Progressive Maintenance -- How to Log?

[StuBob]

Let's say you're following the recommendations of Vic Syracuse's truly excellent Maintenance Handbook for Van's RV Aircraft and performing progressive maintenance. Every month, you do a little something, inspect a little something, replace something that wore out.

Your condition inspection was in, say, July. In October, you open up the tail and replace the ELT battery. While you're there, you inspect and lubricate the rod ends, check the jam nuts, etc. What do you log then?

And what do you log the following July? The regs say you have to do an inspection annually, and that inspection must include certain things. I can't claim to have completed in July an inspection that includes data gathered in October, can I? It doesn't seem right.

Or am I then just obligated to keep the new schedule and look down the tail every October? The excuse for doing it in October had been that you had to change the ELT battery, but you don't have to do that every October.

Anyway, what should the logbook say?

 

[664781]

Logbook entry

When you comply with your conditional inspection you must make a logbook entry per your operating limitations. Since they have varied a lot in the past there is no one size fits all response. It must be per YOUR operating limitations.

 

[Canadian_JOY]

Some folks keep two sets of records, the official logbook and an unofficial maintenance log. The unofficial maintenance log is what they use to record the work done progressively and it helps them identify any items which were not inspected and must be inspected in the annual inspection.

When annual inspection time comes their official log entry documents a complete annual inspection as a summary of all the work which has been done.

For those who want to get technical on the legalities, I'll leave that to you. Let's just say that on any particular day that an annual inspection is signed off in the logbook it is known and accepted that all of the work documented in that sign-off was not carried out within that single 24-hour period. Progressive inspections take advantage of this known and accepted procedure.

 

[sahrens]

Log it

There are two issues. One is completing the annual condition inspection and the other is logging maintenance. If an inspection is due annually there is nothing restricting you from completing it earlier. It just becomes due one year after the inspection.

Further there is no restriction about what and when you put in your aircraft/engine/propeller logbooks. If you complete an inspection earlier than was required, to use your example, its due no later than one year after the new inspection. You will end up with different inspection requirements through out the year. One way to remember the different inspection times is with the logbook entry. Something like Complied with service bulletin X by inspection, no cracks noted. Next inspection due October 2024. If you change your mind and reinspect that area in July during your CI, just make a new entry in your logbook with a due date of the next July.

Some folks make minimal entries in the aircraft logbook, others make an entry every time they touch the aircraft such as adding a quart of oil. I'm somewhere in the middle and treat it as a maintenance record.

 

[rocketman1988]

Split

I use the logbook for the required “safe for operation” endorsement. The detailed record of what was accomplished is kept in a separate binder. Trying to write everything accomplished, and more importantly be able to read it, has always been a pet peeve.

Splitting the two allows an organized and detailed maintenance record and, IMO, will benefit my heirs in the future. Not planning on ever selling it…

 

[vic syracuse]

Just make the logbook entries as you perform the maintenance. The Condition Inspection entry just states that you have inspected the aircraft and found it in an airworthy condition. Most of us do that before every flight.

Seriously, it's OK to perform the maintenance throughout the year. Some things don't even coincide with the CI annual requirement's, such as ELT inspections. Those are per the manufacturer. Some ELT's require a test every 3 months. That test is different than making sure the battery is still current (date and no more than 50% used). Transponder and pitot-static inspections, 500 hr. mag inspections, prop overhauls, etc., are usually all on different scheduels than the CI.

You might consider doing the compression checks/borescope inspection around the CI date.

To directly answer your question regarding looking at the tail innards while you did the ELT, there's no requirement to open it up again for the upcoming CI. What you could do is use the CI checklist throughout the entire year, and check off items as the year goes by. That's what progressive maintenance is all about.

BTW, some items might need looking at more than once a year, depending upon how much you are flying. Things such as brakes, spark plugs, oil, etc.

Hope this helps.

Vic

 

[StuBob]

Would that mean that I, as a non-builder, have to have an A&P sign off on the inspections, lubes, etc. I do during the year, or does he just need to be willing to state “IAW Part 43, Appendix D, etc.” once a year?

Am I making this harder than it needs to be?

 

[OKAV8r]

Be Careful

A note of caution, the FAA has a distinct idea of what constitutes a "Progressive Inspection". Read 91.409(d). While you might feel comfortable doing your annual condition inspection in chunks, or having gaps of flying time in between portions of the inspection, the FAA has another view. I certainly wouldn't log it as progressive unless I have a letter from a FSDO approving the progressive inspection plan.

See also: 43.9, 43.11, 91.405, 91.411, 91.417, and AC 43-9C

 

[BobTurner]

Would that mean that I, as a non-builder, have to have an A&P sign off on the inspections, lubes, etc. I do during the year, or does he just need to be willing to state “IAW Part 43, Appendix D, etc.” once a year?

Am I making this harder than it needs to be?

The latter. While it certainly is good practice to keep good records, as an EAB owner you are only required to keep records of required inspections, not maintenance. e.g, annual condition inspection, ELT inspection, pitot static/transponder inspections (assuming these apply to you). This. applies to builders and non-builders equally, the only difference being that if you hold the limited repairman certificate for your plane you can also sign off the condition inspection.
I'm also with the last poster. Since my Op Limits say "condition inspection" I would not use the words "progressive inspection".

 

[Walt]

Would that mean that I, as a non-builder, have to have an A&P sign off on the inspections, lubes, etc. I do during the year, or does he just need to be willing to state “IAW Part 43, Appendix D, etc.” once a year?

Am I making this harder than it needs to be?

Guess you're looking for an A&P to falsify records?

A note of caution, the FAA has a distinct idea of what constitutes a "Progressive Inspection". Read 91.409(d). While you might feel comfortable doing your annual condition inspection in chunks, or having gaps of flying time in between portions of the inspection, the FAA has another view. I certainly wouldn't log it as progressive unless I have a letter from a FSDO approving the progressive inspection plan.

See also: 43.9, 43.11, 91.405, 91.411, 91.417, and AC 43-9C

Yep, agree with the above.

In addition, logs are an extremely important document which is a history of the aircraft and it's maintenance. As far as I'm concerned if it's not in the 'official' aircraft logs, then it didn't happen. I remember a prebuy I did like that, nothing in the logs but owner said all this stuff was done, just not logged, told the buyer to walk away.

 

[lr172]

A note of caution, the FAA has a distinct idea of what constitutes a "Progressive Inspection". Read 91.409(d). While you might feel comfortable doing your annual condition inspection in chunks, or having gaps of flying time in between portions of the inspection, the FAA has another view. I certainly wouldn't log it as progressive unless I have a letter from a FSDO approving the progressive inspection plan.

See also: 43.9, 43.11, 91.405, 91.411, 91.417, and AC 43-9C

I would think that this is closer to the real requirement. Your op lims require that an inspection has occurred withing the last 12 months before flight and that inspection must be within the scope and detail of part 43 (lot of grey in that statement, but easy to assume that you can't just ignore it). Then you get to the area of doing the CI and signing it off in july, but you had done part of the actual inspection work in january. You MAY have met the letter of the regs, but if questioned on it, you need to understand how the FAA is going to interpret the 6 month gap in the previously mentioned item that was not inspected at the CI. Once you have gone 7 months from the CI, the CI is still in the 12 mo window, but the part you inspected no longer is. I have not read 43 cover to cover, so don't know what it says about timing between work done and sign off. I am sure there is something from them on the subject, as one could go so far as to say that the inspection done for last years CI just rolls into the next one. If you sign off now even though the plane was inspected 6 months ago, why not just stretch that to 12 and use last years inspection? There just has to be a line that the FAA has drawn somewhere.

I recommend understanding what the FAA expects in this area and then follow it. If you plan to skirt it, definitely dont put the progressive items in the log book as that is just asking for trouble.

None of this has anything to do with maintenance, loosely defined as replacing worn or broken components, adjusting things and fixing things. That can be done anytime you have the need for it or decide to do it preventively. The CI is all about inspecting the plane to determine it's condition for safe operation. Doing maintenance to repair any item that didn't pass the inspection doesn't really fall into all of the inspection stuff that is part of the CI and has the timing requirements. Yes, not repairing it might prevent you from considering it to be in a safe condition, but the maintenance portion of that is not really part of the CI's intent (an inspection) and therefore not tied to the timing requirements of the CI, as I see it.

If I changed my oil in january and did a full inspection of the engine area at that time, I would feel compelled to do the inspection (but not the oil chang) all over again in July when I did my CI, because 1) it is safe and responsible and 2) it is my opinion that this is the legal requirement. I know of a plane where the CI is 2 minute signing ceremony and I am sure everything in between is out there. In the ELT example discussed, I might consider doing what he did eventhough I question whether it fits in the FAA guidelines. However, if going to an A&P for your CI, I have all confidence he will NOT accept that and will re-inspect everything.

 

[BillL]

The more this is discussed the more opaque it becomes.

Here is what I do - for safety, and hopefully it is legal.

Time related inspections by the book when they occur during the year. They are logged in the maintenance files, all with details of findings.

Any minor modifications logged in the maintenance log - like installation of a USB port.

Progressive take apart, lube, inspect, torque check etc over a 4 (sometimes 6) week period annually. The plane is flyable for sections of time in-between segments. The big one of taking all the interior out, bulkhead out for the cabin inspection is done in one segment.

Condition inspection sign-off is down after all the segments are done in the official logbook.

Two books are not considered (by me) to be skirting any legality, simply to keep the complete knowledge and content on the how it was done and non actionable findings (to me monitored) documented. Nothing tricky or attempt to hide, just hoping it is all legal without having to think like an FAA lawyer. Being safe and documented is the personal goal.

Walts' condition inspection list was used for the baseline (super generous to share -thanks Walt!!) then modified for my equipment, what was done, and where to make it a project task list to be stepped through. The goal was to keep the segments tidy, and allow it to be completed, managed and restored to use before moving forward. I can only juggle so many things in my head at a time these days, so this process ensures all the necessary and desired items are covered.

 

[2theskyy]

Guess you're looking for an A&P to falsify records?



Yep, agree with the above.

In addition, logs are an extremely important document which is a history of the aircraft and it's maintenance. As far as I'm concerned if it's not in the 'official' aircraft logs, then it didn't happen. I remember a prebuy I did like that, nothing in the logs but owner said all this stuff was done, just not logged, told the buyer to walk away.

What Walt says. He’s done this for a long time.

Don’t complicate this. Do maintenance along the way. But do a CI when due. If that means looking back over items, then do it. A lot of aircraft have hourly inspection/maintenance plus the CI, annual or phase.

People tend to freak out at a lot of maintenance in logbooks. I always liked it.
I did the same as Walt. Doing prebuy with a decade of annual only sign offs. I’d advise to run away.

Key point- DON’T keep “unofficial” logs.
Walt will correct me if I’m wrong but nothing says you can’t have 2 concurrent logs. But they are both official logbooks. I just didn’t like doing things that way. I liked everything going in 1 logbook. Then go onto logbook 2 when first one is full. You can put done in accordance with (I.A.W) references so procedures, torques, etc isn’t unnecessary filling up logbook. Keep separate reference manuals to use as, well, reference when performing Mx.

 

[rocketman1988]

What Walt says. He’s done this for a long time.

Don’t complicate this. Do maintenance along the way. But do a CI when due. If that means looking back over items, then do it. A lot of aircraft have hourly inspection/maintenance plus the CI, annual or phase.

People tend to freak out at a lot of maintenance in logbooks. I always liked it.
I did the same as Walt. Doing prebuy with a decade of annual only sign offs. I’d advise to run away.

Key point- DON’T keep “unofficial” logs.
Walt will correct me if I’m wrong but nothing says you can’t have 2 concurrent logs. But they are both official logbooks. I just didn’t like doing things that way. I liked everything going in 1 logbook. Then go onto logbook 2 when first one is full. You can put done in accordance with (I.A.W) references so procedures, torques, etc isn’t unnecessary filling up logbook. Keep separate reference manuals to use as, well, reference when performing Mx.

I would argue that a maintenance binder is exactly the same thing as a "logbook". As long as this history and sign off is there, a stack of napkins would be a "logbook".


I much prefer the legibility, organization, and repeatability of a computer generated document binder than abbreviated handwriting in a traditional "logbook".

Personal preference; as long as the required information is available, the form factor of the logbook doesn't matter.

 

[2theskyy]

I would argue that a maintenance binder is exactly the same thing as a "logbook". As long as this history and sign off is there, a stack of napkins would be a "logbook".


I much prefer the legibility, organization, and repeatability of a computer generated document binder than abbreviated handwriting in a traditional "logbook".

Personal preference; as long as the required information is available, the form factor of the logbook doesn't matter.

I don’t think I specified what the logbook was produced from. But if the FAA asks for your logbooks. You best get the entire stack of napkins.

Treat your aircraft logs like you do your flight logs. If you write all your flight time on napkins then have at it.

I just know I’d never buy or sell a plane or myself, with logs on napkins.

 

[rocketman1988]

I don’t think I specified what the logbook was produced from. But if the FAA asks for your logbooks. You best get the entire stack of napkins.

Treat your aircraft logs like you do your flight logs. If you write all your flight time on napkins then have at it.

I just know I’d never buy or sell a plane or myself, with logs on napkins.

You miss the point; it is the content of the log that matters, not the medium used.

You are not required to carry said log in the aircraft, and I'd love to see the face of the FAA guy going through that stack of napkins!

...and I only keep a flight log of my GA time anymore

 

[2theskyy]

You miss the point; it is the content of the log that matters, not the medium used.

You are not required to carry said log in the aircraft, and I'd love to see the face of the FAA guy going through that stack of napkins!

...and I only keep a flight log of my GA time anymore

Lol. You’re just F’ing with me now bob. I’ve said no such things as you are saying I said.

I didn’t say to carry any logs with you in an airplane. And, I did not say it mattered what medium to use.

But I’m not going to go back and forth with you when it’s going off the rails.

If you’d like to discuss further. Just PM me

 

[StuBob]

Do maintenance along the way. But do a CI when due. If that means looking back over items, then do it. A lot of aircraft have hourly inspection/maintenance plus the CI, annual or phase.

That makes good sense and is more or less what I suspected was the wise thing to do. It appears people promote progressive “inspection” but perhaps mean progressive “maintenance.” A little research seems to indicate that you can’t embark on a progressive inspection program without the blessing of the FSDO. It isn’t clear at all whether being Experimental makes a difference, especially for someone without a Repairman Certificate.

As to what’s required in the logs, Cornell Law (FWIW) says this in their review of maintenance logs:

6) For progressive inspections, the following or a similarly worded statement—“I certify that in accordance with a progressive inspection program, a routine inspection of (identify whether aircraft or components) and a detailed inspection of (identify components) were performed and the (aircraft or components) are (approved or disapproved) for return to service.”

People tend to freak out at a lot of maintenance in logbooks. I always liked it.

I agree completely. The logs for my RV7 were. . . Um. . . .less informative than those in my previously-in-Canada C185. After years of meticulous record keeping in certified aircraft, I’m bringing the same attitude to my homebuilt. That’s why I made the OP; I want to be fastidious in my documentation. I’m not satisfied with, “It’s experimental; do what you want.”

 

[2theskyy]

I think you’ve got the correct attitude. I’d say work very close with your A&P that is going to be doing your CI. They’ll help you in the details and work with you on owner assistance and other items/questions.

Good luck

 

[dmattmul]

Saw this on the FAA website:

 

[Ironflight]

Saw this on the FAA website:

Sorry - but without some context for what that “asterisk” is being referenced by, we have no idea what this is about - could be a Part 135 or 131 operation….. and I am curious!

 

[RV6_flyer]

Saw this on the FAA website:

91.409(d) insert copy / paste:

Progressive inspection. Each registered owner or operator of an aircraft desiring to use a progressive inspection program must submit a written request to the responsible Flight Standards office, and shall provide -

 

[Stevea]

Saw this on the FAA website:

There might be some confusion here. Not to get caught up in splitting hairs, but the original thread title refers to Progressive MAINTENANCE (Logging). The bit cited from the FAA website refers to Progressive INSPECTIONS. The two terms sometimes tend to be used interchangeably (in the AEB builder/pilot world) , but as RV6_flyer implies, "progressive inspections" come with many more requirements than most of us in the amateur built experimental world would like to deal with, via 91.409(d). "Progressive Maintenance" (and it's associated logging) on the other hand are easy to deal with....no additional FARs.

 

[rockyfatcat]

25 years ago, I worked at an FBO that specialized in light twins. The owner of a Barron needed to use the aircraft and it was going to be due for annual.

The guy who ran the FBO worked it out that we could have the aircraft for a couple days every week. We would inspect a complete section of the aircraft ie left wing, put it back together again and give it back till the next time.

When we had completed all of the sections and individual inspections the IA/owner of the FBO signed off the annual.

His logic was we had done all the work and everything was either inspected or repaired. The aircraft was airworthy. It shouldn’t matter that the work was spread out over 6 weeks instead of being done all at once.

If you are signing off your own aircraft, and you know that you recently removed and replaced the tires and cleaned/inspected/re-lubricated the bearings while you had it apart. You will document your work at the time you do it. When you do your annual, you know that portion of things are all good and focus on other areas.

Your signature that the aircraft is in airworthy condition isn’t that everything was performed on that date. Just that on that date you are certifying the aircraft has been inspected and you are certifying it as airworthy.

 

[Taltruda]

If I changed my oil in january and did a full inspection of the engine area at that time, I would feel compelled to do the inspection (but not the oil chang) all over again in July when I did my CI, because 1) it is safe and responsible and 2) it is my opinion that this is the legal requirement. I know of a plane where the CI is 2 minute signing ceremony and I am sure everything in between is out there. In the ELT example discussed, I might consider doing what he did eventhough I question whether it fits in the FAA guidelines. However, if going to an A&P for your CI, I have all confidence he will NOT accept that and will re-inspect everything.

Maybe not perform the oil change again.. or maybe do.. at least pull the suction screen and cut open the filter may be in order to comply with appendix (d) (3). “ 3.) Internal engine—for cylinder compression and for metal particles or foreign matter on screens and sump drain plugs.

 

[dmattmul]

Sorry - but without some context for what that “asterisk” is being referenced by, we have no idea what this is about - could be a Part 135 or 131 operation….. and I am curious!

This is where I saw the reference. As far as maintenance vs inspections I keep maintenance items and inspection items noted in the same logbook. Figured it couldn't hurt and keep everything in one logbook. The exception is the prop which might be separated from the airframe in the future, so it has its own logbook. (Provided by Whirlwind)

 

[Taltruda]

This is where I saw the reference. As far as maintenance vs inspections I keep maintenance items and inspection items noted in the same logbook. Figured it couldn't hurt and keep everything in one logbook. The exception is the prop which might be separated from the airframe in the future, so it has its own logbook. (Provided by Whirlwind)

You should keep a separate logbook for the AIRFRAME, ENGINE, and PROPELLER. One day, you may buy a new engine, and want to sell your old one, but your engine logs are intertwined into the airframe logs. Some people even have an avionics logbook.

 

[gasman]

That makes good sense and is more or less what I suspected was the wise thing to do. It appears people promote progressive “inspection” but perhaps mean progressive “maintenance.” A little research seems to indicate that you can’t embark on a progressive inspection program without the blessing of the FSDO. It isn’t clear at all whether being Experimental makes a difference, especially for someone without a Repairman Certificate.

As the owner of an experiential aircraft that you do not have the repairman's cert for, you can inspect and repair anything anytime. And you can log that you inspected and made the repair...... The Annual Condition Inspection by an A&P is still required.

 

[plehrke]

Just a reminder that inspections, preventive maintenance, and FAA regs are supposed to reduce risk and provide increase safety and safety awareness to you, the pilot, and your passengers. Therefore the questions you should ask yourself are: Does the way you perform and document your condition inspection provide you confidence that your plane is airworthy? If someone else asks (a passenger or FAA) does your documentation provide them confidence that you have done enough to ensure an acceptable risk level?

 

[planenutz]

There might be some confusion here. Not to get caught up in splitting hairs, but the original thread title refers to Progressive MAINTENANCE (Logging). The bit cited from the FAA website refers to Progressive INSPECTIONS. The two terms sometimes tend to be used interchangeably (in the AEB builder/pilot world) , but as RV6_flyer implies, "progressive inspections" come with many more requirements than most of us in the amateur built experimental world would like to deal with, via 91.409(d). "Progressive Maintenance" (and it's associated logging) on the other hand are easy to deal with....no additional FARs.

I agree with you on this.

I believe Progressive Maintenance is what everyone should do to keep their equipment operational and my definition of this is that it consists of the day to day work we carry out between routine or scheduled inspections. Changing tires that are worn, replacing light bulbs, out of phase items that we do progressively as time goes on.

Progressive Inspections are a different beast and in my experience these require approved maintenance programs. A classic example of this is the old Cessna Progressive Care maintenance system which was designed to progressively cover every item of the aircraft over a period of 200 hours at 50 hour intervals. If you applied this to your RV it might consist of something like this: Check 1 is an oil change and a quick look at the engine with a detailed look at the Fuselage. Check two is a detailed look at the engine and a quick check of the fuselage and other components. Check 3 is a quick check of the engine and filter but a detailed look at the wings. Check 4 is a detailed look at the engine, empennage and wings but a quick check of everything else. In this way the entire aircraft has been inspected progressively over a nominated period of time via a recognized maintenance system.

Neither of the above should be confused with the idea of staging a routine inspection over a period of several days or weeks.