FAA Feedback: Logbook Entries

Aug. 6, 2014
What exactly am I responsible for when I sign a maintenance record or logbook?

You fixed the problem, the airplane is ready for the trip. You sit down at your desk and open the logbooks. As you organize the paperwork, the same thought goes through your mind every time you do this chore. “Am I signing my life away? If something goes wrong, am I going to get in trouble with the feds? What exactly am I responsible for when I sign a maintenance record or logbook?”

To ease your fears let’s take a look at requirements for general aviation maintenance and inspection record entries and the responsibility you take on when you put your signature on the bottom line.

What kind of record entries can technicians make?

All certificated and authorized maintenance personnel can make just two kinds of record entries: one for maintenance performed and one for inspections completed.

Required maintenance record information

The rule that covers maintenance signoffs for aircraft operated under Part 91 is FAR 43.9. This important rule sets the requirements for the recording of maintenance, preventive maintenance, rebuilding and alterations. It states that on the completion of the work, you must make out a maintenance record that has at least the following information:

  1. A description of, or reference to, acceptable data used to perform the work.
  2. The date you finished the work.
  3. Name of the person who performed the work, if other than the person who approved the work for return to service.
  4. Name, certificate number, kind of certificate and signature of the person approving the work for return to service.

Even if a certificated person doesn’t actually write in the aircraft’s log that the component worked on is “approved for return to service,” FAR 43.9 (4) says when the maintenance entry is signed, that person’s signature constitutes the “approval for return to service.”

Notice that the rule doesn’t require that “total time” be included in a maintenance entry like it does for an inspection entry. So you won’t get in trouble if you don’t include it in your maintenance entry. However, recording the total time is an excellent way for monitoring maintenance trends, and I encourage the practice.

What am I responsible for when I sign off maintenance?

When you sign your name to the maintenance record you’re telling the world and the FAA two things. First, the aircraft or component that you performed maintenance on is airworthy. Second, by accurately describing the part or component that you worked on, you set the limits on the responsibility that you’re willing to accept.

For example: When a technician signs off a repair to a starter generator and its installation on an engine, he or she is accepting the responsibility for the work performed. But with the same entry, the technician is also telling the FAA that they are responsible only for the airworthiness of the repair and the installation of that component – nothing more. If the engine or another engine component fails, the technician would not be held responsible.

What do you mean by the term airworthy?

Airworthy means that the aircraft or component thereof meets its type design and is in a condition for safe operation. This definition is found on a Standard Airworthiness Certificate and in a law called The Federal Aviation Act of 1958.

How long am I responsible for maintenance that I perform?

You are responsible for that maintenance until that part is again worked on, replaced, damaged in service, until it has exceeded its life limit or until the next required inspection during which an airworthiness determination is made.

How can I avoid a visit from the FAA?

• Do all work in accordance with FAR 43.13 Performance Rules.

• Use current acceptable data for all maintenance except major repairs and major alterations.

• Use current approved data for all major repairs and major alterations.

Some words of caution: Don’t perform any maintenance unless the approved or acceptable data is in front of you in writing. Never perform maintenance based on a verbal OK, even if it’s from your company’s top engineer or factory rep. There are some maintenance organizations where this wink-and-a-handshake way of doing business has been going on for so long that everyone on the hangar floor thinks a verbal OK is a legal procedure. In reality, though, it’s a violation of FAR 43.13(a) Performance Rules.

To illustrate my point, let’s explore how performing maintenance on a verbal OK can potentially affect your career: During a C-check, you find that the right aileron is delaminating and determine the damage exceeds the maintenance manual limits. The airplane has to meet a gate time so your boss makes a quick call and gets a verbal OK to exceed the repair limits from the company’s engineering rep.

The boss then tells you that an OK was given by engineering to extend the limits and make the repair. You repair the aileron, sign the logs, and the airplane makes the gate time. An in-flight aileron separation subsequently causes an uncontrollable roll vector, and the plane goes down. You know the FAA will pay you a visit. It’s no surprise that you’re not kept waiting very long.

The first thing the FAA inspector asks you for is the data you used to make the repair. With nothing to show him, I doubt the inspector will be impressed with your explanation that the data came courtesy of the AT&T operator?

Bottom line – if you’re betting your career on the hope that the person responsible for the verbal OK will stand up and take the fall and save you from the wrath of the federal government, your odds aren’t very good.

To avoid this, make sure all maintenance data you use is in writing. And make sure the data qualifies as either acceptable or approved.

What if someone later tampers with the aircraft or component I worked on and doesn’t sign the logbook?

This is a sad and recurrent problem I’ve found in both general aviation and the air carrier maintenance community. It’s no secret that owners, and “shade tree mechanics” are forever “fixing” things on aircraft that you previously worked on, but never a hint of their sloppy maintenance appears in the logbooks.

Regardless, the FAA, following standard investigative procedures after an accident or incident, will always focus on the technician who last signed the logbook.

Unless the technician can prove that someone else worked on the aircraft after it left his or her care, the technician with the last entry is held responsible.

I know – the legal practice of delegating blame to the last guy who signed the maintenance records is biased and unfair. But until people everywhere are honorable, the FAA is left without many choices.

What am I responsible for when I sign off an inspection?

Depending on the type of inspection you perform, your responsibility for airworthiness can be for individual parts, or for the entire aircraft.

For example, when you put your signature to the following logbook entry: “I certify that this aircraft was inspected in accordance with an annual/100-hour inspection and determined to be in an airworthy condition,” you take responsibility for the airworthiness of the entire aircraft, engines, propellers and component parts. You take responsibility for all the Airworthiness Directives that must be complied with, all repairs and alterations, both major and minor, that were performed from the time the aircraft was manufactured, whether the date was six months ago or 60 years ago.

This responsibility, however, lasts only up to the time the ink on your signature dries. The FAA can’t hold you responsible for the continuing airworthiness of the aircraft once it leaves your control.

The only way you will be held responsible for the airworthiness of the aircraft after the inspection, is if the FAA can prove the aircraft was not airworthy when you signed off the inspection. For example, you missed an AD or failed to repair a structural problem.

Tips on protecting your logbook entries

Until we come up with better ideas, here are three suggestions that might be helpful in avoiding falling into the logbook ambush set by individuals of questionable character.

  1. If you have reason to suspect that the part or component will be tampered with later, take a photograph of the installation. A photo is excellent proof that someone tampered with the component; especially when it shows the difference between the before and after routing of fuel or electrical harness.
  2. Paint slippage marks on the component’s mounting bolts with enamel cracks easily when disturbed and the bottle even comes with its own brush. If the slippage marks are cracked or gone altogether it will prove that someone else worked on the component after you.
  3. Have another pair of eyes look at your work and initial the work order.
  4. Keep duplicate copies of all work orders, receipts for parts and supplies for at least two years. Please don’t forget to note the markings or photographs you made in both the aircraft maintenance records and your own. Remember good record entries can help you, poor record entries can hurt you.

If you have any ideas on how to prevent honest technicians from being falsely accused please call me at (202) 267-9312 or write me C/O FAA, AFS360, 800 Independence Ave., S.W., Washington, D.C. 20591

Required inspection record information

FAR 43.11 is the rule that sets the requirements for inspections performed under Part 91, Part 125 and aircraft that meet Part 135 sections 135.411(a)(1) and 135.419. For aircraft inspected under Part 43, the following items must be included in all inspections entries:

• The type of inspection and a brief description of the extent of the inspection.

• Date of the inspection.

• Total time in service.

• Signature of the person approving or disapproving the approval for return to service of the aircraft or component part thereof.

This article originally appeared in the November/December 1992 issue of Aircraft Technician.

About the Author

Bill O'Brien