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I used to be in Walt's camp until a couple run-ins with the FAA. I still agree that a "description of work accomplished" is required, but am very careful with the description. Many years I've done over two dozen annuals and never had to do anything else for recurrency. This year I decided to sit through AMT's online recurrency. A lawyer lady did 3 of the seminars and I started out annoyed with the lawyer talk. Then I started listening. She said things like never sign off "performed SB in accordance with". Instead say " did such and such REFERENCING SB such and such. Words are legal traps that can hang you in todays world. The wrong words can make you legally responsible for things you haven't touched. You can put yourself on the hook for things you never imagined.
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Thanks. Good dialog here. |
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My comments were in regard to a builder who possesses the Repairman's Certificate and is the only individual involved in maintaining the aircraft. In this case, when I sign the logs for the Condition Inspection, no A&Ps are put at risk, all responsibility is on my shoulders due to the unique flexibility we have with EAB aircraft. By recording that the aircraft is in a condition for safe operation I am implying that all maintenance I have performed is such that the safety of the aircraft has not been compromised. This may come as a shock to many, but EAB only requires one entry per twelve months in a logbook.....the one that states a Condition Inspection has been satisfactorily completed. Anything we add to this requirement is just a memory aid to help us keep up with how long components have been in service, service intervals, etc. Of course, records will be reviewed by a prospective buyer, but the extent of those records are at our discretion. This is a fine point but one that was getting muddled when A&Ps in the discussion were stating how they felt records should be maintained in order to protect their business, and by extension how EAB records must be created in an identical manner. But I am in a different environment as a non-professional who isn't trying to protect a business. I can meet the recording requirements of EAB without necessarily going to the lengths the professional in the certificated world would find necessary. The flexibility we have in EAB is daunting to many with backgrounds in the certificated world, but liberating to many of us immersed in EAB. :) |
Well said Sam. You have always been a voice of reason on this forum. There are many more A/P's chiming in these days muddying up the EAB waters needlessly.
Thank you! |
Thanks Sam. Now I understand the perspective you are coming from.
Don |
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Do the usual EAB Operating Limitations specifically excuse the EAB owner from the requirements of tis FAR? §91.417 Maintenance records. (a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. ...... Just for completeness, this is the Applicability paragraph for the above FAR section - §91.401 Applicability. (a) This subpart prescribes rules governing the maintenance, preventive maintenance, and alterations of U.S.-registered civil aircraft operating within or outside of the United States. ........ Also note that 91.409 "Inspections" in the same subsection does specifically exclude EAB aircraft by way of their Experimental certificate. I would think the bold ones above would be applicable to EAB aircraft. Note also that the word "logbook" is only a convenience we use. The FAA usually uses the term "aircraft records". |
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I think the real "muddying of the waters" is the mindset that because its not required by the devil (FAA) I don't/won't do it and the paperwork is really not that important. |
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Having said all this, the RV-6 I built and have been flying for 16 years has a good set of records. When the engine was rebuilt the A&P and I discussed this situation and decided it would be in my best interest for future sale of the aircraft to include a comprehensive recording of the work performed and all the yellow tags. But that was at my discretion, not because it was required by regulation. Please don't assume that just because I have attempted to explore the regs that govern our aircraft, and because I may have speared a few sacred cows that I am advocating sloppy record keeping or an attitude of cutting corners. In this era where RVs have almost become a 'certificated' aircraft due to popularity, purchase by non-builders, and increasing maintenance by A&Ps, we must be very careful to not let the camel get his nose under the tent. We don't want to give away the wonderful flexibility we have with the EAB rule. |
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