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KennyFlys
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A recent copy of that log page would be good to keep with the log that signs out with the aircraft during rentals.
Operator
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Tom-D
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I enjoyed reading your post, thinking about the shimmy dampener thread going on now, and how many FBOs rent unairworthy aircraft, just because the renter will not insist they get fixed. AD compliance is just one side to this coin.
As a renter you have no idea if they even freakin exist. It's a moronic position and if it's written that way, it's a bloody error. You can't be held liable for information you have no access to.
dmccormack
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Dan Mc
If you want to be completely anal, you cross reference the printout to the online AD list (http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAD.nsf/)
The printout lists ALL ADs for that model -- the A/C has to have the applicable S/N and installed equipment to be addressed.
Richard
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Ack...city life
All the IA signature says is that on THAT day the aircraft was in compliance. No gaurantee for the next day or any day after.
dmccormack
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Hunh?
You mean if nothing changes -- no dings, no missing parts -- the IA compliance statement is only in force up until the moment the last flourish of the signature?
That seems a bit ridiculous.
Tom-D
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I can legally sign off an annual inspection as airworthy with an AD with .001 hour left on the time requirement.
TMetzinger
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Yep, or knowing the AD becomes effective tomorrow, doesn't change the fact that the airplane is airworthy TODAY.
Richard
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Ack...city life
Even if nothing changes...how in the world can the IA be held responsible for what happens in the future (the day after the IA signs)
Think of it as the "burden of proof" rests with the operator. Prove, to ascertain that the craft is in compliance.
ntbjounin
Pre-takeoff checklist
"It was airworthy when i took off!!!! then it became unairworthy in mid flight... DUHHH"
dmccormack
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I understand PIC authority/responsibility, but what's the use of the IA's statement if it is past tense?
Everskyward
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Everskyward
What should really happen is that there should be a notation on the clipboard, or however you check the plane out, which states the date of the next required maintenance and the tach or hobbs of the next required maintenance. That way the pilot knows not to overfly those numbers.
dmccormack
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Like this?
Everskyward
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That's good, but I was thinking of something even simpler. The ones I'm used to seeing have the next inspection in hours, the next inspection by date and the next inspection by cycles. It doesn't even really matter what that inspection is going to be, just that you can't overfly it.
Your form is good, though, because it gives students an reminder of the types of inspections which are necessary plus you don't need to hunt the A&P down to find out if the next due item is going to take 5 minutes (fire bottle inspection) or 5 weeks.
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Greg Bockelman
Which is pretty much exactly what you seem to be saying needs to be done to protect the PIC from unpleasantness.
jesse
Touchdown! Greaser!
I'm not even sure that'd do it for you. What about non-factory equipment? you'd have to get the serial number for all of that...and check all of that...and who knows how many other exceptions there could be.
No, that only gets you a probably incomplete list, and even when complete, as renter it would be your duty to make sure they were all complied with, so you as a renter would effectively have to have an annual done on every aircraft before you rent it. It's too stupid to think about. Renter is not Operator in the context of maintenance.
Hopefully, there's an AD sheet in the log book. We used to put in a post it with the times/dates for next on each of the recurrents. Now with computers, the paperwork has completely changed in 20 years and you just give them a print out. For the renter/pilot though, I still maintain that for the purpose of AD compliance and Maint, is not an operator and was never intended by the people writing the rules to be responsible for AD compliance. It wouldn't be found to be a legaly required thing because the process required to go past the point of looking at the log for a current annual/100hr and other inspections are signed off and in date is just too onerous a burden. Most of the time, the last annual RTS log entry will give the next time for recurring as well, so if it's there you can check, but it would not positively confirm or deny an AD even applied or not, but that last log entry is the only thing we can go by as renter/pic to determine paperworthyness. You still have to preflight to determine airworthyness.
As much discussion and attention as I see here about this basically irrellevant crap, I'd feel much better if I saw people discussing how to do the important parts of a preflight. I see completely bogus preflights done all the time and on rental planes.
TMetzinger
Final Approach
Your wish is my command - look for a new thread on preflights.Hopefully, there's an AD sheet in the log book. We used to put in a post it with the times/dates for next on each of the recurrents. Now with computers, the paperwork has completely changed in 20 years and you just give them a print out. For the renter/pilot though, I still maintain that for the purpose of AD compliance and Maint, is not an operator and was never intended by the people writing the rules to be responsible for AD compliance. It wouldn't be found to be a legaly required thing because the process required to go past the point of looking at the log for a current annual/100hr and other inspections are signed off and in date. Most of the time, the last annual RTS log entry will give the next time for recurring as well, so if it's there you can check, but it would not positively confirm or deny an AD even applied or not, but that last log entry is the only thing we can go by as renter/pic to determine paperworthyness. You still have to preflight to determine airworthyness.
As much discussion and attention as I see here about this basically irrellevant crap, I'd feel much better if I saw people discussing how to do the important parts of a preflight. I see completely bogus preflights done all the time and on rental planes.
jmaynard
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You know, all of this makes me really happy I have a new airplane with no ADs ever issued against it, and manufacturers' certifications that all ADs have been complied with before installation of the various components...
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Greg Bockelman
On that, I agree.
stingray
Line Up and Wait
Hopefully, there's an AD sheet in the log book. We used to put in a post it with the times/dates for next on each of the recurrents. Now with computers, the paperwork has completely changed in 20 years and you just give them a print out. For the renter/pilot though, I still maintain that for the purpose of AD compliance and Maint, is not an operator and was never intended by the people writing the rules to be responsible for AD compliance. It wouldn't be found to be a legaly required thing because the process required to go past the point of looking at the log for a current annual/100hr and other inspections are signed off and in date is just too onerous a burden. Most of the time, the last annual RTS log entry will give the next time for recurring as well, so if it's there you can check, but it would not positively confirm or deny an AD even applied or not, but that last log entry is the only thing we can go by as renter/pic to determine paperworthyness. You still have to preflight to determine airworthyness.
As much discussion and attention as I see here about this basically irrellevant crap, I'd feel much better if I saw people discussing how to do the important parts of a preflight. I see completely bogus preflights done all the time and on rental planes.
The AI that I work with just found out that the FAA wants the AD's written IN the log book. A plane (AA1A) that we recently did the annual on then crashed because of pilot error, we repaired it, (pilot had to do a 701?) crashed it again two weeks later. I think he ran out of fuel. He flies out of his own field. The FAA asked the AI to see the AD compliance. AI said it was with the log book. FAA says can't find it. Pilot probably threw it away to shift the blame to the AI. FAA says it has to be entered IN the log book not on a sheet. AI says that's not what you said before.
Dan
Best that I knew, when you deal with an AD, it has always been recorded in the log book in normal fashion. The AD log sheet I'm refering to is a supplemental sheet to help steamline looking them up in the log by creating a compiled index of those that are in the log.
Stache
Pre-takeoff checklist
I know this is a bit long, but this is a highly charged subject so bare with me.
In order for an aircraft to be considered airworthy two conditions must be met. The first condition is that the aircraft must conform to its type design. In the context of maintenance under Part 43 of the Federal Aviation Regulations, conformity to the type design is attained when maintenance work is done in such a manner, and materials used are of such quality, that the condition of the aircraft, aircraft engine, propeller or appliance worked on will be at least equal to its original or properly altered condition (14 CFR Section 43.13(b)). In addition, all required equipment and instruments must also be installed and operable for the aircraft to be operated. The second condition is that the aircraft must be in condition for safe operation. This condition requires the determination that the aircraft is in condition for safe flight. If one or both of these conditions are not met, the aircraft would be unairworthy.
Under the provisions of 14 CFR Section 91.405, a Part 91 operator may not operate an aircraft following maintenance unless an appropriate entry is made in the aircraft log that no known condition exists that would make that aircraft unairworthy. An incorrect or intentionally misleading entry in the aircraft log, which misrepresents the physical condition of the aircraft as being safe for operation, would conceal the fact that the aircraft was unairworthy.
The question keeps coming up is the mechanic or the pilot responsible for the airworthiness of the aircraft. Let’s look at the rule in 14 CFR Section 91.7. This section states, in pertinent part, that no person may operate a civil aircraft unless it is in an airworthy condition. The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy conditions occur. Seem pretty clear to me.
The FAA has set up a complex division of responsibility that allows no one and everyone to be accountable. Primary responsibility is said to rest on the owner operator. (91.403 and 405) The owner operator must ensure the compliance of all required inspections and airworthiness directives.
The problem in knowing airworthiness lies in the need for specificity where the complaining pilots are unable to put the problem into words. The average pilot has a fear of being wrong about bringing up a discrepancy that affects the airworthiness of an aircraft. Another fear is that the availability and cost of flying may be affected by a reported discrepancy. Should a pilot hedge in the depiction of a problem if it means that the situation is not fully identified.
AD's are regulations issued under part 39. Therefore, no person may operate a product, to which an AD applies, except in accordance with the requirements of that AD. Owners and operators should understand that to "operate" not only means piloting the aircraft, but also causing or authorizing the product to be used for the purpose of air navigation, with or without the right of legal control as owner, lessee, or otherwise. Compliance with emergency AD's can be a problem for operators of leased aircraft because the FAA has no legal requirement for notification of other than registered owners. Therefore, it is important that owner(s) of leased aircraft make the AD information available to the operators leasing their aircraft as expeditiously as possible, otherwise the lessee may not be aware of the AD and safety may be jeopardized.
The Federal Aviation Regulation requires a presentation showing the current status of applicable airworthiness directives, including the method of compliance, and the signature and certificate number of the mechanic or repair agency who complied with the AD.
It is the aircraft owner/operator’s mandatory responsibility to assure compliance with all pertinent AD notes. This includes those ADs of a recurrent or repetitive nature; for example, an AD may require a certain inspection every 100 hours. This means that the particular inspection shall be made and recorded after every 100 hours of flight time.
“By the FBO making their plane available for rent, are they IMPLYING (Implied Warranty) that the plane is airworthy as far as AD's, etc.?”
The answer is YES the FBO is implying the aircraft is airworthy (NTSB ruling). However it is still upon the PIC to perform a proper preflight inspection and part of that in record keeping. I would hope the aircraft if leased comes with a status sheet indicating when the inspections and reoccurring AD’s are due. If not it’s the responsibility of the PIC to check the actual aircraft records to find out (due diligence). Keep in mind aircraft airworthiness is a shared responsibility from owner, mechanic (only until the ink dries), dispatcher (FBO), and the PIC.
Just one man’s opinion.
In order for an aircraft to be considered airworthy two conditions must be met. The first condition is that the aircraft must conform to its type design. In the context of maintenance under Part 43 of the Federal Aviation Regulations, conformity to the type design is attained when maintenance work is done in such a manner, and materials used are of such quality, that the condition of the aircraft, aircraft engine, propeller or appliance worked on will be at least equal to its original or properly altered condition (14 CFR Section 43.13(b)). In addition, all required equipment and instruments must also be installed and operable for the aircraft to be operated. The second condition is that the aircraft must be in condition for safe operation. This condition requires the determination that the aircraft is in condition for safe flight. If one or both of these conditions are not met, the aircraft would be unairworthy.
Under the provisions of 14 CFR Section 91.405, a Part 91 operator may not operate an aircraft following maintenance unless an appropriate entry is made in the aircraft log that no known condition exists that would make that aircraft unairworthy. An incorrect or intentionally misleading entry in the aircraft log, which misrepresents the physical condition of the aircraft as being safe for operation, would conceal the fact that the aircraft was unairworthy.
The question keeps coming up is the mechanic or the pilot responsible for the airworthiness of the aircraft. Let’s look at the rule in 14 CFR Section 91.7. This section states, in pertinent part, that no person may operate a civil aircraft unless it is in an airworthy condition. The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy conditions occur. Seem pretty clear to me.
The FAA has set up a complex division of responsibility that allows no one and everyone to be accountable. Primary responsibility is said to rest on the owner operator. (91.403 and 405) The owner operator must ensure the compliance of all required inspections and airworthiness directives.
The problem in knowing airworthiness lies in the need for specificity where the complaining pilots are unable to put the problem into words. The average pilot has a fear of being wrong about bringing up a discrepancy that affects the airworthiness of an aircraft. Another fear is that the availability and cost of flying may be affected by a reported discrepancy. Should a pilot hedge in the depiction of a problem if it means that the situation is not fully identified.
AD's are regulations issued under part 39. Therefore, no person may operate a product, to which an AD applies, except in accordance with the requirements of that AD. Owners and operators should understand that to "operate" not only means piloting the aircraft, but also causing or authorizing the product to be used for the purpose of air navigation, with or without the right of legal control as owner, lessee, or otherwise. Compliance with emergency AD's can be a problem for operators of leased aircraft because the FAA has no legal requirement for notification of other than registered owners. Therefore, it is important that owner(s) of leased aircraft make the AD information available to the operators leasing their aircraft as expeditiously as possible, otherwise the lessee may not be aware of the AD and safety may be jeopardized.
The Federal Aviation Regulation requires a presentation showing the current status of applicable airworthiness directives, including the method of compliance, and the signature and certificate number of the mechanic or repair agency who complied with the AD.
It is the aircraft owner/operator’s mandatory responsibility to assure compliance with all pertinent AD notes. This includes those ADs of a recurrent or repetitive nature; for example, an AD may require a certain inspection every 100 hours. This means that the particular inspection shall be made and recorded after every 100 hours of flight time.
“By the FBO making their plane available for rent, are they IMPLYING (Implied Warranty) that the plane is airworthy as far as AD's, etc.?”
The answer is YES the FBO is implying the aircraft is airworthy (NTSB ruling). However it is still upon the PIC to perform a proper preflight inspection and part of that in record keeping. I would hope the aircraft if leased comes with a status sheet indicating when the inspections and reoccurring AD’s are due. If not it’s the responsibility of the PIC to check the actual aircraft records to find out (due diligence). Keep in mind aircraft airworthiness is a shared responsibility from owner, mechanic (only until the ink dries), dispatcher (FBO), and the PIC.
Just one man’s opinion.
Tom-D
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Tom-D
The AD compliance must be in the "MAINTENANCE RECORDS" no guidance is given as to the form of these records.
There are several AD compliance companies that provide a separate records of AD compliance, if these compliance records are placed in the MAINTENANCE RECORDS. you are good to go.. and legal as you can get.
There is no requirement for the AD to be listed in the "LOG BOOK"
http://www.adlog.com/
Tom-D
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Tom-D
Tom-D
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How does he cope with any aircraft that has the ADlog system? that is a separate record.
TangoWhiskey
Touchdown! Greaser!
If you try that excuse with the ALJ, you better be able to demonstrate that you landed as soon as practicable when it became apparent the aircraft was no longer airworthy, per CFR 91.7(b):
flyingcheesehead
Taxi to Parking
I heard an interesting discussion between Front Range tower and a pilot the other day...
Front Range tower: "Skywagon 60U, recycle transponder."
Skywagon: "Uhhh, my transponder is inop."
Front Range: "60U, were you aware of that before you took off?"
Skywagon: "Yeah, it was inop on the way in too."
Front Range: "60U, roger, your transpoder appears inoperative."
Skywagon: "Affirmative, transponder is inoperative." (Didn't get the hint, apparently)
Front Range: "60U, an operating Mode C transponder is required in the Denver area."
Skywagon: "Uhhhh, we have it scheduled for repair tomorrow."
That guy hung himself on tape. (60U is made up, BTW...)
stingray
Line Up and Wait
That is the way he always did it just provided a print out from his program for the AD's. The FAA just said 1 week ago this is not acceptable, it must be written in the log book. This is second hand info for me I was not at the table when the conversation took place. If that is the case I know there are a lot of log books out there not up to pare with that ruling.
Dan
TMetzinger
Final Approach
It ain't a RULING, it's an opinion - one that should be reviewed by those higher in the food chain. At one place, they have the ADLOG system but still list compliance with the individual AD's in the log - their system just generates a narrative on a label and they paste it in the log.
Tom-D
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Tom-D
Some one better be able to show me the new rule, if they plan on busting me.
Simply because the FARs do not give us guidance as to what form the "MAINTENANCE RECORS" are required to be. There is no requirement for a "BOOK" in any FAR.
Simply because the FARs do not give us guidance as to what form the "MAINTENANCE RECORS" are required to be. There is no requirement for a "BOOK" in any FAR.
TMetzinger
Final Approach
A record "acceptable to the administrator" is how it's published, I believe. The inspector may feel the record is not acceptable. There's no immediate remedy for an inspector who has an outrageous opinion (none that aren't felonies, anyway), so the only option is to speak to his boss, and then carry it up the food chain.
Stache
Pre-takeoff checklist
Just for the record AD’s do NOT have to be listed in the aircraft logbook. FAR 91.417 states; “The current status of applicable airworthiness directives (AD) including, for each, the method of compliance, the AD number, and revision date. If the AD involves recurring action, the time and date when the next action is required.”
Keep in mind there are several ways to keep aircraft records one is logbooks with an AD compliance list separate from the logbook. The FARs only refer to aircraft records not logbooks. Adlog is another example of keeping aircraft records. Even writing it on toilet paper is another acceptable method to the far extreme.
AC 43.9 explains this subject pretty well.
Just one man’s opinion.
Keep in mind there are several ways to keep aircraft records one is logbooks with an AD compliance list separate from the logbook. The FARs only refer to aircraft records not logbooks. Adlog is another example of keeping aircraft records. Even writing it on toilet paper is another acceptable method to the far extreme.
AC 43.9 explains this subject pretty well.
Just one man’s opinion.
stingray
Line Up and Wait
I will pass that along, although it may not be wise for him to argue with the inspector.
Dan
gismo
Touchdown! Greaser!
I understand that an AD compliance list should/could be a separate document that's part of the aircraft maintenance records, but I assume that anytime a maintenance action is performed to comply with an AD, a separate entry in the records (logbook?) complete with appropriate signoff (pilot/mechanic/inspector) is needed. Perhaps this is what Dan's mechanic/AI was talking about (e.g. the FSDO wouldn't accept the AD compliance list in lieu of maintenance activity log entries.