Annual inspections and log entries

Half Fast said:
Folks, you do realize that you can scan the sticker, shrink it in ppt or word, then print it onto your own blank sticker paper, right?
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Can you? Interesting concept. Back in whatever year it was, the government said that scans (and faxes) were acceptable documentation. So I never thought about it, but I don't see any reason as far as the FAA is concerned if you scan the sticker.

But two things come to mind. First, I could see some issues trying to sell the plane if you presented "Logbooks" that were full of copies of the stickers and did not actually have the IA's original signature. Sure, probably still legal, but I could see a lot of people questioning the copies.

And the other, which I'm not sure where this falls in the scheme of things, but I remember there was some issue with a plane in a shop my plane was at and there was actually some wording on the sticker that the FSDO guy actually messed up on (I'm assuming some installation they had to get involved in). On the phone he told the IA to just stick a new sticker over the old one and a discussion ensued. Bottom line was you can't just stick one sticker over another one. So again, not sure how that falls into place here, but basically you're presenting a copy when you did have the original.
 
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Heck, I bought the plane with an E signature on a contract, I bought a house with an e signature. I'm sure an A&P or IA's electronic signature on a printed sticker would be fine. Heck, a PDF copy printed out would be fine for the FAA or anyone else, so no, I think the days of needing a "wet" signature with a different color ink pen are behind us.
 
In reality, unless there's a legal issue where the signer claims it's not his signature, nobody will even notice or care that it's not a real signature. I raised it mainly as an academic question. I've been "signing" forms with a pasted bitmap of my signature for years and nobody has ever questioned it.
 
An annual is an inspection. Regardless of whether it's signed off IAW appendix D or a manufacturer's maintenance manual the signed statement that it was done means that all of the listed tasks were completed. That includes the engine and propeller and there is no need to repeat it in writing or state that you did a compression test or that you checked the air pressure in the tires. Most IA's will however make entries in engine and propeller logbooks just so the owner doesn't have a hissy fit. Many IA's will also make long winded entries to try to make an impression that the owner is getting his money's worth. I know this because I have had to spend countless hours reading through them over the past 50 years. Personally I prefer terse and to the point, just the facts please.
 
ateamer said:
E-signatures have been valid for commerce under federal law for 26 years. There is absolutely no reason why they shouldn’t be acceptable for logbooks.
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Except maintenance signatures follow different guidance due to the airworthiness connections per ICAO and other international agreements. So if you look at the signature definitions within that FAA guidance a mx signature is handwritten or part of an FAA acceptable electronic or digital signature process. One guidance example is an AC 120-?? which shows these basic definitions.

However, only those signature records per 91.417 are required to be retained in their original handwritten, ie. pen and ink, condition. But one point to note is while .417 states life limit part status and OH status in order to "prove" those times you must be able to produce the component card or mx record with those original wet signatures. And a scan of those required signatures is considered a photocopy and not equvilent.
 
Bell206 said:
However, only those signature records per 91.417 are required to be retained in their original handwritten, ie. pen and ink, condition.
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Am I missing something? Where do you find "handwritten" "pen" "ink" or anything like that in 91.147? There is (a) (1) (iii) that states: "The signature, and certificate number of the person approving the aircraft for return to service." But in no way does that imply it must be an original hand written signature.

And even if I did miss it, I'm pretty sure AC 120-78B supersedes anything in 91.417 or any other FAR as far as digital records go. Though as I commented earlier, I could see a potential issue with buyers depending upon how the records are kept. I'd be wondering what was going on if I were handed a binder that is full of 8.5x11" photocopies when it could just as easily be an 8.5x11" page with the original signatures. It wouldn't be so much a "they can't do this legally" question as "okay, why are they not showing me the real signatures?"
 
M20K said:
And even if I did miss it, I'm pretty sure AC 120-78B supersedes anything in 91.417 or any other FAR as far as digital records go.
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An AC has no legal weight and cannot supercede a regulation.
 
In the U.S. E-signatures and digital signatures are definitely OK if they meet the guidance in AC 120-78B. I can't find anything in 91.417 or 43.9 or 43.11 that contradicts that or restricts the format. All just mention "signature".

The wrinkle is that if you hold an Operator Certificate, you must submit and get OpSpec A025 authorization from the FAA for the system. However, AC 120-78B Chapter 2.3 details the process fairly clearly.

AC 120-78B gives good guidance on the signature aspect. Chapter 2 details the digital signature requirements. Chapter 3 details what an "electronic recordkeeping" system should look like.

2.1.2 even reminds us that due to Public Law 106-229, a valid, legal e-sig. cannot be denied just because it's an e-sig. Which I take that to mean that unless the format is specifically declared in the CFRs, an e-sig. is legally acceptable.

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M20K said:
Am I missing something? Where do you find "handwritten" "pen" "ink" or anything like that in 91.147? There is (a) (1) (iii) that states: "The signature, and certificate number of the person approving the aircraft for return to service." But in no way does that imply it must be an original hand written signature.
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Except, in general, thats not how the regulations work by providing all inclusive info. Its the underlying FAA guidance that provides those details as I stated above and that guidance comes in many levels: ACs, Orders, Policy Letters, etc. So where you only see "signature" in the rule, the FAA has provided additional guidance in defining that term.

And the AC 120-78 above does provide 3 such guidance definitions for the different types of FAA recognized mx signatures. I believe the AC defines it as a "signature" should be handwritten or part of FAA acceptable system. There is also an Order that takes it a step further which includes the "wet, pen and ink" reference. And if I recall the "scan is a photocopy" reference I used above was from an LOI which also indicated the wet signature requirement.

Plus if you look at 91.419 at the sale of an aircraft which requires the transfer of those 91 417 records, its at the descretion of the buyer if he wants those records in a digital format or paper. So as I mentioned, the only mx records/signatures one needs to maintain in their original state are those in 91.417.
 
Ed Haywood said:
An AC has no legal weight and cannot supercede a regulation.
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Ummm.... It's called the Electronic Signatures in Global and National Commerce (ESIGN) Act, which became law on June 30, 2000. :cool:

The AC is the FAA's reference. So if you didn't know... Digital copies, signatures, etc. are all accepted by the US Government, which means the FAA.

But regardless of that. I still see nothing in 91.417 that even remotely says it has to be a handwritten signature in ink. Again, unless I'm just blind and missing it.
 
Bell206 said:
Except, in general, thats not how the regulations work by providing all inclusive info. Its the underlying FAA guidance that provides those details as I stated above and that guidance comes in many levels: ACs, Orders, Policy Letters, etc. So where you only see "signature" in the rule, the FAA has provided additional guidance in defining that term.
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I'm not saying you can't use a handwritten signature. My point is that it is no longer required in any department of the US Government.

You can use a crayon and make an X if you want. (Hmm... But I think there may be something somewhere that a witness has to cosign if you use a "mark." But I don't remember the specifics.)
 
M20K said:
I'm not saying you can't use a handwritten signature. My point is that it is no longer required in any department of the US Government.
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As I stated , if you want to use an electronic mx signature system it needs to meet certain FAA requirements to be legit. There are international aviation agreements at play that those other govt depts dont have. And even though Part 91 ops do not require any formal acceptance of an e-sign system, if your personal selected system does not meet the same key items of an accepted system, those records will be invalidated per the guidance.

Regardless, I'd go easy on the crayons and Xs in your mx records.
 
Bell206 said:
it needs to meet certain FAA requirements to be legit.
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No... It needs to meet the Electronic Signatures in Global and National Commerce (ESIGN) Act standards. Which the FAA must comply with.

It's not rocket science.
 
Can anyone point to an example of where the FAA ever said a record was not acceptable because it had an electronic signature?
 
M20K said:
It's not rocket science.
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Exactly. And if you were to read the existing guidance you'll find the E-Sign Act and other similar Acts all allow goverment agencies to develop policy and performance standards to comply with those Acts within their oversight. And for electronic signature and records applicable under 14 CFR the FAA has that authority.

WDD said:
Can anyone point to an example of where the FAA ever said a record was not acceptable because it had an electronic signature?
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Those examples tend to be from enforcement actions and if it doesnt raise to the Admin level there would be no public examples to link to. However, there are several public legal LOIs that address that topic should you choose to look for them.
 
Bell206 said:
Those examples tend to be from enforcement actions and if it doesnt raise to the Admin level there would be no public examples to link to. However, there are several public legal LOIs that address that topic should you choose to look for them.
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So that would be a “no”.
 
WDD said:
So that would be a “no”.
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As I recall, that would be a yes as the electronic records in question did not meet the requirements of AC 120-78 or 8900.1 guidance. Follow the guidance and your golden.
 
Bell206 said:
Exactly. And if you were to read the existing guidance you'll find the E-Sign Act and other similar Acts all allow goverment agencies to develop policy and performance standards to comply with those Acts within their oversight. And for electronic signature and records applicable under 14 CFR the FAA has that authority.
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I'm not the one saying you can't use electronic signatures. I believe I'm also the first one to reference AC 120-78B.

I'm fully aware of how you can use different means. But getting back to my original question... Please show me where it says "per 91.417 are required to be retained in their original handwritten, ie. pen and ink, condition" as you stated. I sure don't see it anywhere. And even if it were there, that has since been superseded by a Congressional Act, but for reference, I'd still like to to know why you think (or thought) pen and ink are/were required.
 
WDD said:
Heck, I bought the plane with an E signature on a contract, I bought a house with an e signature. I'm sure an A&P or IA's electronic signature on a printed sticker would be fine. Heck, a PDF copy printed out would be fine for the FAA or anyone else, so no, I think the days of needing a "wet" signature with a different color ink pen are behind us.
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Well… not so fast. I was told that was an absolute no by the feds when it came to a recent registration issue. Absolutely had to have original wet ink…. Arg

To clarify, I couldn’t take original signed affidavits (and such) and get certified true and correct copies to submit. Had to send the originals which made me nervous…
 
Tools said:
To clarify, I couldn’t take original signed affidavits (and such) and get certified true and correct copies to submit. Had to send the originals which made me nervous…
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True, you cannot send a scan or copy. You must send the original ***OR*** a true Digital Signature. (Same as you can't send a scan of a check, but you can send an ACH. :D)

So whomever told you it could ONLY be wet ink was incorrect, but it is by far the easiest way. (Scan it to have a digital copy, then use FedEx or USPS that you can track with a "Signature Required" so you have proof it got there.
 
M20K said:
I'm not the one saying you can't use electronic signatures. I believe I'm also the first one to reference AC 120-78B.
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I mentioned 120-78 in Post 48 but had forgotten the dash number on it. You acknowledged my reference in Post 49 and added the proper dash number. But to note, I’ve been signing off mx under that AC guidance since its original issuance in 2002 as my former day job was an early adopter of electronic mx records and signatures.

M20K said:
I'm fully aware of how you can use different means. But getting back to my original question... Please show me where it says "per 91.417 are required to be retained in their original handwritten, ie. pen and ink, condition" as you stated. I sure don't see it anywhere.
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It seems you are taking my use of 91.417 out of its original context so let me try this way. In order for me to affix my signature to a mx task per 43.9 or 43.11, I have two options: handwritten or via an AC 120-78 acceptable electronic signature process (see reference #1 below). My use of 91.417 in this context was to illustrate only those mx records are required to maintain their original legal signatures, as noted above, and that not all signatures have this same requirement.

And given AC 120-78 acceptable electronic records system are few and far between at the Part 91 level, the only legal signature option for the vast majority of recreational owners is a handwritten pen and ink signature for those 91.417 records requirements. A scan or photo of those 91.417 signatures is considered a photo-copy and is not considered a legal mx signature by the FAA .

Now the reason behind retaining the 91.417 original legal signatures is they provide the minimal regulatory requirement to show a Standard Airworthiness Certificate is both in effect and that the aircraft is airworthy (see ref. 2 below). And its the connection between the 91.417 records and the AWC that requires those signatures be in their original Part 43 legal format whether handwritten or part of an FAA acceptable electronic records system.

M20K said:
And even if it were there, that has since been superseded by a Congressional Act, but for reference, I'd still like to to know why you think (or thought) pen and ink are/were required.
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While you continue to believe those congressional acts superseded the FAA guidance, you’ll find in fact AC 120-78 was actually written to provide current policy and standards in CFR Title 14, ie., the FARS, for the congressional acts you reference with the latest revision dated Dec 2024. So the guidance was not superseded but augmented those congressional acts (ref. #3 below).


Reference #1: AC 120-78 and Order 8100.1, National Policy.
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Reference #2: Order 8900.1, National Policy
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Reference #3: Order 8900.1, National Policy
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There's a letter saying that you can do it either way - just airframe, or all logbooks. Both are valid. QED.
 
M20K said:
I'm pretty sure AC 120-78B supersedes anything in 91.417 or any other FAR as far as digital records go
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That's a negative ghost rider. AC's are NOT regulatory in nature UNLESS a FAR cites one directly.

A quick read of 91.417 does NOT cite 120-78B so no, relying on it will not keep you out of 'FAA jail'.
 
Silvaire said:
On the final departure he did a high speed pass along the runway past all of us. Something I watched and experienced naked eye with no phone or camera in hand and if you want to convince me it wasn't cool I'll take that argument.
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I'll take the bait - it was a little cool, but not nearly as cool as watching the Hawkins and Powers radial piston powered beasts work out of Greybull, WY in the mid-90s. Nothing cooler than a Jet-A fuel turbojet assisting some tired radials pull tons of retardant into the air. C-54, c-118, C-82, C-123, etc. Now that's cool.
 
pfarber said:
That's a negative ghost rider. AC's are NOT regulatory in nature UNLESS a FAR cites one directly.

A quick read of 91.417 does NOT cite 120-78B so no, relying on it will not keep you out of 'FAA jail'.
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Very true, they may not be a get out of jail free card. But typically ACs that are published AFTER the Reg are taken into consideration.

It's much easier to publish an AC than it is to rewrite the Regs, and changes happen with over time. A Legal Interpretation is even better, but there isn't one I can find, so hopefully I'll get one in about a year.
 
M20K said:
Very true, they may not be a get out of jail free card. But typically ACs that are published AFTER the Reg are taken into consideration.

It's much easier to publish an AC than it is to rewrite the Regs, and changes happen with over time. A Legal Interpretation is even better, but there isn't one I can find, so hopefully I'll get one in about a year.
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From what I understand (pecking order of sorts):

FAR is law
Legal Interpretation are how the FAA would interpret a law/FAR.
AC is a 'best practice' and has no weight unless a FAR cites it. Although I'm told that FSDO's give AC's the weight of FARs in most matters, unless a legal opinion conflicts.

People should read the FAA working group papers on FAA topics... it will quickly show you what a complete mess the FAA is. The 'Major Repair' working group paper is hilarious IMHO. The WG admits that the FAAs wording is so vague its useless and subjective.. you really never know until the FAA starts action against you.

If you have not moved in E/AB ownership then you are gonna have the boat anchor that is the FAA around your neck until you do.
 
Bell206 said:
A scan or photo of those 91.417 signatures is considered a photo-copy and is not considered a legal mx signature by the FAA .
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I don't believe this is the reason. Say for example I have a stack of 'Super Duper A&P #1233456' signed pre-preinted forms (labels or for a printer).

The issue arises in 43.9(a)(4): If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

This means that you have to sign the entry AFTER the work is performed, not fill out a blank, pre-signed entry. The preprinted form can have pre-populated text, but the signature cannot exist before the work is completed. This is also try for e-signs.

Also (this is gonna be entertaining) nothing says I have to write my name. Its says 'signature' and A&P number. A signature or 'mark' can by highly stylized or even a simple scribble. As long as the entry proper is legible and the certificate number is legible you are good to go.

At my last 121 I fought with QA on this multiple times. The company policy was (the this is a direct quote from the GMM) 'signature and legible employee ID number'. After 7 work cards initialed and signed, QA dude said he was not going to sign off his part because he couldn't read my name (my signature is completely illegible). That plane sat until he was 'educated' on what a signature is. I wasn't going to alter/forge my signature for some random jabrony that can't read the GMM.
 
pfarber said:
AC is a 'best practice' and has no weight unless a FAR cites it. Although I'm told that FSDO's give AC's the weight of FARs in most matters, unless a legal opinion conflicts.
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Yes, that's basically what I heard. A lot of times the FAA will release the ACs vs trying to change the Reg, which is a pain.

But actually, duh.... Since it was the over all Government that changed the AC is explaining the new digital world starting with the Electronic Signatures in Global and National Commerce Act (ESIGN) and other digital laws/acts by Congress would supersede the FAA's Reg. So I'd now say that the AC was explaining at that time about the new brave digital FAA. And I'll guess the old Reg will go unchanged until it becomes a hassle for someone in the Gov. Not one of us lowly pilots. :D
 
pfarber said:
From what I understand (pecking order of sorts):

FAR is law
Legal Interpretation are how the FAA would interpret a law/FAR.
AC is a 'best practice' and has no weight unless a FAR cites it. Although I'm told that FSDO's give AC's the weight of FARs in most matters, unless a legal opinion conflicts.
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U.S. Code Title 49 is the law.
CFR Title 14 is the regulation to enforce the law.
FAA Orders provide the National Policy to enforce the regulation.
FAA ACs provide acceptable guidance to comply with the regulation.
 
Tools said:
Well… not so fast. I was told that was an absolute no by the feds when it came to a recent registration issue. Absolutely had to have original wet ink…. Arg

To clarify, I couldn’t take original signed affidavits (and such) and get certified true and correct copies to submit. Had to send the originals which made me nervous…
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Interesting

I used these folks for escrow, closing, and registration. They have been doing this for many years, and are a substantial "real" company. I never sent a wet signature to anyone when we bought and registered the aircraft.

Aerospace Reports

www.aerospacereports.com www.aerospacereports.com
 
WDD said:
Interesting

I used these folks for escrow, closing, and registration. They have been doing this for many years, and are a substantial "real" company. I never sent a wet signature to anyone when we bought and registered the aircraft.

Aerospace Reports

www.aerospacereports.com www.aerospacereports.com
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I had “stuff”, non sale set asides, affidavits of small estate, death cert, etc.

It was THOSE documents which I wanted so badly to NOT entrust to the USPS. If they go lost, the life of registering neat old plane gets HARD.

But man were they adamant about having the original…
 
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