Logbooks and "other evidence"

Discussion in 'Flight Following' started by Half Fast, Nov 6, 2017.

  1. Half Fast

    Half Fast Cleared for Takeoff

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    In section 61.51, the FAR requires

    So do any of you sport pilots carry something other than your logbook? Any idea what the FAA would deem acceptable as "other evidence?" This is one of those questions that probably shouldn't be asked of the FAA, lest we not like the answer.

    I'd prefer not to carry my actual logbook on flights, lest I screw up and leave it in some rental aircraft or spill my beer onto it during a rough landing. I'm thinking that a photocopy of the logbook endorsements would suffice.

    Thoughts? Anyone know if the issue has ever come up?
     
  2. labbadabba

    labbadabba Pattern Altitude

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    I had an endorsement to take an FAA written exam put on a post-it note when I didn't have my log-book with me. Methinks that is what it means.

    I guess as a sport pilot you need to have it on your person, interesting... In that case, def have a photocopy back-up.
     
  3. rocketflyer84

    rocketflyer84 Line Up and Wait

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    Photo of your logbook entires stores on an IPad?
     
  4. N659HB

    N659HB Pattern Altitude

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    Clear as mud, like most every regulation. I carry my logbook every flight, but I plan to make photo copies. My flight review is Saturday. I'll ask my CFI for clarification.
     
  5. Ryanb

    Ryanb En-Route PoA Supporter

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    Get a better cup holder...:rockon:
     
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  6. Twin_Flyer

    Twin_Flyer Cleared for Takeoff

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    :rofl:
     
  7. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    How about a photo on your cell phone?
     
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  8. Shawn

    Shawn En-Route

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    I don't think digital copies are yet accepted by the FAA. I was with my CFI and his other student was on a check ride away from home...well, student needed one of the endorsements that was not completed and the DPE would not accept a picture of it...we had to send that picture of the endorsement to the student via email, then student then had to print it out at the FBO he was at for it to be accepted...now it was the same friggin thing from the same digital image, but the FAA is still stuck in the paper stone ages apparently.
     
  9. frfly172

    frfly172 Touchdown! Greaser!

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    Keep a copy of the log book on my I pad and cell phone.
     
  10. rk911

    rk911 Pre-takeoff checklist

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    I'm a sport pilot and was told unequivocally that I had to have my original logbook...not photocopies...with me which includes all of my endorsements during every flight. i keep it in my flight bag which lessens the chance of losing it. I feel the same way the OP does and to further demonstrate the idiocy of that policy when my CFI lost his logbook and did not have copies. he had to recreate everything from FBO logs, my logs, etc. so I have copies of every page and every endorsement in our safe deposit box as well as keeping a parallel electronic log.
     
  11. wayne

    wayne Line Up and Wait

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    I thought that’s why LSA’s can have one passenger; hold my beer.
     
  12. Half Fast

    Half Fast Cleared for Takeoff

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    Do you mind telling us who told you that and what his rationale was?

    It seems pretty clear that something other than a logbook is acceptable. Otherwise the reg wouldn't have an "or" in it. The question is what might be okay.

    I suppose if photocopies aren't acceptable you could get your CFI to sign a second set of endorsements on a single sheet.

    I suspect it will (unfortunately) be up to whatever official is looking at it as to what is good enough.
     
  13. MIFlyer

    MIFlyer Pre-takeoff checklist

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    I’m private and not required to carry, but I snap a photo every few flights that backs up to the cloud in case it’s lost


    Sent from my iPhone using Tapatalk
     
  14. rk911

    rk911 Pre-takeoff checklist

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    the chief instructor at the flight school is who told me i must always carry the actual logbook and not copies. he gave two reasons....a ramp check and if i rent at another FBO i'd be able to prove endorsements for B,C and D airspace, etc. well, i have been ramp checked and i did have my logbook checked for a Class D endorsement out in AZ prior to renting a couple of years ago.
     
  15. Half Fast

    Half Fast Cleared for Takeoff

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    Why did he think only a logbook would be acceptable at a ramp check?
     
  16. rk911

    rk911 Pre-takeoff checklist

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    didn't ask. this was part of my first day orientation. logbook and valid DL were among the items a sport pilot would need to produce during a ramp check plus the aircraft reg, AWC, etc. well, sure enough, we (my CFI and myself) were ramp checked a couple of months later and the FAA rep asked to see my logbook. either she was new and not very familiar with LSAs and the Sport Pilot pgm or she was testing me cuz she sure didn't seem to know much about either.
     
  17. Dana

    Dana Pre-takeoff checklist

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    Seems it would be logical for a CFI to write out and sign copies of any endorsements on a blank business card so you could carry it in your wallet and leave the logbook at home.
     
  18. midlifeflyer

    midlifeflyer Final Approach

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    I agree with you. I think (don't "know") the "other evidence" is there as an alternative. Compare that language with the previous subsection and the next subsection which both require recreational pilots and sport pilots to carry logbooks.

    Although it never was required, years ago, the FAA had a form for a wallet-sized card for flight reviews. It was Form 8710-5. About 12 years ago, I reproduced them and made them available to CFIs to put on the back of business cards as a marketing thing.
    8710-5.PNG

    I don't see a problem with that kind of form for sport pilot endorsements. I also see no difference between digital and paper when it comes to logbooks, so long as the endorsement bears the CFI's signature (a whole 'nother issue). Then again, I can't account for the reaction of any particular ASI when encountering something they don't expect.
     
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  19. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Final Approach PoA Supporter

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    Electronic records are easy to modify and falsify. Forging a paper record would require access to a scanner and a printer.
     
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  20. Omalley1537

    Omalley1537 Pre-takeoff checklist

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    9B7F2E35-C6EC-42C1-A12F-6699DE4A487A.jpeg
    Or one of these...this one has a built-in stall horn...
     
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  21. Half Fast

    Half Fast Cleared for Takeoff

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    It's not like access to a scanner and printer is difficult, though. Trivial, in fact.
     
  22. Eric Gleason

    Eric Gleason Pre-Flight

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    There's only one valid source to clarify this, and that's your local FSDO. Anyone who is not an employee of the FSDO is applying their own interpretation, which doesn't carry any more weight than your own.

    The most value the option of someone like a CFI has is that *maybe* they have an idea what what the FSDO's policy is. Maybe.
     
  23. midlifeflyer

    midlifeflyer Final Approach

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    Actually, oftentimes, no. FSDOs can differ on this unless the FAA has a uniform published policy. You call your FSDO and they say no problem. Then you fly and have an incident in another FSDO district where it is a problem.
     
  24. midlifeflyer

    midlifeflyer Final Approach

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    Electronic records can be far more difficult to falsify than paper records. That's why there are so readily accepted in business and in government, including by the FAA. The FAA has some published guidelines for electronic records, AC 120-78A, "Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals." Most of the eLog companies out there claim to meet them.
     
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  25. Eric Gleason

    Eric Gleason Pre-Flight

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    True, but we're splitting hairs awfully thin now. FSDOs are responsible for interpreting and enforcing the FARs in their district. If another district interprets the rules differently and it bites someone, the FAA is likely not going to step in unless the pilot's attorney manages to make it happen, and that wouldn't happen for a case like this.

    Let's say Half Fast's home airport is in the Orlando district, and Orlando tells him by email that photocopies of the endorsements meet the rule, and he can leave the originals at home in his safe. Then he gets ramp-checked in the Tampa district and they say photocopies aren't good enough. He shows them the email of the Orlando FSDO's interpretation, and odds are good that the agent is reasonable enough to say he doesn't agree, but it's okay to fly home. There will likely be a follow-up exchange between the two districts, and our guy may get a letter later on explaining what he has to do differently, but almost certainly wouldn't be subject to any enforcement action.

    Regardless, the point was that the chief flight instructor and his CFI are not the people who can clarify this.
     
  26. midlifeflyer

    midlifeflyer Final Approach

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    I agree with that point. Only the FAA can clarify FAA policies.

    Whether FSDO history of doing exactly that - different interpretations in different districts, and sometimes different Inspectors in the same district - is splitting hairs thinly, I 'll leave to others.

    When I come across one of these, unless I am willing to ask for a formal interpretation, I follow my own.
     
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  27. N659HB

    N659HB Pattern Altitude

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    Our tax dollars at work! Yet again.
     
  28. midlifeflyer

    midlifeflyer Final Approach

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    I'm not so sure creating requirements to allow the expansion of privileges for a brand new never seen before pilot certification strongly urged upon the FAA by a number of pilot organizations really fits into the usual meaning of that. Although I guess, some folks do think it would have been better for the FAA to have left things alone and heck, if you can't meet at least private pilot requirements, just stay on the ground.
     
  29. N659HB

    N659HB Pattern Altitude

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    Oh, I meant making regulations clear as mud.
     
  30. midlifeflyer

    midlifeflyer Final Approach

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    LOL. We do quite a good job of making the simple straightforward ones sound complicated.
     
  31. Doug F

    Doug F Pre-takeoff checklist

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    I went through this in FDA land. Prior to 1997 the FDA accepted only paper records. In '97 they release 21 CFR Part 11 that specifically allowed for use of electronic records. The reg included specific mandates for what constituted a valid electronic record or signature. The intent of the reg was to create an environment that made electronic forgery difficult. It spawned an entire consulting industry to help companies read the tea leaves and figure out how to meet the regs. Bottom line, if you couldn't prove that the e-record or e-sig presented to the FDA was THE record or sig, you were non-compliant and the record was invalid. It's a non-trivial problem that would be difficult for an individual to comply. Compliance requires validated and controlled systems. My guess is the FAA's approach would be similar.
    Interesting side note: I worked for a company that did both FDA and FAA work. When I asked the FAA side if there was anything similar to Part 11 for the FAA side, the answer always came back 'no'. Our systems were accepted by the FAA but as far as I know they never asked to see the development validation or record management side of the apps. Go figure...00000000000000000
     
  32. bflynn

    bflynn En-Route

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    They are for basicmed. Now you might have to bring in a paper copy later if they care to see it, but it is not true that digital copies are not accepted by the FAA.
     
  33. midlifeflyer

    midlifeflyer Final Approach

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    Similar, but with the update of 20 years of experience, acceotance, industry standards, and acknowledgement that technology moves faster than regulation. You can see it reflected in the Advisory Circular I linked earlier, which is substantially more liberal than its predecessor, particularly for us Part 91 guys and meeting our Part 61 requirements.
     
  34. midlifeflyer

    midlifeflyer Final Approach

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    Correct , but one would actually have to read the AC to know that. Much easier to believe than to read.
     
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  35. Doug F

    Doug F Pre-takeoff checklist

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    Any idea if/how the circular might apply to a Depot Repair station? The company I used to work for did a bunch of work for both military and civilian companies and manufactured stuff that went into aircraft (everything from altimeters to FLIR systems for FedEx). Would records associated with repair (as opposed to maintenance) be in scope? I am not familiar with the FAA regs that drove the company's paperwork trail so I'm just looking for some general feedback.
    Thanks for anything you can provide.
     
  36. James331

    James331 Touchdown! Greaser!

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    I carry my certs and medical, want anything further send a letter to my lawyer and I'll send it to him to send to you.
     
  37. mscard88

    mscard88 Touchdown! Greaser!

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    I thought they were clear and thought I fully understood the regs until I joined POA and started reading everyone's opinions of various regs. :crazy:
     
  38. midlifeflyer

    midlifeflyer Final Approach

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    You'd have to read it, since the devil is in the details, but AC 120-78A states it applies to persons providing Part 43 maintenance and Part 147 repair stations. Keep in mind though, that this AC only deals with the form the records are kept in. There are other regs, rules, orders, ACs and guidances discussing what the records must consist of and the information they must contain.
     
  39. Doug F

    Doug F Pre-takeoff checklist

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    My (naive) read seems to indicate that the repair/rebuild work my company did would be covered but the original manufacturing may not be covered.
    This is kind of interesting in that it's an 'Advisory' document and not mandatory but within the text of the AC it basically says 'if we look at your e-records/sigs and find them lacking we are likely to grill you' so it's kinda/sorta like a reg but it's not. At least the FDA had the decency to say 'it's a reg' when they implemented 21 CFR Part 11 back in '97.
    I sent a copy of the AC to several people at my prior company for their review. The good news for them is that the systems I designed are compliant with FDA's Part 11 so the AC is covered. Other electronic systems...maybe, maybe not.
    Thanks for the info.
     
  40. midlifeflyer

    midlifeflyer Final Approach

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    Personally, I think the FAA was pretty clever in using advisory guidance for this (as it does for many other things) instead of issuing regulations which technology might moot in a month.

    All the FAA is saying is, "your electronic records need to meet standards of authenticity. Here are some you can follow as a 'safe harbor.'" Doesn't preclude someone, particularly a company, from looking at other industry standards which accomplish the same thing, perhaps updated ones that are maybe even better. Pretty standard fare from what I've seen in other regulated industries.

    Your prior company? Well that's what compliance counsel or other compliance professionals are for. Not SGOTI.