The code - Part II

In my preceding article, entitled: The Code: Part I, for this venerable publication, I went over the Code of Federal Regulations

Section 43.11 Inspection Entries requires all log book entries to have:
1. The type of inspection and a brief description of the extent of the inspection.
2. Date and total time in service. Time in service is defined as the time accumulated from take-off to landing, and yes, using Hobbs time and tach time is just fine, except please do not mix the two together, it makes for a convoluted set of records.
3. The signature and certificate number of the person approving or disapproving the aircraft or component part for return to service.

Remember, inspections, big and small, which are conducted on Part 91 aircraft, cannot be delegated to another individual. The one signing the log book entry must be the one who performed the eyeball inspection.

How long are you held responsible for an inspection? For an inspection, the technician is held responsible for as long as it takes for the ink to dry on the log book.

While this drastic departure from sanity might sound like the FAA is freebasing, the truth is the technician has no control over the airworthiness condition of the aircraft once the aircraft leaves his care. The FAA would be unreasonable to hold the technician responsible for the future airworthiness of an entire aircraft for an undetermined period of time, especially when the aircraft is at the mercy of every pilot out there!

So, Part 43, Section 43.11 says that the inspection log book entry declares that every AD, every major and minor repair and alteration is airworthy at that moment in time. Another way of looking at this rule is, an inspection approves the past, not the future.

Before I close out inspection requirements, it is a wise technician who also understands that Section 43.15 talks to additional performance rules for inspections. It is in this rule where specific inspection items are called out for rotorcraft annual and 100-hour inspections, and progressive inspections.

Form 337, used for major repairs and major alterations, is a very old form going back to the CAA Form 337 which the FAA embraced. While a technician does not have the authority in Part 65 to approve an aircraft for return to service after a major repair or major alteration, it is the technician who first makes the decision whether or not the repair or alteration is major or minor.

While Part 43 requires a Form 337 to be made out for a major repair or alteration, it is Part 91, Section 91.417 on recordkeeping that states the length of time the owner or operator is required to keep the Form 337. For a major repair, Section 91.417 (a)(1) requires that Form 337 is kept only one year.

The FAA thinking behind this rule is based on the fact that this major repair returns the aircraft or component part back to its original type design so nothing has been changed. Furthermore, in most cases within a year, the repair would be bought off again by a new inspector, so the form can be discarded because a copy of the major repair is kept in the aircraft's file in Oklahoma City.

While trashing the major repair Form 337 after a year is perfectly legal, from the technician's point of view, I sure would want a copy of the Form 337 in the maintenance records in order to see who, what, when, where, and how the aircraft was repaired. So, in yours and my own personal interest, I would tell the owners to hold on to all major repair Form 337s.

On the other hand, Section 91.417(a)(2) says major alterations Form 337 should be treated differently. These Form 337s, unlike their major repair cousins, requires the owner to hold them forever. This is because each major alteration changes the aircraft's type design. So, a record of each change must be kept with the aircraft.

Also, starting last year, the FAA changed its policy on field approved major alterations. Now the technician has to develop instructions for continuing airworthiness (ICA) in order to aid the next technician a year from now who has to inspect the alteration that was installed today.

Technicians usually get into trouble when they write something in the log book. Maybe that is why their handwriting is so small and a little smudgy. But handwriting alone is not the problem. Usually the hammer falls because they describe the work performed based on what they think they did and not what they legally did. To avoid this mantrap, read on.

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