Who can update W&B records?

[RotorAndWing]

You've made it very hard to address your points by the way you posted, but to put it simply, Mr. Chamberlain prepared that article in consultation with the Chief Counsel's office merely as a means for pilots to understand how the FAA came to its position on this issue (I actually talked to him about that some years ago). If you really need a letter from an FAA Counsel on the point, you can either ask for an interpretation or just get caught without a properly signed W&B document in your plane, although the letter you get in the latter case will be a Notice of Proposed Certificate action, not just an interpretation.

For the rest of you out there, you can listen to Jim and Silvaire and maybe get hosed by the FAA if they catch you signing your own W&B documents or flying without at least a copy of the properly signed document, or you can listen to me and be 100% absolutely completely certain that you will not have any trouble with the FAA on this issue. Choose wisely.

-30-

Sorry, you're wrong on this, and Silvaire and Jim are correct.

You have the propensity to lambast AW Inspectors for supposedly not knowing regulations that concern operations, but yet you as a pilot without any credentials as a mechanic try to browbeat other mechanics with your off the wall interpretations.

I'm with Silvare, show us official documentation that supports your point.

 

[weirdjim]

You've made it very hard to address your points by the way you posted, but to put it simply, Mr. Chamberlain prepared that article in consultation with the Chief Counsel's office-30-

I don't care if he consulted with Jesus, Mary, and Joseph. Unless the Chief Counsel signed on as a co-author all your "I was buddy-buddy with Chamberlain and he told me ..." crap says is that you are trying to wow us with your supposed "contacts".

I prefer to deal with regulations and not jailhouse lawyer interpretations.

Jim

 

[RotorAndWing]

I prefer to deal with regulations and not jailhouse lawyer interpretations.

Jim

"hangar lawyer"......more appropriate.

 

[weirdjim]

"hangar lawyer"......more appropriate.

I'll be willing to bet he would tell us he "knew" Monterey Jack.

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Jim

 

[kontiki]

What if owner isn't a pilot?


Sent from my iPad using Tapatalk

 

[Henning]

Wait a minute let me *grunt* put on my *twist and groan* asbestos undies and simply say that nothing I see in the regs requires the entry by a certificated mechanic, so I say go for it. If some bushwhacker Fed takes a swipe at you, simply beg forgiveness and get whatever signature you need then.

/asbestos mode off/

Jim

Exactly, make the corrections. Should whatever occur that could possibly bring this to the forefront, having the correct information on the document will be of higher value than having a correct signature on an incorrect document. You aren't going to see the inside of a jail cell, lose your medical, or get your ticket revoked for filling in the correct information to fix the A&P error, especially since you aren't changing the substance of the report, just correcting arithmetic errors to come up with the correct output from his input.

If an IA catches it on annual, they can provide the signature then.

 

[Henning]

If you knowingly operate with defective paperwork, are you flying an unairworthy aircraft?

 

[Silvaire]

Here is the last thing I'll add to this:

The W&B report, which may be a piece of folded paper tucked in the pouch with the registration and airworthiness certs or may be a page in the AFM, is there so that the pilot who is going to fly the airplane can determine if the load he intends to carry is within the limits. It is not there to CYA on a ramp check.

If someone wrote one up and made a math error FIX THE DARN ERROR. At the very least that report is going to have the empty weight and the empty weight CG. It may also have the arms of the seats, baggage and fuel tanks or you might get those from the manual but without the empty weight and the CG there is no way for a pilot to calculate the weight and balance of the aircraft prior to a flight.

and finally, one more time: it doesn't require a signature on it anywhere. It is just like an Aircraft Flight Manual that is required on certain airplanes. Do you see any signatures in your AFM?

Do a Google image search of "aircraft weight and balance document" and note how many completely different looking pages come up. If there is a signature on one it is most likely part of a work order. The only thing required to be in the airplane are the empty weight numbers because it is impossible to legally fly that airplane if you have no means of first determining the weight and balance.

That's it, that's what it's for.

 

[RotorAndWing]

Here is the last thing I'll add to this:

The W&B report, which may be a piece of folded paper tucked in the pouch with the registration and airworthiness certs or may be a page in the AFM, is there so that the pilot who is going to fly the airplane can determine if the load he intends to carry is within the limits. It is not there to CYA on a ramp check.

If someone wrote one up and made a math error FIX THE DARN ERROR. At the very least that report is going to have the empty weight and the empty weight CG. It may also have the arms of the seats, baggage and fuel tanks or you might get those from the manual but without the empty weight and the CG there is no way for a pilot to calculate the weight and balance of the aircraft prior to a flight.

and finally, one more time: it doesn't require a signature on it anywhere. It is just like an Aircraft Flight Manual that is required on certain airplanes. Do you see any signatures in your AFM?

Do a Google image search of "aircraft weight and balance document" and note how many completely different looking pages come up. If there is a signature on one it is most likely part of a work order. The only thing required to be in the airplane are the empty weight numbers because it is impossible to legally fly that airplane if you have no means of first determining the weight and balance.

That's it, that's what it's for.

yep.......

 

[kontiki]

I'm pretty sure the AFM is approved by the FAA. The FAA gets around signing every single document by approving Type Certificates that point to data lists that specifically identify all the documents embodied under the approval. Changing any AFM Limitation would have to be approved by the FAA.

 

[Witmo]

I'm pretty sure the AFM is approved by the FAA. The FAA gets around signing every single document by approving Type Certificates that point to data lists that specifically identify all the documents embodied under the approval. Changing any AFM Limitation would have to be approved by the FAA.

Can an owner operator buy/rent some scales and weigh his aircraft and update his w&b? No. It's not something a pilot, owner, operator is allowed to do. It takes an a&p and he has to sign it. In order to alter it, you need an a&p also. This includes "correcting" an existing w&b whether it's because equipment has been added or removed or because of a math error.

 

[Silvaire]

 

[FastEddieB]

Do you see any signatures in your AFM?

Sometimes.

 

[weirdjim]

I'm pretty sure the AFM is approved by the FAA.

Being "pretty sure" and knowing are two separate and independent things. Please don't post conjecture.

Jim

 

[Henning]

Being "pretty sure" and knowing are two separate and independent things. Please don't post conjecture.

Jim

An AFM is an FAA approved document.

 

[weirdjim]

Can an owner operator buy/rent some scales and weigh his aircraft and update his w&b? No. It's not something a pilot, owner, operator is allowed to do. It takes an a&p and he has to sign it. In order to alter it, you need an a&p also. This includes "correcting" an existing w&b whether it's because equipment has been added or removed or because of a math error.

And you know this to be fact because you are (a) an FAA PMI or (b) an A&P/IA with a few dozen years in the business or ...

just another post with nothing to back it up?

Jim

 

[Silvaire]

Okay I give up.

As an A&P/IA I will gladly put on a Hawaiian shirt, a pair of Bermuda shorts and flip-flops. With a fresh Mai-Tai in hand I'll sit down and charge you a hundred and fifty bucks to correct the mathematical errors on your weight and balance report. In order to not feel guilty about it I'll pick up some fancy gold edged stationary at the local Staples to print it out on after which I'll use an expensive pen to put a very large fancy completely illegible signature at the bottom.

I'm guessing everyone will be happy as a clam in mud.

 

[weirdjim]

Sometimes.

Isn't that just interesting as hell. The typed signature is a "Royace" somebody and the signature is a "Joseph" somebody. I wonder if Joseph is an FAA PMI, the fellow that cleans the restroom, or somebody who happened to be wandering by in the hall when this needed signing.

We don't know, do we?

And without a serial number. And without an N number. Can I make a copy of this and use it on my 182 just by typing in the appropriate s/n & N/n?

Jim
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[weirdjim]

Okay I give up.

Me too, but Silvaire, I want you to order TWO Mai Tais, and we'll charge double, and countersign each other's signature. That way it will take TWO FAA PMIs to do the detective work.

No mas, you folks do whatever mental masturbation you want about this. I'm out of here.

Jim

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[FastEddieB]

Isn't that just interesting as hell. The typed signature is a "Royace" somebody and the signature is a "Joseph" somebody. I wonder if Joseph is an FAA PMI, the fellow that cleans the restroom, or somebody who happened to be wandering by in the hall when this needed signing.

We don't know, do we?

And without a serial number. And without an N number. Can I make a copy of this and use it on my 182 just by typing in the appropriate s/n & N/n?

Jim
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This was not my Cirrus manual - it's a screen shot of a cover sheet of a downloadable POH that Cirrus made available for training purposes.

I don't recall if my official document was similar or not.

 

[Witmo]

And you know this to be fact because you are (a) an FAA PMI or (b) an A&P/IA with a few dozen years in the business or ...

just another post with nothing to back it up?

Jim

Is updating w&b documentation listed in appendix a of part 43? No.

 

[Silvaire]

Me too, but Silvaire, I want you to order TWO Mai Tais, and we'll charge double, and countersign each other's signature. That way it will take TWO FAA PMIs to do the detective work.

No mas, you folks do whatever mental masturbation you want about this. I'm out of here.

Jim
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Ha, ha You're on Jim. I never thought it would happen but maybe we're gonna end up rich after all. Hell, we deserve it right?

Is updating w&b documentation listed in appendix a of part 43? No.

Nope, you're right Tim but what exactly do you mean by "update"? Print out a new report because you spilled coffee on the old one or remove an old ARC Navomatic and replace it with an STEC?

Explain to us why you consider correction of a math error as maintenance

 

[Witmo]

...
Explain to us why you consider correction of a math error as maintenance

Doing a w&b correctly is a maintenance function. Correcting one with an error is still a maintenance function. It doesn't become preventive maintenance no matter how simple the correction might be.

 

[kontiki]

For what it's worth, here is what the FAA handbook says (see attachments).

OK, I believe FARs say owner/operator is responsible for ensuring the records are kept.

There are different interpretations for the level of (I'll use the word ) craftsmanship in everything. I am fortunate enough to work with probably thousands of years of aviation experience daily. There are a couple guys I work with that started their on part 145 repair station years ago. Another guy owns his own Avionics shop. Sometimes I sound them out on issues I see or ask about here.

And, Sometimes you get response like, yeah we had a guy in the other day with XYZ problem. I took one look at it and told him were not going to touch that. Many of their customers go there because they want it done per the book, and then some. Hassling over the small stuff is not what some owners want.

The owners attitude toward safety, compliance will be reflected in his airplane. Old USMC promotion warrants used to say, "attention to detail." I always liked that. Good Luck.

 

[Silvaire]

For contextual accuracy let it be known that the page cited from FAA-8083-H-1A is in Chapter 5, the title of which is "Center of Gravity Change after Repair or Alterations"

We have not been discussing a repair, an alteration nor a change in either the empty weight or CG. We have been discussing a clerical error that in no way, shape or form under any published regulation requires an A&P Mechanic to be corrected or signed.

If a Pilot cannot legally correct this clerical error how can he possibly legally fly the airplane after he has changed the Weight and Balance by putting fuel in the tanks and climbing aboard?

 

[Witmo]

For contextual accuracy let it be known that the page cited from FAA-8083-H-1A is in Chapter 5, the title of which is "Center of Gravity Change after Repair or Alterations"

We have not been discussing a repair, an alteration nor a change in either the empty weight or CG. We have been discussing a clerical error that in no way, shape or form under any published regulation requires an A&P Mechanic to be corrected or signed.

If a Pilot cannot legally correct this clerical error how can he possibly legally fly the airplane after he has changed the Weight and Balance by putting fuel in the tanks and climbing aboard?

It's not a question of capability. A pilot is required to calculate his weight and determine if his loaded aircraft is within cg limits using the aircraft w&b documentation. If the documentation is in error, he needs an authorized person to correct it. He's not authorized to alter the aircraft w&b documentation, only to use it to calculate he's within the approved envelope. Who determines what errors are trivial and what errors are substantive? If it's a MX function, a mechanic needs to do it correctly. If its done wrong, a mechanic needs to fix the mistake. I can find no FAA exception for "clerical" mistakes and pilots being allowed to correct a mechanic's error, clerical or otherwise. Would a math error be a "clerical" error anyway?

 

[gismo]

For contextual accuracy let it be known that the page cited from FAA-8083-H-1A is in Chapter 5, the title of which is "Center of Gravity Change after Repair or Alterations"

We have not been discussing a repair, an alteration nor a change in either the empty weight or CG. We have been discussing a clerical error that in no way, shape or form under any published regulation requires an A&P Mechanic to be corrected or signed.

I think I disagree. Unless the incorrect W&B was itself a correction of an error, it was likely generated to accommodate an alteration. Therefor the correction would also be "after a repair or alteration".

Also if an A&P signature is required for the initial attempt, why wouldn't it be needed for any subsequent corrections?

 

[Silvaire]

This example is a mathematical error, nothing is wrong with the W&B other than he accidentally multiplied the wrong two numbers. All the correct numbers are there to produce the correct result, nothing is being altered.

It's the same thing as if a Mechanic had made a mathematical error for the total airframe time in your logbook. The error is clearly traceable and definable from previous logbook entries. Can the owner make an entry with the corrected total airframe time or does he have to have an A&P Mechanic do it? Nothing is getting crossed out, whited out or redacted with a Sharpie pen. There is no cover-up or skulduggery involved in this. The end result is a CORRECT W&B Report as opposed to an erroneous one.

 

[gismo]

This example is a mathematical error, nothing is wrong with the W&B other than he accidentally multiplied the wrong two numbers. All the correct numbers are there to produce the correct result, nothing is being altered.

It's the same thing as if a Mechanic had made a mathematical error for the total airframe time in your logbook. The error is clearly traceable and definable from previous logbook entries. Can the owner make an entry with the corrected total airframe time or does he have to have an A&P Mechanic do it? Nothing is getting crossed out, whited out or redacted with a Sharpie pen. There is no cover-up or skulduggery involved in this. The end result is a CORRECT W&B Report as opposed to an erroneous one.

I suspect that if you alter an official record like a logbook entry that appears with a signature other than your own you need to have the same authority as the original signer. This is certainly true for legal documents like contracts and affidavits, with those there's no way it's legal to make your own corrections after it's been signed by all parties unless said parties acknowledge the correction with their initials or signature.

 

[Silvaire]

I suspect that if you alter an official record like a logbook entry...

Where did I say you were going to alter an entry? I specifically stated that you weren't going to mark, cross out or erase anything. You are simply going to make your own entry stating the correction. You can use references to the previous entries to explain the error but you are not going to change them in any way.

Same goes for the W&B Report. There is no required format for it, the only requirement is that it contain the CORRECT empty weight and empty weight CG and be in the aircraft.

 

[Jaybird180]

Where did I say you were going to alter an entry? I specifically stated that you weren't going to mark, cross out or erase anything. You are simply going to make your own entry stating the correction. You can use references to the previous entries to explain the error but you are not going to change them in any way.

Same goes for the W&B Report. There is no required format for it, the only requirement is that it contain the CORRECT empty weight and empty weight CG and be in the aircraft.

So by that logic, is a spreadsheet on my iPad a legal W&B if it's onboard the aircraft?

 

[Henning]

I suspect that if you alter an official record like a logbook entry that appears with a signature other than your own you need to have the same authority as the original signer. This is certainly true for legal documents like contracts and affidavits, with those there's no way it's legal to make your own corrections after it's been signed by all parties unless said parties acknowledge the correction with their initials or signature.

You make the format correction and sign it yourself if you want. Since the signature certified data hasn't changed, no big deal as long as you produce the correct result in the output of the form. The mechanic certificate is required to provide the input to the form, not the output. It is only obvious and directed arithmetic, pilots are trusted to do W&B arithmetic, we have been tested on it; it is in our assigned scope of responsibility.

 

[Henning]

So by that logic, is a spreadsheet on my iPad a legal W&B if it's onboard the aircraft?

Interesting question considering that the FAA allows other required documentation to be on an iPad. It's not wholly germane to answering the other question though, but it could alleviate the need since the weights were good and arms provided by the manufacturer. The question is, is there a eSig protocol to let the mechanic endorse the weight, otherwise I imagine a PDF with his sig could provide the provenance.

 

[bnt83]

Sometimes.

 

[Silvaire]

Interesting question considering that the FAA allows other required documentation to be on an iPad. It's not wholly germane to answering the other question though, but it could alleviate the need since the weights were good and arms provided by the manufacturer. The question is, is there a eSig protocol to let the mechanic endorse the weight, otherwise I imagine a PDF with his sig could provide the provenance.

As you said in your earlier post Henning, the Mechanics signature is only required for any work accomplished which resulted in a revised W&B. That document could be a work order or even a 337 and it is not required to carry that on the aircraft. The requirement is for a W&B Report which could be as sparse or fancy as the owner chooses.

It's very easy for example, using the empty weight and CG along with the gross weight CG ranges and a sheet of graph paper, to create an envelope diagram that would allow quick and easy verification that any resultant loaded weight and CG were in the box.

As for having it all on an iPad? I technically so no reason why not. Are you allowed to have an AFM on an iPad?

 

[gismo]

As you said in your earlier post Henning, the Mechanics signature is only required for any work accomplished which resulted in a revised W&B. That document could be a work order or even a 337 and it is not required to carry that on the aircraft. The requirement is for a W&B Report which could be as sparse or fancy as the owner chooses.

It's very easy for example, using the empty weight and CG along with the gross weight CG ranges and a sheet of graph paper, to create an envelope diagram that would allow quick and easy verification that any resultant loaded weight and CG were in the box.

As for having it all on an iPad? I technically so no reason why not. Are you allowed to have an AFM on an iPad?

If the airplane is weighed to generate data for a revised W&B would an A&P signature be required? Weighing is not modifying or repairing.

 

[Henning]

If the airplane is weighed to generate data for a revised W&B would an A&P signature be required? Weighing is not modifying or repairing.

Interesting question, under those auspices I would say the A&P is not in play, it would either require nothing, or an IA since attaining weight would as you point out, not be a maintenance function but rather one of inspection.

 

[Witmo]

Interesting question, under those auspices I would say the A&P is not in play, it would either require nothing, or an IA since attaining weight would as you point out, not be a maintenance function but rather one of inspection.

Inspection is a maintenance function as per the faa definition of maintenance and reserved to certificated a&P's. An IA is only required for annual inspections and 337 approvals.

 

[Silvaire]

If the airplane is weighed to generate data for a revised W&B would an A&P signature be required? Weighing is not modifying or repairing.

I know you are posing this as a theoretical question but why would one revise the W&B if no alteration or repair had been done to the aircraft? If it were weighed however and the results differed from the current W&B Report that in itself would constitute an alteration (for whatever reason) So unless you come up with the exact same results, which leaves you with no purpose in creating a revised W&B Report anyway, there is no way for this scenario to play out.

Maybe a better way to pose the question would be ask what would happen to you if an FAA inspector came nosing around and saw that you had your fully assembled airplane on a set of scales as opposed to having your magneto torn apart on a bench and fiddling with it?

 

[Witmo]

I know you are posing this as a theoretical question but why would one revise the W&B if no alteration or repair had been done to the aircraft? If it were weighed however and the results differed from the current W&B Report that in itself would constitute an alteration (for whatever reason) So unless you come up with the exact same results, which leaves you with no purpose in creating a revised W&B Report anyway, there is no way for this scenario to play out.

Maybe a better way to pose the question would be ask what would happen to you if an FAA inspector came nosing around and saw that you had your fully assembled airplane on a set of scales as opposed to having your magneto torn apart on a bench and fiddling with it?

Aircraft are weighed and balanced all the time without being in conjunction with an alteration. Some owners ask that one be done when the airplane is older and hasn't ever been weighed but the official weight and balance has been adjusted numerous times. They do it for peace of mind. What would a FAA inspector say if he saw a non-a&p weighing an aircraft? Probably nothing unless it became known that the official w&b document was being replaced or changed in any way by an unauthorized person.