Finding more work.

Discussion in 'Maintenance Bay' started by Tom-D, Oct 29, 2017.

  1. Bell206

    Bell206 Pre-takeoff checklist

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    Tom:
    You are 100% correct on the write up requirements. But that was not the context of my replies to you or Salty. All maintenance, alteration , or preventative maintenance must be performed in accordance with 43.13 and inspections to 43.15. When completed you make the required entries per 43.9 and 43.11.

    As far as I know the word "airworthy" in a write up is only required in an annual sign off, and as for the "approve return to service" your signature constitutes that per the same 43.9.

    So to stick with your oil change example, if you perform half an oil change and find metal, but your customer is not concerned and demands you finish the oil change... what would be your regulatory defense to signing off half a maintenance task if the owner takes your entry to the fsdo and cites you violated 43.13(a)?

    While the FARs may seem disorganized, there is a defined hierarchy. The owner is responsible for the overall airworthiness 91.403(a) to include how that airworthiness is documented in his record 91.405(b). Cherry pick at your peril.
     
  2. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    Is there not any maintenance manual guidance? Every engine I've ever worked on would require a high power engine run for a specific amount of time and if there was no metal in the filter it was good, if there was metal, it would be an engine change/overhaul.
     
  3. JAWS

    JAWS Pre-takeoff checklist

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    § 91.405 Maintenance required.
    Each owner or operator of an aircraft -

    (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;

    (b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service;

    (c) Shall have any inoperative instrument or item of equipment, permitted to be inoperative by § 91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required inspection; and

    (d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a placard has been installed as required by § 43.11 of this chapter.

    So what is an appropriate maintenance entry?

    § 43.9 Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records (except inspections performed in accordance with part 91, part 125, § 135.411(a)(1), and § 135.419 of this chapter).
    (a)Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:

    (1) A description (or reference to data acceptable to the Administrator) of work performed.

    (2) The date of completion of the work performed.

    (3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.

    (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.

    "Aircraft Registration: XXXXXX TTAF: xxxx
    Cowls removed, engine oil drained, filter removed. Cowling re-installed. No further action taken at this time.
    Mech: xxxxxxxx Licence: xxxxxxxx Date: xxxxxxxx"

    That entry should satisfy both requirements. I would make a copy and add it to my own file on the aircraft. I have heard that getting the owner to counter sign is also a good idea, but have never gone down that road.

    My entry will be good until the engine is touched again, either by me or by someone else.
     
  4. JAWS

    JAWS Pre-takeoff checklist

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    See AC43.13-1B, Chp 8.
     
  5. Tom-D

    Tom-D Ejection Handle Pulled

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    First of all the customer can not demand you finish any thing.
    I entered what I did, that is all that is required.
     
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  6. Tom-D

    Tom-D Ejection Handle Pulled

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    ACs are not regulatory. and I see no relationship to the subject.
    Why would you re-install the cowl?
     
  7. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    Agree. That sign off is inviting disaster
     
  8. Tom-D

    Tom-D Ejection Handle Pulled

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    Pretty much says it all.
     
  9. Bell206

    Bell206 Pre-takeoff checklist

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    JAWS:
    All perfect examples of how YOU would determine what is an "appropriate maintenance entry." Unfortunately that determination is listed under Part 91 which applies to an owner/operator making that determination and not the mechanic. Our guidance in 43 on entries only states "shall make an entry in the maintenance record of that equipment containing the following information:..." not what's "appropriate."

    It might seem like splitting hairs but the USC/FARs put the owner as the head kahuna regulatory wise and from a legal stand point gives him more wiggle room than a mechanic. There is existing guidance on this.
     
  10. Bell206

    Bell206 Pre-takeoff checklist

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    Tom:
    Maybe in your shop and rightly so. But as I explained in the post above an owner has more stroke in the matter than it may appear.

    If an owner comes to your shop today for an annual and directs you to use an OEM annual form from 1962, the year he bought his plane, but you state I'll use the form I want to use per Part 43, who is correct per the FARs? The owner.

    If a mechanic requires to make all his maintenance entries in a logbook only, but the owner hands him a bar napkin instead to make entry, who is correct per the FARs? The owner.

    If an owner travels to your shop to pick up his aircraft after your annual, complete with your appropriate "found to be airworthy" sign off, but then determines during the pre-flight the aircraft is unairworthy, who is correct per the FARs? The owner.

    If these are not examples of an owner demanding/insisting/mandating something then I guess I need a new dictionary.
     
    Last edited: Nov 1, 2017
    Norman and Checkout_my_Six like this.
  11. Checkout_my_Six

    Checkout_my_Six Final Approach

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  12. JAWS

    JAWS Pre-takeoff checklist

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    My reference above was in reply to Glen asking about references to an engine run-up.
     
  13. JAWS

    JAWS Pre-takeoff checklist

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    My entry is just an example. In my example above, I would install the cowls to be a decent guy. Might also install the filter and add the oil. Might leave the cowl off.

    But I would definitely be flagging the oil dipstick and throttle. Maybe some pictures as well.

    Luckily for me, this is just a theoretical exercise. I have not had to deal with this kind of thing so far. My customers tend to take my advice.
     
    Last edited: Nov 1, 2017
  14. paflyer

    paflyer Final Approach

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    IMO, no.
     
  15. paflyer

    paflyer Final Approach

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    I think only the FAA or the pilot can declare unairworthiness.
     
  16. paflyer

    paflyer Final Approach

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    No.

    Is this a CYA issue? :rolleyes:
     
  17. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    Would a mechanic not declaring it airworthy be the same as rendering it unairworthy?
     
  18. Norman

    Norman En-Route

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    I once did a pre-buy on a PA28R that had some unauthorized repairs to the wings. I called the FSDO and one of the inspectors saw the upper wing skins were fastened with countersunk rivets; neither dimpled nor the normal button head rivet. He got me off the hook by hanging a "condition notice" on the plane effectively grounding it. He bailed me on that and I'm thankful for that.
     
  19. paflyer

    paflyer Final Approach

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    Not necessarily. If it's in annual the owner can fly it away.
     
  20. danhagan

    danhagan Cleared for Takeoff

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    The owner sound like a real piece of ... er... work. I'd expect you to tell me what options are available to diagnose the source short of cracking the block. Have a friend that was told their case was cracked and he needed engine over-haul, etc. Second opinions at TWO major engine sites confirmed it was a "case crease mark" and not a crack. No leaking oil and he flew it another 900 hours to TBO without issue. At engine over-haul was also confirmed "not a cracked block".

    My mechanic sets up folders on his computer with the owners name and N number. When he prints a label, it is saved in the owners folder.

    Now for the 180: Years ago I went to look at a Tiger that the owner said was NDH. In the logs after traveling, I noticed a new engine and prop due to prop strike (so I think "OK" the owner isn't very trustworthy), followed by a log entry 3 weeks after new engine install that states "Plane off airport "landed" into 8 feet of saltwater" (with "LANDED" in parenthesis) followed by a specific statement that there was no engine tear down (which I think the mechanic was covering himself). Now imagine there was no prop strike and no entry for the saltwater "landing"? There was no accident history for this N number.
     
  21. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    Aircraft mechanics are always concerned with CYA, it's nature of the business.
     
  22. Tom-D

    Tom-D Ejection Handle Pulled

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    no
     
  23. Tom-D

    Tom-D Ejection Handle Pulled

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    I've done that once, with a rotted out longhorns on a Stinson 108-3. owner was there and saw the ASI pull the airworthiness certificate and got handed the letter grounding the aircraft. ended up selling the a/c for parts and the engine.
     
  24. Tom-D

    Tom-D Ejection Handle Pulled

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    Pilot options are " unsafe to fly " not unairworthy.

    91.7 Civil aircraft airworthiness.
    (a) No person may operate a civil aircraft unless it is in an airworthy condition.

    (b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.
     
  25. paflyer

    paflyer Final Approach

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    Um, re-read the reg slowly...
     
  26. Tom-D

    Tom-D Ejection Handle Pulled

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    How does he prove that, when you don't like the write up and throw it away. (assuming they gave you a sticker)

    I simply don't give the sticker to the owner, my stickers do not have the N or the times on them. I place it in the book and write in the times as per 43-9.
     
  27. ZeroPapaGolf

    ZeroPapaGolf Line Up and Wait

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    How do you prove it when the owner didn’t like the write up and cut the page out of the logbook?
     
  28. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    A repair station would have records, duplicates, of their work/findings. It would be advisable that individual A&P/IA's do the same.
     
  29. Tom-D

    Tom-D Ejection Handle Pulled

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    That's the quandary isn't it?

    it's a matter of who has proof, its the owners responsibility to get the sign off, but when there are pages missing form a log book, the NTSB will be asking a lot of questions about what that page contained. and when there is a smoking hole I'll bet the insurance companies will as well.
     
  30. Checkout_my_Six

    Checkout_my_Six Final Approach

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    Only two years worth.....o_O
     
  31. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    I have records going back more than 20 years. Someone can throw them away after I die.
     
  32. Tom-D

    Tom-D Ejection Handle Pulled

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    The only records we are required to keep are what we are required to show for renewal. and that's only an activity sheet.
     
  33. Checkout_my_Six

    Checkout_my_Six Final Approach

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    I don’t use that....so I don’t keep that.

    I do keep files with every sign off ... but that’s for me.
     
  34. Tom-D

    Tom-D Ejection Handle Pulled

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    How do you prove you are active in the industry?
     
  35. Checkout_my_Six

    Checkout_my_Six Final Approach

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    Perform maintenance. So I need to describe at least one sign off.
     
  36. Tom-D

    Tom-D Ejection Handle Pulled

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    Easy FSDO.:)
     
  37. Checkout_my_Six

    Checkout_my_Six Final Approach

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    Nope.....dats da rules for actively engaged.

    Remember....it's a two part question.
     
    Last edited: Nov 1, 2017
  38. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    I've never been required to prove that.
     
  39. danhagan

    danhagan Cleared for Takeoff

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    His have everything in fine detail and he stores everything. I imagine if something ever went to court over a single entry a mildly capable attorney could show the dozens of other entries that EXACTLY match the log book, and why would there be only one omission?

    By having a copy on your computer. If it floats your boat, shoot a picture with your phone and transfer to PDF. When I sold the Tiger this month and had nearly 2 suitcases of logs over 40 years, I was able to shoot each page of a book, transfer to computer and store using a JPG to PDF converter (free software). If I could do that many entries in about an hour and 15 minutes, I'm positive an A&P like Tom could do similar. Hell, you could shoot the customers entire log book, tell them you have a special support service storing their data and charge a nominal fee for that as well. I don't know anyone that likes to make logbook PDFs, but once in the work flow, it is quite easy.

    Imagine the Scenario:

    Customer: "Crap, I think I lost a log book"
    Tom or A&P: "No worries, you paid me to make a backup for you"
     
  40. Tom-D

    Tom-D Ejection Handle Pulled

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    I'd Bet that the number of freelanced A&P's that can do that is very low.

    Simply because we choose to not deal with those we can't trust.