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01-27-2015, 06:30 AM
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Join Date: Sep 2006
Location: Defiance, MO
Posts: 1,674
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Quote:
Originally Posted by Walt
This is how I would do it, something like:
"removed prop, engine and engine mount to access nose gear leg retainer bolt. Reamed upper nose gear leg bolt hole and engine mount for installation of taper pin, installed pin. Re-installed engine mount, engine and prop. Accomplished ground runs, leak checks and systems operational checks with no discrepancies noted."
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Not an A&P, but I am an engineer, so the only thing I would add to the above is the process used to do the work. I would add a phrase like "installed taper pin per AC 43-13 1b"
__________________
Philip
RV-6A - 14+ years, 950+ hours
Based at 1H0 (Creve Coeur)
Paid dues yearly since 2007
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01-27-2015, 08:29 AM
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Join Date: Dec 2008
Location: Big Sandy, WY
Posts: 2,567
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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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Actual repeat offender.
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01-27-2015, 09:15 AM
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Join Date: Aug 2005
Location: Dallas/Ft Worth, TX
Posts: 5,686
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Quote:
Originally Posted by aerhed
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.
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Don't get me wrong, I never advocated that you need to write a novel about the work you did, just a clear description of the work accomplished, no more no less.
__________________
Walt Aronow, DFW, TX (52F)
EXP Aircraft Services LLC
Specializing in RV Condition Inspections, Maintenance, Avionics Upgrades
Dynamic Prop Balancing, Pitot-Static Altmeter/Transponder Certification
FAA Certified Repair Station, AP/IA/FCC GROL, EAA Technical Counselor
Authorized Garmin G3X Dealer/Installer
RV7A built 2004, 1700+ hrs, New Titan IO-370, Bendix Mags
Website: ExpAircraft.com, Email: walt@expaircraft.com, Cell: 972-746-5154
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01-27-2015, 02:07 PM
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Join Date: Dec 2006
Location: Collinsville, IL
Posts: 620
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Quote:
Originally Posted by Sam Buchanan
Because you have the Repairman's Certificate (which means you are the builder):
"Replace AN5 bolt on holding nose gear strut to engine mount". Period.
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Sam, You keep referring to the "Builder" in these posts. I understand that having the Repairman's Certificate would mean you are the builder, but what is the difference between documenting the same maintenance performed by the builder as opposed to a "non-builder owner"? The ONLY difference I see is that the holder of the Repairman's Certificate can sign off the Condition Inspection.
Thanks. Good dialog here.
__________________
Don
VAF #1100, EAA864
-6A bought flying
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01-27-2015, 05:42 PM
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been here awhile
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Join Date: Dec 2004
Location: North Alabama
Posts: 4,301
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Quote:
Originally Posted by flytoboat
Sam, You keep referring to the "Builder" in these posts. I understand that having the Repairman's Certificate would mean you are the builder, but what is the difference between documenting the same maintenance performed by the builder as opposed to a "non-builder owner"? The ONLY difference I see is that the holder of the Repairman's Certificate can sign off the Condition Inspection.
Thanks. Good dialog here.
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The non-builder owner is going to have an A&P in the maintenance loop, and the A&P is understandably going to have his ideas on inspection and log entries. Most likely those will be driven by how he performs inspections in the certificated environment.
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. 
Last edited by Sam Buchanan : 01-27-2015 at 05:53 PM.
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01-27-2015, 08:06 PM
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Join Date: Jan 2005
Location: Cincinnati, Ohio
Posts: 1,060
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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!
__________________
Jon Thocker
Habitual Offender
RV4, RV4, RV6A, RV8, RV8, RV8,RV8, RV8, RV8, RV12
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01-27-2015, 08:32 PM
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Join Date: Dec 2006
Location: Collinsville, IL
Posts: 620
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Thanks Sam. Now I understand the perspective you are coming from.
Don
__________________
Don
VAF #1100, EAA864
-6A bought flying
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01-27-2015, 11:20 PM
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Join Date: Jan 2005
Location: 57AZ - NW Tucson area
Posts: 10,011
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Quote:
Originally Posted by Sam Buchanan
.....
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.
...
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Sam,
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".
__________________
Gil Alexander
EAA Technical Counselor, Airframe Mechanic
Half completed RV-10 QB purchased
RV-6A N61GX - finally flying
Grumman Tiger N12GA - flying
La Cholla Airpark (57AZ) Tucson AZ
Last edited by az_gila : 01-27-2015 at 11:29 PM.
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01-28-2015, 06:44 AM
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Join Date: Aug 2005
Location: Dallas/Ft Worth, TX
Posts: 5,686
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Quote:
Originally Posted by Sam Buchanan
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. 
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Good record keeping personifies the professionalism of the person doing the maintenence. The log record that has one stamp in it a year for the "inspection" raises a big red flag.
Quote:
Originally Posted by jthocker
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!
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"Muddying up the waters"... I don't look at it that way, I think many/most folks are looking for what is the "normally accepted" way to maintain aircraft records. Records are a history of the aircraft and ducument the care and maintenance of the machine.
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.
__________________
Walt Aronow, DFW, TX (52F)
EXP Aircraft Services LLC
Specializing in RV Condition Inspections, Maintenance, Avionics Upgrades
Dynamic Prop Balancing, Pitot-Static Altmeter/Transponder Certification
FAA Certified Repair Station, AP/IA/FCC GROL, EAA Technical Counselor
Authorized Garmin G3X Dealer/Installer
RV7A built 2004, 1700+ hrs, New Titan IO-370, Bendix Mags
Website: ExpAircraft.com, Email: walt@expaircraft.com, Cell: 972-746-5154
Last edited by Walt : 01-28-2015 at 07:05 AM.
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01-28-2015, 07:21 AM
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been here awhile
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Join Date: Dec 2004
Location: North Alabama
Posts: 4,301
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Quote:
Originally Posted by az_gila
Sam,
Do the usual EAB Operating Limitations specifically excuse the EAB owner from the requirements of tis FAR?
<Big snip>
Also note that 91.409 "Inspections" in the same subsection does specifically exclude EAB aircraft by way of their Experimental certificate.
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Gil, I think the case can be made that because the EAB Op Lims specifically call out an inspection protocol unique to aircraft with experimental airworthiness certificates that FAR 91 is excluded by our operating limitations.
Quote:
Originally Posted by Walt
Good record keeping personifies the professionalism of the person doing the maintenence. The log record that has one stamp in it a year for the "inspection" raises a big red flag.
"Muddying up the waters"... I don't look at it that way, I think many/most folks are looking for what is the "normally accepted" way to maintain aircraft records. Records are a history of the aircraft and ducument the care and maintenance of the machine.
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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Walt, I agree that the mindset you describe is unproductive and I hope you do not think that is what I have been advancing. I also agree that if I was purchasing an RV, a logbook with only one entry per year would indeed raise red flags. But it would be legal.
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.
Last edited by Sam Buchanan : 01-28-2015 at 08:34 AM.
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