. I couldn't comply since I was still a student pilot. As an aside, it frosted me that as a lowly student pilot, I couldn't look at a sticker and see if it was in the same orientation as a picture). I got my CFI to look at it and sign off the log entry.

 

[Bell206]

I am trying to figure out how to send a copy???

A copy of what?

 

[John Adams]

A copy of what?

A copy of the logs?

 

[Bell206]

A copy of the logs?

What "logs"? Aircraft logbooks? AD records? Lincoln logs? PoA doesn't provide a mind reading function that I can find.

 

[PeterNSteinmetz]

What "logs"? Aircraft logbooks? AD records? Lincoln logs? PoA doesn't provide a mind reading function that I can find.

Very true. Though many posters often assume they can read the mind of other posters!

 

[John Adams]

Sorry for my stupidity...
I was trying to find a feed...
And somehow assumed...
I was trying to find out if my AdLog system/aircraft logs was available to send to a potential buyer in any electronic form/pdf??
Thank you for your assistance
Sorry I was not more clear about my request..

 

[John Adams]

I was trying to find out if my AdLog data/aircraft logs
Were available to send in any electronic format/pdf??

 

[Bell206]

I was trying to find out if my AdLog data/aircraft logs Were available to send in any electronic format/pdf??

You will need to scan your paper records into a digital format first then you can share them which depending on the file size could be through email, or at an online hosting site, or copy to portable storage and mail it. The ADlog pages scan easily with the preferred format PDF. The old style log books usually need a long scanner bed to catch both pages of the open logbook.

For extensive records I would take my old customers PDF scans and create a PDF binder with my Acrobat Pro then organize the binder complete with a TOC. You can also take all your records to an Office Depot, etc and they can scan them plus create a binder if you want or need.

 

[John Adams]

You will need to scan your paper records into a digital format first then you can share them which depending on the file size could be through email, or at an online hosting site, or copy to portable storage and mail it. The ADlog pages scan easily with the preferred format PDF. The old style log books usually need a long scanner bed to catch both pages of the open logbook.

For extensive records I would take my old customers PDF scans and create a PDF binder with my Acrobat Pro then organize the binder complete with a TOC. You can also take all your records to an Office Depot, etc and they can scan them plus create a binder if you want or need.

Thank you very much for your reply and suggestions...Blue Ones!

 

[unsafervguy]

That one came out right before my checkride. It is applicable and requires a log entry whether or not the stickers are in the right place. I couldn't comply since I was still a student pilot. As an aside, it frosted me that as a lowly student pilot, I couldn't look at a sticker and see if it was in the same orientation as a picture). I got my CFI to look at it and sign off the log entry.

I would consider that an illegal sign off. The ad states the owner/operator with at least a private pilot certificate. A cfi that does not own the aircraft is not the owner/operator.

 

[Hang 4]

I would consider that an illegal sign off. The ad states the owner/operator with at least a private pilot certificate. A cfi that does not own the aircraft is not the owner/operator.

OK, so how does a student pilot owner sign off? By that definition if you are student pilot, no one can sign off. My AP is neither the owner nor the operator.

BTW the AD was related to some Piper Cherokee's having the left and right tank labels reversed at the factory. Compliance with the AD required looking at a picture of a fuel selector with the L and R in the right place and "certifying" that your's looked like this. I got a lot of guff from this group when I complained that as a Student Pilot, I wasn't qualified to look at a freaking picture of 2 letters and see if they are in the right place or not. Still bugs me. I have a ton of respect for A&P/AI folks, and I know my limits of what I can and can't do, but this one really chapped my fritters.

 

[mondtster]

OK, so how does a student pilot owner sign off? By that definition if you are student pilot, no one can sign off. My AP is neither the owner nor the operator.

A student doesn't sign it off regardless if they own it or not. Likewise, the way the rules are written it disallows a pilot who holds a certificate at the sport pilot level to perform work on an airplane they own. There are other avenues that they need to pursue in that case.

In your case the AD should have been signed off by a mechanic because despite being neither the owner or operator, they are authorized to do the work.

 

[Bell206]

that as a Student Pilot, I wasn't qualified to look at a freaking picture of 2 letters and see if they are in the right place or not. Still bugs me. I have a ton of respect for A&P/AI folks, and I know my limits of what I can and can't do, but this one really chapped my fritters.

But it's a two-way street. Once you get your private pilot certificate, in addition to being the owner, you'll actually have more stroke over your aircraft than any APIA. Everything maintenance starts with you and ends with you as owner. And you can even legally manufacture parts which no stand alone APIA can. But with that comes all the responsibility as well. Considering few ADs allow for owner/pilot sign offs, I wouldn't sweat the one AD that got away due to a simple legality in certificate type.

 

[unsafervguy]

OK, so how does a student pilot owner sign off? By that definition if you are student pilot, no one can sign off. My AP is neither the owner nor the operator.

BTW the AD was related to some Piper Cherokee's having the left and right tank labels reversed at the factory. Compliance with the AD required looking at a picture of a fuel selector with the L and R in the right place and "certifying" that your's looked like this. I got a lot of guff from this group when I complained that as a Student Pilot, I wasn't qualified to look at a freaking picture of 2 letters and see if they are in the right place or not. Still bugs me. I have a ton of respect for A&P/AI folks, and I know my limits of what I can and can't do, but this one really chapped my fritters.

as stated, a student pilot or a sport pilot cannot sign it off. like it or not,that's the way the rules are written. An A&P would need to sign it off.
no disrespect, but you apparently do not know the limits or have an understanding of far parts 43 and 39 (maintenance and AD's). which as an owner and pilot you really need to understand. As you had it illegally signed off and all flights done since 20apr2018, as per section (G) of AD2018-07-03 states, until it was properly signed off, were in an un-airworthy aircraft. see FAR39.7 and FAR39.9 and FAR91.7 as an owner A DPE will most likely dive into these areas refering to:
FAR91.403 (a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter.

if you brought the aircraft for a checkride a really sharp DPE would possibly catch that when he reviewed the logbooks and would have no choice but end the ride, and suggest you not fly the aircraft home. frankly, your CFI should have know that he could not sign it off, and that you would need to get your A&P to sign it off.
minor point, its A&P IA not A&P AI.

 

[Hang 4]

I showed the DPE the sign off and he had no problem with it. I guess both my rating and my DPE’s should be pulled. This nitpicking is what I truly hate about GA. Spelling IA backwards, YHGTBSM. No disrespect

 

[Hang 4]

I maintain my aircraft meticulously btw. In addition to the logs, I have a binder with every 337, STC, maintenance receipt, an AD log anything else pertaining to the plane. I also have a spreadsheet where I have a record of the date and tach hours when any wear item was last replaced like tires and plugs so I know when they are coming due. I also know exact what I can do as an owner and when I need an A&P. I’m not anti authority, this one just bugs me that looking at a picture of a fuel selector and seeing if the L and the R are in the right place requires a qualified professional to check it. If no one else thinks that’s a bit silly, then I guess I’m an outlier.

 

[Silvaire]

The problem is that there has never been a real standard for this. In essence the signature for the annual inspection is supposed to mean that, as of that date, everything is in compliance. Anyone who wants to challenge or second guess this, well that's a whole different ballgame. But again, there isn't a set standard method of recording this compliance. Some logbooks have sections for listing AD compliance, some people use ADlog, some mechanics use Tdata or one of the other compiler/report generators. In my opinion most of these systems waste a lot of paper. You really just need a simple list of applicable AD's stating the date of compliance. This will allow you to go to the logbook and view the actual entry that was made and signed at the time of compliance. For convenience the list can also include those AD's that were deemed N/A with a short description of why. Because the AD search engines can only get you so far, only into the first layer which is usually manufacturer type. After this the layers and filters go deeper into maybe serial number, date of manufacture, hours in service and even beyond to conditions and circumstances that might not have anything to do with math or numbers so the only way to determine applicability is for a dumb human to read the text.

The best method is for the mechanic to make a concise and detailed entry when the AD is complied with and for there to be a reference sheet or page so that someone twenty years later can easily find that entry amongst all of the wordy entries of greasing wheel bearings and adjusting magneto timing. It doesn't have to be a book, just a list.

 

[Silvaire]

...Spelling IA backwards, YHGTBSM. No disrespect

Yea, I don't know when that started. IA is the card, AI is the guy who has it in his wallet.

 

[Bell206]

I don't know when that started.

FYI: the history of the AI vs IA starts in the CAA days when only the Feds or a Designated Airworthiness Maintenance Inspector (DAMI) could sign an annual and reissue the required new AWC. The DAMI, better known as an Authorized Inspector (AI), was used until the early 50s when all AIs/DAMIs were grandfathered into the new Inspection Authorization regulation except the Inspection Authorization was not a standalone certificate like the DAMI/AI certificate was. So the AI term was technically dropped for AP/IA. However, the older term AI simply was still used informally. But if you want to get the semantics right it's an FAA A&P with an Inspection Authorization vs. a CAA Authorized Inspector. May seem trivial to some but the GADO inspector who issued my A&P test tickets was a former DAMI and would set everyone straight who came looking for an AI vs IA application. So I guess there's something to it in some circles.

 

[Silvaire]

Thanks for that tidbit of nostalgic trivia Bell. Strangely it all kinda makes sense now