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

[roger lee]

Good & Legal Documentation
USA & FAA vs a Mechanic’s Documentation
Piloting, being an owner or a mechanic takes responsibility and attention to what’s legal or the “the best practice” in maintenance and that helps keep us all safe and away from bad legalities.
Watch what you write it can and will be used either to support you for the good or cause you bad legal issues. I’m writing this in the hopes to help owners and mechanics to not be a target in case of an issue and it doesn’t have to be something you did wrong to become that target. As an owner / pilot make sure the mechanic or yourself does the right thing and document’s so you aren’t hanging out on a limb. You’re also paying good money for an inspection and it should be done the way you need it done and not always the way some people do them. I spent 30 years in the field and watched countless times when people from all walks of life got burnt to the ground in court or legal issues all because of either poor or no documentation. The other issue with poor documentation is getting Rotax or the aircraft’s MFG help. If you didn’t ever do your Rotax 25 hr. warranty inspection or you have poor logbooks you may not get help during warranty or at other times. You’ll be ask to fill out a Customer Service Information Report and send in your logbook entries.
In the last few years I have seen more and more SLSA logbook entries state they were inspected in accordance with FAA part 43 checklist. The SLSA Mfg’s must provide a maintenance manual and inspection checklist and you must use it over the FAA part 43 checklist. If you inspected an SLSA or an SLSA that was turned into an ELSA and you used a part 43 checklist then you missed half of what the MFG has listed for their specific inspection. Now you’re hanging out on that proverbial limb for trouble. SLSA aircraft have maintenance manuals with inspection checklist in them. It’s easy to just print the fuselage and Rotax maintenance checklist and use it. If your mechanic doesn’t do it print it out and give it to them. I print a checklist for the Rotax and one from the aircraft Mfg when I inspect aircraft and fill it out. I sign off everything and if I touch, tweak, torque or change something it gets annotated in the margin. Then I give this checklist to the owner. I do the same thing with a Rotax maintenance checklist and the owner gets this. A normal inspection logbook for me is usually a full logbook page long and typed in #9 font so it all fits and of course it’s more readable than many hand written entries. A Rotax rubber change and an annual is usually two pages long. This shows you followed the SPECIFIC aircraft Mfg’s and Rotax’s inspection items and didn’t use a general FAA general part 43 checklist and missed many items. I see some only doing 100 hr. inspections and no mention ever of an annual condition inspection and vise versa in the logbooks. You could just write you are doing the 100 hr. and annual condition inspection at the same time.
I see too many three liner logbook labels. This is just being lazy. The FAA says this is the bottom of a barely legal logbook entry depending on your wording. They usually say they inspected this aircraft IAW (In Accordance With) the aircrafts maintenance manual and then “put it back in service”. Bad idea for any LSA. When you wrote you did an inspection IAW the maintenance manual that means you did everything on that checklist and we know many times that doesn’t happen. Very few actually use the real checklist. So if anything happens to that plane or engine you better be able to prove what you did and the numbers associated with it because you put in writing that you did it “IAW” the manual. I’ve had a few companies ask me to call mechanic’s and ask what they really did. 100% of those failed to even do half the proper inspection for that aircraft or even have a clue to what any numbers were i.e. gearbox friction torque check or plug gaps or compression test, ect... Then they write they put the SLSA back in service. You can’t do that for LSA. You must “find it in a condition for safe operation”. This is not a certified aircraft so it doesn’t just get returned to service. Plus the bottom line in court is “if you didn’t write it you didn’t do it”. Complain all you want, but that’s what the courts and lawyers standards are for any trial and so does the FAA and insurance companies.
This is like the Internal Revenue Service at tax time. You can claim anything you want until you get caught or audited. You don’t need to be Earnest Hemingway to document. All you are is a secretary and write it any way you want, just write it down. If you did something then write it down. i.e. oil change or spark plugs or gearbox friction torque, ect…. Example only: You replaced all spark plugs with new NGK DCPR8E plugs, gapped them at .025 and applied thermal paste. You performed and oil change. You drained the oil and installed 3 liters of Aero Shell Sport Plus 4, installed a new Rotax oil filter, Inspected the magnetic plug and found it clean then safety wired the mag plug and oil tank plug back in place. Removed, cleaned and oiled the K&N air filter. You did a gearbox friction torque check and it was 480 in/lbs. You say why write that I put safety wire on the magnetic plug or oil tank plug. Because in let’s say 6 months the plane goes down because of an engine failure and they find the magnetic plug gone. Then you’ll know it wasn’t you and someone else was in there after you and they failed to apply safety wire. Protect yourself.
So now the owner knows you did a complete job, knows what you did and for the next inspection has information to compare trends happening. It’s so easy to protect yourself and the owner. Plus it makes the next mechanic’s job easier because he’ll know what was actually done or not done or what SB’s were followed. Good documentation also makes the plane easier to sell and keeps its value up higher. Last, but not least. If someone writes a three liner for an annual condition inspection and says that the rest is on file then they must have it already done. Then why didn’t they just reach over and hit the print button and give you the additional logbook entry information? What happens if their system gets wiped out by hackers or a total system failure. Make them print out and give you what they just said they have. You paid for it.
§ 107.140 Category 4 operations.
(c) Maintenance requirements for Category 4. The owner must (unless the owner enters into an agreement with an operator to meet the requirements of this paragraph (c), then the operator must) meet the requirements of this paragraph (c):
(1) Ensure the person performing any maintenance, preventive maintenance, alterations, or inspections:
(i) Uses the methods, techniques, and practices prescribed in the manufacturer's current maintenance manual or Instructions for Continued Airworthiness that are acceptable to the Administrator, or other methods, techniques, and practices acceptable to the Administrator;
(ii) Has the knowledge, skill, and appropriate equipment to perform the work;
From me: Take a Rotax class. Way too many mechanics making bad mistakes and leaving themselves open for trouble.
(iii) Performs the maintenance, preventive maintenance, or alterations on the small unmanned aircraft in a manner using the methods, techniques, and practices prescribed in the manufacturer's current maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator;
(iv) Inspects the small unmanned aircraft in accordance with the manufacturer's instructions or other instructions acceptable to the Administrator; and
(v) Performs the maintenance, preventive maintenance, or alterations using parts of such a quality that the condition of the aircraft will be at least equal to its original or properly altered condition.
From me: Don’t use aftermarkets parts. They aren’t acceptable and you can’t prove they are equal to an OEM part. Don’t open a door you can’t close.
(2) Maintain all records of maintenance, preventive maintenance, and alterations performed on the aircraft and ensure the records are documented in a manner acceptable to the Administrator. The records must contain the description of the work performed, the date the work was completed, and the name of the person who performed the work.
(3) Maintain all records containing—
(i) The status of life-limited parts that are installed on, or part of, the small unmanned aircraft;
(ii) The inspection status of the aircraft; and
(iii) The status of applicable airworthiness directives including the method of compliance, the airworthiness directive number, and revision date. If the airworthiness directive involves recurring action, the record must contain the time and date of the next required action.
(4) Retain the records required under paragraphs (c)(2) and (3) of this section, as follows:
(i) The records documenting maintenance, preventive maintenance, or alterations performed must be retained for 1 year from when the work is completed or until the maintenance is repeated or superseded by other work.
(ii) The records documenting the status of life-limited parts, compliance with airworthiness directives, and inspection status of the small unmanned aircraft must be retained and transferred with the aircraft upon change in ownership.
(5) Ensure all records under paragraphs (c)(2) and (3) of this section are available for inspection upon request from the Administrator or any authorized representative of the National Transportation Safety Board (NTSB).
And here it is. Just remember: If you didn’t write it you didn’t do it and there is no way you can prove it especially after it’s way down the calendar time.
Fly safe, have fun and be all you can be!
Here’s another documentation article.
https://www.rotax-owner.com/en/rotax-bl ... everything

[3Dreaming]

What does CFR part 107 have to do with light sport aircraft?

[roger lee]

Hi All,
Sorry I got two papers crossed up. Part 107.140 has nothing to do with my subject. The first part of the post is fine, but when you get to 107 part forget it. So forget that part.

I would delete it if I could.