Logbooks

[dmccormack]

Anyone provided only a printed copy of an electronic logbook at a practical, lately?

At my latest (CFI) he only wanted to see the written.

My handwriting has become so poor after years of computer use and forms-in-triplicate that it's barely legible.

My Excel logbook displays far more data and the math is accurate.

And it's legible.

 

[poadeleted20]

I'd be interested to hear about the repercussions of someone refusing to accept a printout of an electronic log record as long as each page was signed attesting to its accuracy. There is nothing in 61.51 or any other FAA regulation requiring logbooks to be handwritten.

 

[dmccormack]

I'd be interested to hear about the repercussions of someone refusing to accept a printout of an electronic log record as long as each page was signed attesting to its accuracy. There is nothing in 61.51 or any other FAA regulation requiring logbooks to be handwritten.

I agree.

The only downside to an electronic log is the lack of endorsements. All my endorsements are in the back of my written log.

 

[poadeleted20]

I agree.

The only downside to an electronic log is the lack of endorsements. All my endorsements are in the back of my written log.

Obviously, those would have to be kept separately from your e-log, because there is not yet a method for instructors to e-sign e-logs.

 

[dmccormack]

Obviously, those would have to be kept separately from your e-log, because there is not yet a method for instructors to e-sign e-logs.

Though the government does have policies for accepting "digital signatures."

The FAA may do well to see what other departments are doing in this regard.

 

[TMetzinger]

I've actually had instructors sign labels on my tablet PC that I could then print out and put in a logbook. Worked fine and no questions yet. I've also scanned in all my old endorsements. But it is a pain to capture the required signatures on dual received. I believe the next rev of Logbook Pro will include Digital Ink, so if you run it on a platform that has pen input you will be able to get your CFI's signature on various data objects.

The Government's law on Electronic Signatures purposefully kept the standard loose (thus you can e-file your taxes and never "sign" anything) and mandates that agencies have to accept electronic representations of signatures, not just "digital signatures" which are very secure (and expensive).

 

[poadeleted20]

I've actually had instructors sign labels on my tablet PC that I could then print out and put in a logbook.

I'm sure it works fine, but what's to prevent someone from cutting and pasting that signature to another endorsement? Absent a much more secure system, I would not recognize a such a signature (nor, do I think, would the FAA), nor would I sign anyone's tablet PC.

 

[EdFred]

I'm sure it works fine, but what's to prevent someone from cutting and pasting that signature to another endorsement? Absent a much more secure system, I would not recognize a such a signature (nor, do I think, would the FAA), nor would I sign anyone's tablet PC.

I could also scan a signature from my written logbook, and use it. If fraud is going to be committed, it's going to be committed.

As to the original question, I brought my laptop to my IFR, Comm, CFI, and SES rides with no issues. I did not show a printed copy for any of them, although I had one for a couple of them. My written logbook ONLY contains rides where training was received for the past 3 years because of the signature. If I got a CFI that wanted to see the written, he's going to have to keep wanting, because I don't have one, except for signatures.

 

[dmccormack]

I could also scan a signature from my written logbook, and use it. It fraud is going to be committed, it's going to be committed.

As to the original question, I brought my laptop to my IFR, Comm, CFI, and SES rides with no issues. I did not show a printed copy for any of them, although I had one for a couple of them. My written logbook ONLY contains rides where training was received for the past 3 years because of the signature. If I got a CFI that wanted to see the written, he's going to have to keep wanting, because I don't have one, except for signatures.

The issue isn't a "CFI who wants to see the written," but rather some agent of the FAA for a practical, or -- Lord Forbid -- after an accident.

 

[EdFred]

The issue isn't a "CFI who wants to see the written," but rather some agent of the FAA for a practical, or -- Lord Forbid -- after an accident.

Oh, I read your first post wrong. Thought it said a CFI wanted to see it. For my CFI ride, all he wanted to see was signatures since there's no hour requirements for SE after you have your commercial.

 

[poadeleted20]

I could also scan a signature from my written logbook, and use it.

Not if only original signatures are accepted.

 

[TMetzinger]

I'm sure it works fine, but what's to prevent someone from cutting and pasting that signature to another endorsement? Absent a much more secure system, I would not recognize a such a signature (nor, do I think, would the FAA), nor would I sign anyone's tablet PC.

A person with evil intent can forge a signature in ink too. The only provenance of an unnotarized pen and ink signature is analysis by an expert, or validation/revocation by the purported signer. Given the low "value" (in money/criminal fraud terms) of signatures in a logbook, there has been no historical need to make them very secure. There just hasn't been a level of fraud high enough to require more secure recordkeeping.

You as an individual do have the option to reject that electronic signature. The government, by law, has to abide by the current (loose) standard, unless they first publish rules through the rulemaking progress stating what their specific standards are.

So, for instance, DEA has a very secure PKI based system for electronic transactions and reporting of controlled substances. They went through the whole rulemaking process and codified their system, and can therefore require all their registrants to pay the fees and get a (very) secure digital ID.

The FAA has probably already set agency precedent with IACRA and the Electronic Medical System, both of which require signatures, and neither of which are digitally secure. But I'm not familiar with the business process, does a paper copy of records from these systems get signed and forwarded as well? I'm pretty sure that lots of airline/manufacturer maintenance systems nowadays have AMTs and Inspectors signing off the work electronically. Those systems are FAA-approved.

The FAA has also agreed that photocopies are accepted when they are the best available document (when an original log is lost or claimed to be lost).

When a logbook product comes out that will allow for electronically capturing a signature, I'll be happy to be a guinea pig. It would certainly be more convenient and more secure to be able to have your logbook in digital format. You'd be able to make backups and not worry about losing all your info, accident investigators would have a better shot of reconstructing a pilot's history, etc.

 

[poadeleted20]

A person with evil intent can forge a signature in ink too.

But it's a whole lot harder.

The only provenance of an unnotarized pen and ink signature is analysis by an expert, or validation/revocation by the purported signer. Given the low "value" (in money/criminal fraud terms) of signatures in a logbook, there has been no historical need to make them very secure. There just hasn't been a level of fraud high enough to require more secure recordkeeping.

The FAA has been down that road before, and handwriting analysis has been sufficient to prove their case.

You as an individual do have the option to reject that electronic signature. The government, by law, has to abide by the current (loose) standard, unless they first publish rules through the rulemaking progress stating what their specific standards are.

Actually, by law, the FAA can set its own standards by interpreting its own regulations -- see Administrator v. Merrell. So far, with the exception of IACRA, I haven't seen the FAA accepting Part 61-required logbook endorsements with anything but pen-and-ink signatures.

The FAA has probably already set agency precedent with IACRA and the Electronic Medical System, both of which require signatures, and neither of which are digitally secure.

You sure about that? I have been using IACRA with the understanding that my e-signature on the 8710-1 is password-protected and cannot be made or altered by others.

But I'm not familiar with the business process, does a paper copy of records from these systems get signed and forwarded as well?

No.

 

[TMetzinger]

But it's a whole lot harder.
The FAA has been down that road before, and handwriting analysis has been sufficient to prove their case.
Actually, by law, the FAA can set its own standards by interpreting its own regulations -- see Administrator v. Merrell. So far, with the exception of IACRA, I haven't seen the FAA accepting Part 61-required logbook endorsements with anything but pen-and-ink signatures.
You sure about that? I have been using IACRA with the understanding that my e-signature on the 8710-1 is password-protected and cannot be made or altered by others.
No.

Um.... The FAA can absolutely interpret it's own regulations, but if they haven't promulgated an agency regulation on signatures (which they haven't to my knowledge), they are bound by the basic electronic signature act (I think it was 99 or 2000). I think that they just haven't gotten to the point yet, and that they probably will in the future. Again, that's the general principle behind the Electronic Signature Act, and like you, I don't see any value in testing those waters. By the time someone "won" a case for an electronic logbook record, the FAA would probably have set up clear regulations for everyone else.

Your IACRA signature is password-protected, meaning that it's "somewhat" secure. A person with a key logger, an FAA systems administrator, or someone shoulder-surfing could easily compromise your password, and thus become "you". How did you initially prove your identity to be issued your IACRA password? How often are you forced to change the password? All of these things affect the confidence a relying party can have on your "signature".

The security standard for a transaction is usually based on the value of the transaction. For the relatively low value of these IACRA transactions a password seems reasonable. But for high value transactions, usually multiple factors are required. Your ATM requires physical possession of your card, AND knowledge of your PIN. One very-high value system I know of requires knowledge of a PIN, possession of a token, and a biometric mechanism to activate the token.

Sorry to be so long-winded about this, but digital signatures are something I'm an expert in - I used to chair the DOJ technical working group on PKI and we originally wanted to mandate a high level of integrity, but the legal working group on PKI (wisely) specified the flexiblity of different levels of integrity for different transaction values. If us "geeks" had won the argument we'd all still be waiting for face-to-face issuance of expensive tokens to citizens, and we wouldn't have any of the good things (like IRS E-File) we have today. Sometimes it's very good to be wrong.

It will be interesting to see how things trend over time - I know some DPE's hated the coming of IACRA, and some AMEs hate that electronic system too.

Best wishes,

 

[midlifeflyer]

Not if only original signatures are accepted.

That's the issue. Are they? Federal and state laws say they are, but may be subject to restrictions.

The fact of the matter is that, without appropriate security, electronic records are much easier to falsify. And, in terms of the disagreement between you an Tim on the endorsement issue I don't see the basis for a distinction between records that are endorsed by someone else and records that are mine. Heck, if anything, Tim's scanned-in signatures that Tim has have far =more= inherent reliability than the pilot's own flight time entries.

With endorsements, there's a cross-check - the endorser's records (not necessarily required, but generally kept). Both can be falsified, but for the personal flight time, there's a much greater ability to falsify (than with paper records) with less chance of detection.

My current personal take (subject to change without notice ) is that I'm not prepared to rely solely on an eLog for either my flight time or endorsements that I need until there is some guidance on the issue from the FAA. (I hope that doesn't make me anti-tech; I've been using an eLog for about 15 years now - I originally wrote it in Paradox for DOS.) OTOH, I would have no hesitation signing someone else's tablet PC logbook. if that's they way they chose to verify their flight time.

 

[EdFred]

Not if only original signatures are accepted.

I can scan it, and reprint it in a written logbook (without using a sticky label) quite easily if I so desire. And it's going to be quite difficult to tell if it's original or not. As I said, if fraud it going to be committed, it is going to be committed.

 

[dmccormack]

With endorsements, there's a cross-check - the endorser's records (not necessarily required, but generally kept). Both can be falsified, but for the personal flight time, there's a much greater ability to falsify (than with paper records) with less chance of detection.

There is precedent for the FAA reviewing hobbs and tach time on airplanes to determine the veracity of logbook entries -- after enforcement action or accident, of course.

 

[poadeleted20]

Um.... The FAA can absolutely interpret it's own regulations, but if they haven't promulgated an agency regulation on signatures (which they haven't to my knowledge), they are bound by the basic electronic signature act (I think it was 99 or 2000).

I'm not familiar enough with that act to comment, but since the FAA need not give its interpretation of an FAR in advance of an enforcement action (once again, see Administrator v. Merrell), I wouldn't count on it.

 

[poadeleted20]

I can scan it, and reprint it in a written logbook (without using a sticky label) quite easily if I so desire. And it's going to be quite difficult to tell if it's original or not.

I don't think it would take a document expert more than five seconds to tell if it's an original pen signature or computer printed -- or does your printer do impressions, too?

 

[EdFred]

I don't think it would take a document expert more than five seconds to tell if it's an original pen signature or computer printed -- or does your printer do impressions, too?

"This is a photocopy of my logbook because I lost my original logbook."

Or are backup copies now invalid? If so, why do we bother making backups?

 

[poadeleted20]

"This is a photocopy of my logbook because I lost my original logbook."

I still think it's not hard for an expert to tell if a logbook copy has been photoshopped.

 

[TMetzinger]

That's the issue. Are they? Federal and state laws say they are, but may be subject to restrictions.

The fact of the matter is that, without appropriate security, electronic records are much easier to falsify. And, in terms of the disagreement between you an Tim on the endorsement issue I don't see the basis for a distinction between records that are endorsed by someone else and records that are mine. Heck, if anything, Tim's scanned-in signatures that Tim has have far =more= inherent reliability than the pilot's own flight time entries.

With endorsements, there's a cross-check - the endorser's records (not necessarily required, but generally kept). Both can be falsified, but for the personal flight time, there's a much greater ability to falsify (than with paper records) with less chance of detection.

My current personal take (subject to change without notice ) is that I'm not prepared to rely solely on an eLog for either my flight time or endorsements that I need until there is some guidance on the issue from the FAA. (I hope that doesn't make me anti-tech; I've been using an eLog for about 15 years now - I originally wrote it in Paradox for DOS.) OTOH, I would have no hesitation signing someone else's tablet PC logbook. if that's they way they chose to verify their flight time.

Mark, we're in violent agreement. I hope for some guidance as this sort of practice becomes more ubiquitous. My doctor now takes all his notes on a tablet, signs them, and my "official" health care record is now completely digital.

The base fact of signature is that the RELYING PARTY (the person who is reviewing/validating the signed transaction) generally sets the standard for the signature based on his/her needs.

The problem under discussion is that in many cases the relying party is a DPE, CFI, FAASTeam Rep (I approve wings requests for credit based on scanned images of log entries or completion certificates sent to me via e-mail - in fact, that's what the FAA has told us to do!), and there isn't any set standard. So we end up seeing a wide range of responses - some will accept digital information, some want to see pen and paper.

The current prudent thing is to use pen and paper, as that is a standard accepted by anyone, for things that require it.

That's not saying the "trust" we have in pen and paper is necessarily reasonable - the initial relying parties will usually not be able to detect a forged signature with pen and paper, unless the signature forged is their own or one very familiar to them. Simple techniques for forging a signature (scan a signature, print it on a transparency, impress it on to paper and then fill in the impression) will get by the naked eye. It's only when there is doubt based on other causes (repudiation by the supposed signer, history of fraud, contradicting evidence) that an expert will be consulted.

All I've tried to say is that if someone wanted to go to the trouble (time and money) to contest a situation where an electronically signed record was rejected by the FAA without a prior published standard to support that rejection, they would have a reasonable chance of eventual success. The cost of achieving that success would probably be wildly out of proportion to its benefit, however.

So, as I said, Ron's approach is practical and prudent.

 

[midlifeflyer]

There is precedent for the FAA reviewing hobbs and tach time on airplanes to determine the veracity of logbook entries -- after enforcement action or accident, of course.

I wouldn't be in the least bit surprised. I'm sure there is precedent for just about evey form of factual investigation by a givernemnt agency.

 

[dmccormack]

I wouldn't be in the least bit surprised. I'm sure there is precedent for just about evey form of factual investigation by a givernemnt agency.

Sadly, it's the same with Insurance. You can say you have 1200 hours time in type -- they'll dutifully take down all you report and insure you.

Until the accident.

 

[midlifeflyer]

Mark, we're in violent agreement.

I figured as much.