Incorrect log book tally

Ron Levy said:
No such animal, but AC 120-78 covers "Acceptance and Use of Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manuals", which provides the means to get the Administrator to accept the manner in which you use electronic signatures and recordkeeping.
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Except that that AC's "Who does this AC apply to?" section does not list pilots maintaining their logbooks. (It does list those who certify pilots.)
 
Ron Levy said:
They do not certify logbooks, but they do have a process for accepting the use of electronic signatures and recordkeeping. Note that 14 CFR 61.51 requires that your pilot logbook be kept "in a manner acceptable to the Administrator".

No such animal, but AC 120-78 covers "Acceptance and Use of Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manuals", which provides the means to get the Administrator to accept the manner in which you use electronic signatures and recordkeeping.

I believe their web site discusses their compliance with AC 120-78.
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So, they are not "certified," which at least implies approval or confirmation of meeting standards by a recognized authority. Thanks for clearing that up.
 
acrophile said:
Except that that AC's "Who does this AC apply to?" section does not list pilots maintaining their logbooks. (It does list those who certify pilots.)
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It lists the FAA-approved means to gain the Administrator's acceptance of your electronic signature/recordkeeping system. If you don't follow it, there's no way to know your electronic logbook (i.e., an electronic signature and recordkeeping system) is "acceptable to the Administrator".
 
midlifeflyer said:
So, they are not "certified," which at least implies approval or confirmation of meeting standards by a recognized authority. Thanks for clearing that up.
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Right -- I used the wrong word. The correct word from the regulation is "acceptable", and AC 120-78 is the only FAA document which tells you what is "acceptable to the Administrator" when it comes to electronic signature and recordkeeping system like an electronic pilot logbook.
 
Ron Levy said:
It lists the FAA-approved means to gain the Administrator's acceptance of your electronic signature/recordkeeping system. If you don't follow it, there's no way to know your electronic logbook (i.e., an electronic signature and recordkeeping system) is "acceptable to the Administrator".
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Sure there is: the Administrator has been accepting my electronic logbook for more than a decade.
 
acrophile said:
Sure there is: the Administrator has been accepting my electronic logbook for more than a decade.
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Mine as well, and it's not even commercial software. I made my own database. I started it when I was a student pilot, and it's been accepted for all 6 certs/ratings.

This is just another example of Ron being Ron. He thinks it should be a certain way, and somehow that translates into the FAA certifying things. Never mind the fact that there are hundreds or thousands of examples contradicting what he says. But nope, that won't stop him, Ron has to make himself appear to be the expert and make claims to know what the FAA is thinking or wanting.
 
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acrophile said:
Except that that AC's "Who does this AC apply to?" section does not list pilots maintaining their logbooks. (It does list those who certify pilots.)
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True. And "acceptable to the Administrator" in 61.51 is really not much more than an after-the-fact determination and I'm not aware of any logbook, paper or plastic, ever being deemed "acceptable" or "not acceptable." But it does provide some guidance on FAA thinking on what an acceptable electronic signature is.

That's really what I personally see as the main issue when it comes to electronic logbooks. Paper or plastic, we authenticate our own entries by the simple act of handing over our records when requested. The question is what we need to do to authenticate regulatory-required signatures of other people.
 
acrophile said:
Sure there is: the Administrator has been accepting my electronic logbook for more than a decade.
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There are a few (very few) NTSB cases involving electronic logbooks. In none was there any question raised about whether the record was acceptable to the Administrator, even when the record was nothing more than a spreadsheet. In one the FAA brought an enforcement action for submitting falsified records based on an emailed Excel spreadsheet*. Kind of hard to say a record is false if you don't consider it to be an "acceptable record" to begin with.


[* a very weird case, FAA v. Rigues. The FAA lost it's bid for an emergency revocation, but the discussion of the Excel spreadsheet is notable for the lack of discussion of its status as a logbook]
 
acrophile said:
Sure there is: the Administrator has been accepting my electronic logbook for more than a decade.
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:confused: How many times in the last decade has your log book been audited by the FAA? Everything is good until you get called to the carpet. It's not until you call attention to yourself that anything matters, although granted, unless it looks like you're covering a fraud, it won really matter.
 
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acrophile said:
Acceptable for a list of specified purposes, conspicuously omitting pilot logbooks.
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Are you not covered by "Operators under 14 CFR parts 91, 125, 133, or 137"? And are the DPE or FAA Inspector giving your practical test not "Persons performing airmen certification under 14 CFR parts 61, 63, 65, 141, and 142"?
 
Henning said:
How many times in the last decade has your log book been audited by the FAA?
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Not sure what an FAA "audit" is, but relevant portions of my electronic log (including necessary signatures) have certainly been reviewed by the FAA's DPEs when I obtained new certificates and ratings.

Everything is good until you get called to the carpet. It's not until you call attention to yourself that anything matters, although granted, unless it looks like you're covering a fraud, it won really matter.
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So, same as for a paper logbook.
 
acrophile said:
Not sure what an FAA "audit" is, but relevant portions of my electronic log (including necessary signatures) have certainly been reviewed by the FAA's DPEs when I obtained new certificates and ratings.
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I'd be interested to see how your instructor electronically signed your electronic logbook for the training and endorsements necessary for you to take a practical test for a certificate/rating. Further, the fact that an individual DPE fails to follow FAA guidance does not mean that is acceptable to the Administrator -- just ask the folks whose tickets were pulled and forced to undergo reexamination due to DPE malfeasance.
 
Ron Levy said:
DPE's are not the Administrator's representatives in his regard. Their designation is very limited.
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When a DPE is administering an exam he most certainly does represent the Administrator.........
 
acrophile said:
Not sure what an FAA "audit" is, but relevant portions of my electronic log (including necessary signatures) have certainly been reviewed by the FAA's DPEs when I obtained new certificates and ratings.



So, same as for a paper logbook.
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Audited is when you have an accident or violation and the FAA has a forensic examiner go through it looking for any fraudulent documentation used to gain certification. That is an FAA audit of your log book. A DPE is not the FAA, he doesn't deal with, or care about, the honesty or integrity of your log book, just that what is presented to him shows the information required.

Exactly the same as for paper logs, which is why the "One line strike out" method of correcting paper logs. All the electronic protocol does is preserves that same transparency of historic corrections.
 
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RotorAndWing said:
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When a DPE is administering an exam he most certainly does represent the Administrator.........
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...only for the purpose of determining whether the applicant meets the standards for issuance of the certificate, not for deciding whether the applicant's electronic signature/recordkeeping system is acceptable to the Administrator. Nothing in 8900.2 or 120-78 gives DPE's that authority.
 
Ron Levy said:
Are you not covered by "Operators under 14 CFR parts 91, 125, 133, or 137"?
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Nope. I'm not an operator. The FAA uses that term for those who run airlines and airports:
https://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/

I've never seen the term applied to private pilots.

And are the DPE or FAA Inspector giving your practical test not "Persons performing airmen certification under 14 CFR parts 61, 63, 65, 141, and 142"?
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Yes, they are. I already mentioned that. So yes, the AC does apply to their electronic records. But not to mine.
 
Henning said:
Audited is when you have an accident or violation and the FAA has a forensic examiner go through it looking for any fraudulent documentation used to gain certification. That is an FAA audit of your log book.
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What " forensic" investigator?

Henning said:
A DPE is not the FAA, he doesn't deal with, or care about, the honesty or integrity of your log book, just that what is presented to him shows the information required.
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You better be the cares. If he suspects fraudulent entries he can stop the test and contact his Principal at the FSDO.
 
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Ron Levy said:
...only for the purpose of determining whether the applicant meets the standards for issuance of the certificate, not for deciding whether the applicant's electronic signature/recordkeeping system is acceptable to the Administrator. Nothing in 8900.2 or 120-78 gives DPE's that authority.
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acrophile said:
Nope. I'm not an operator. The FAA uses that term for those who run airlines and airports:
https://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/

I've never seen the term applied to private pilots.



Yes, they are. I already mentioned that. So yes, the AC does apply to their electronic records. But not to mine.
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:confused: The operator is the person who causes a flight to be dispatched. If you are the owner/pilot who has the ability to make the choice to make a flight and when to make it, you are also the defacto operator of the plane. Whether it is a commercial or private operation, every flight has an operator. Most GA planes not in rental typically are considered under Owner/Operator control.
 
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Henning said:
If you are the owner/pilot who has the ability to make the choice to make a flight and when to make it, you are also the defacto operator of the plane. Whether it is a commercial or private operation, every flight has an operator. Most GA planes not in rental typically are considered under Owner/Operator control.
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I don't own a plane. The FBO I rent from is the operator.

And even if I were an owner/operator, the AC would only apply to my records *as* an operator, not to other records (such as my pilot logbook) unrelated to my being an operator.
 
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RotorAndWing said:
What " forensic" investigator?



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You better be the cares. If he suspects far undulant entries he can stop the test and contact his Principal at the FSDO.
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The guy who looks at evidence closely, the inspector who goes through a log book line by line after something happens, by definition is a forensic investigator.

Why would the DPE suspect fraudulent entries before a ride? Much less why would they attribute that to the software used?:dunno:
 
Henning said:
Exactly the same as for paper logs, which is why the "One line strike out" method of correcting paper logs. All the electronic protocol does is preserves that same transparency of historic corrections.
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I agree that it'd be a good idea to have some such standard for electronic records, including pilot logbooks. My point is just that the FAA has so far chosen to *omit* pilot logbooks from the scope of the AC that establishes such standards.
 
Henning said:
The guy who looks at evidence closely, the inspector who goes through a log book line by line after something happens, by definition is a forensic investigator.
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Spare everyone the psychobabble BS trying to justify your inanity.


Henning said:
Why would the DPE suspect fraudulent entries before a ride? Much less why would they attribute that to the software used?:dunno:
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So you claim no one has ever tried to take a check ride with bogus log entries?

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acrophile said:
I agree that it'd be a good idea to have some such standard for electronic records, including pilot logbooks. My point is just that the FAA has so far chosen to *omit* pilot logbooks from the scope of the AC that establishes such standards.
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Yeah yeah, because it doesn't really matter. There is no adverse result that will occur to the actuarial tables, so no one cares. The whole point of our government is to protect the money.
 
Henning said:
Exactly the same as for paper logs, which is why the "One line strike out" method of correcting paper logs. All the electronic protocol does is preserves that same transparency of historic corrections.
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That statement doesn't make any sense. If you change an entry in your electronic logbook there is no evidence of alteration, unlike white out where there is a trace. As far as signatures go, I don't think anyone has seen or signed my physical or electronic logbook in 15 years.
 
Everskyward said:
That statement doesn't make any sense. If you change an entry in your electronic logbook there is no evidence of alteration, unlike white out where there is a trace. As far as signatures go, I don't think anyone has seen or signed my physical or electronic logbook in 15 years.
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Properly implemented in software then there is indeed a record. The problem is that properly implementing such a thing is quite a bit of work and I"m not convinced any of the logbooks do it to a standard I would trust as a software developer.

Hence why I use an electronic logbook, that I ultimately print paper stickers with, which go in my logbook. if I want a signature it's done with a pen in my logbook.
 
jesse said:
Properly implemented in software then there is indeed a record. The problem is that properly implementing such a thing is quite a bit of work and I"m not convinced any of the logbooks do it to a standard I would trust as a software developer.
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So every time you enter something in a field it is recorded? Even if the reason is that you made a typo and corrected it a few seconds later? Somehow I find this a little implausible, but you are the software developer. I can't believe that developers of electronic logbooks would go to that trouble. They also don't tell you how to retrieve that information or is that some super-secret conspiracy they have with the FAA? :D
 
Everskyward said:
That statement doesn't make any sense. If you change an entry in your electronic logbook there is no evidence of alteration, unlike white out where there is a trace. As far as signatures go, I don't think anyone has seen or signed my physical or electronic logbook in 15 years.
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If you use the software that meets the specs, yes it does, that's what we're discussing. I don't think anybody really gives a **** for pilots either. All the FAA wanted from my log book was a picture of my most recent Flight Review, (I left my log book in Italy and had my deckhand email me a pic of the page), insurance company didn't even want that.

It's the same issue as using white out, it's not the proper way by standards, but nobody is particularly enforcing the standard.

It's just a standard the government has accepted pertaining to e-signatures and record keeping is all. As long as there is no real money involved, no one is particularly concerned. Even in airline service, it's not like the insurance can deny or surrogate on the evidence of your log book, and that is what the protocols are meant to protect.
 
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Everskyward said:
So every time you enter something in a field it is recorded? Even if the reason is that you made a typo and corrected it a few seconds later? Somehow I find this a little implausible, but you are the software developer. I can't believe that developers of electronic logbooks would go to that trouble. They also don't tell you how to retrieve that information or is that some super-secret conspiracy they have with the FAA? :D
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You could set it up a number of different ways. Usually a record is saved after all the information is entered and you move to the next line in the logbook. And yes, it's easy enough to set up another table so that anytime you make a change to a saved record it lists what the change is, when, etc...

It's not that difficult. Of course it is always possible to delete the secondary table...
 
Henning said:
If you use the software that meets the specs, yes it does, that's what we're discussing. I don't think anybody really gives a **** for pilots either. All the FAA wanted from my log book was a picture of my most recent Flight Review, (I left my log book in Italy and had my deckhand email me a pic of the page), insurance company didn't even want that.

It's the same issue as using white out, it's not the proper way by standards, but nobody is particularly enforcing the standard.
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I don't think there are actual standards, just random people saying "this is what you should do".
 
Everskyward said:
So every time you enter something in a field it is recorded? Even if the reason is that you made a typo and corrected it a few seconds later? Somehow I find this a little implausible, but you are the software developer. I can't believe that developers of electronic logbooks would go to that trouble. They also don't tell you how to retrieve that information or is that some super-secret conspiracy they have with the FAA? :D
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Well, ultimately, this would be done with some signing. Once the logbook entry is finalized, a checksum of that entry would be generated, then the instructor would sign that checksum. If the person modifies the entry after that, the checksum would no longer match, and it would be obvious that the person who signed it didn't sign what's currently there. With a good standard for logbook schema, a strong checksum algorithm, etc it'd be impossible to modify the entry and have it go undetected. Way easier to modify paper and pen.

The problem with all of this is that the software would have to be written very well, audited by security companies, and have a software development team that code reviews everything to ensure they don't introduce something that puts the signing layers at risk. It would take a fair amount of process and well written software for it to be something I would say is "solid" and I doubt any of the logbook companies do such things given the limited market. Building really secure software is expensive.

It's certainly technically feasible to do it in a way that's WAY more secure than a pen in a paper logbook is. There are many different schemes one could implement to accomplish such a thing. I just don't think any of the logbooks out there meet the standards I would personally trust.

Securing a logbook entry is trivial in comparison to the software I write to secure credit card numbers.

Signing stuff digitally isn't a new thing and there are really good ways to do it. But like anything the devil is in the details.
 
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EdFred said:
You could set it up a number of different ways. Usually a record is saved after all the information is entered and you move to the next line in the logbook. And yes, it's easy enough to set up another table so that anytime you make a change to a saved record it lists what the change is, when, etc...

It's not that difficult. Of course it is always possible to delete the secondary table...
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You COULD set something up like that but that doesn't mean that you would or are required to do so.
 
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