FAA Feedback: Annual Sign-off

Oct. 7, 2014
The FARs say an annual inspection is a complete inspection of all the aircraft’s individual parts, the airframe, the engine(s), the propeller(s) and everything else listed on the aircraft’s type certificated data/specification sheet and equipment list.

Did you ever ask this question or want to? Hey Mr. FAA inspector, which “logbook” do you sign off for an annual inspection? Do you put annual inspection “approval for return to service” sign-offs in each of the airframe, engine, or propeller “logbooks” or do you just put it in one?

This question is often followed by: If I put annual sign-off in just one “logbook” will I get in trouble? And in which “logbook” should I put the entry in?

To answer these questions let’s first look at the rules covering annual inspections: Federal Aviation Regulation (FAR) 91.409 Inspections (old FAR 91.169) says: “No person may operate an aircraft unless within the preceding 12 calendar months it has had an annual inspection in accordance with Part 43 of this chapter and has been approved for return to service by a person authorized by Part 43.7 of this chapter.”

The key term here is the word “aircraft.” “FAR Part 1 Definitions” defines an aircraft “as a device that is used or intended to be used for flight in the air.”

An “aircraft,” a type certificated aircraft, must be equipped with all pertinent appliances and components including the engine and propeller to accomplish flight. An “aircraft” according to the regs is the sum total of its parts.

So what are the FARs actually saying? The FARs say an annual inspection is a complete inspection of all the aircraft’s individual parts, the airframe, the engine(s), the propeller(s) and everything else listed on the aircraft’s type certificated data/specification sheet and equipment list. The annual inspection must also be completed within the preceding 12 calendar months, and accomplished in accordance with Part 43.

So since you are performing a single inspection covering the entire aircraft, you are required to make only a single entry.

OK, your next question is: So what “logbook” do you put the single annual inspection “approval for return to service” entry in? FAR 43.11 says you make the entry in the maintenance record of the aircraft.

I can almost hear you say “Maintenance Record!” Where did that come from? Whatever happened to the aircraft’s “logbook?”

First allow me to explain that there are technically no such things as “logbooks.” In FAR Part 43 there are no references to the term maintenance “logbooks,” just maintenance “records.” The term “logbooks” is a throwback to old nautical terms that found their way into our industry’s working vocabulary.

So to answer your question, record the annual inspection sign-off in accordance with FAR 43.11 in the airframe maintenance record (logbook).

Why the airframe maintenance record? Of the three maintenance records, the airframe (logbook) is the most permanent. Engine and propeller records (logbooks) will show the entire history of the aircraft, from the issue date of the aircraft’s first airworthiness certificate to the last maintenance or inspection performed.

All FAA Flight Standards District Offices were notified this June of this new policy by FAA Action Notice 8300.81 issued by the hardworking folks in the Aircraft Maintenance Division, General Aviation and Commercial branch. This action notice supersedes any previous FAA policy on annual inspection sign-off.

Originally printed in the November/December 1990 issue of Aircraft Technician