Requirement to log FR, etc.

[sba55]

This question has been answered already, but I'd like to get more detail about the specific requirements here.

The scenario: You don't log most of your flight time, and while the CFI gave you a piece of paper to paste into your logbook for your last flight review, you didn't do so and have lost that piece of paper. I assume that the CFI logged the FR himself as well, but it's impossible to know for sure.

So, given this situation: Are you not able to fly as PIC? I suspect that this would only become relevant in the case of an accident/inspector's demand for the logbook - in which case you would have time to get your logbook into shape before presenting it. Is it _overly_ risky to fly as PIC? I realize that this isn't the best way to handle logging, but given this situation, what do you think?

 

[jesse]

If you don't have record of the flight review - it didn't happen.

61.51(a)

(a)Training time and aeronautical experience. Each person must document and record the following time in a manner acceptable to the Administrator:
(1)Training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review of this part.

Counting on being able to get the record from the CFI could backfire on you if the CFI can't be found or he no longer has it.

The instructor is actually not technically required to keep records of flight reviews given. (They are required to keep record of endorsements for solo flight privileges and knowledge tests and practical tests for 3 years).

Your options:
1.) Find the instructor and have them write you the endorsement again. They will hopefully have record of having done it.
2.) Get another flight review

Right now you have no proof that you completed a flight review therefore you didn't. You also have no clue if you can even get the endorsement again so flying without it would be a terrible idea.

 

[poadeleted20]

Let me start by saying it's my observation that when it comes to training and endorsements, the FAA agrees with Dr. Catherine Ryan: "If it isn't written down, it didn't happen." If you go to FAA Order 8900.1 regarding lost/stolen logbooks, you'll see that while they have ways to document flight time and experience if you lose your logs, they do not say anything about endorsements for which there is no remaining record.

Now, to specifics...

So, given this situation: Are you not able to fly as PIC?

Let's start with the relevant portion of the rule:

Sec. 61.56

Flight review.
...
(c) Except as provided in paragraphs (d), (e), and (g) of this section, no person may act as pilot in command of an aircraft unless, since the beginning of the 24th calendar month before the month in which that pilot acts as pilot in command, that person has--
...(2) A logbook endorsed from an authorized instructor who gave the review certifying that the person has satisfactorily completed the review.

As written, you aren't legal until you have the endorsement in your logbook and the logbook in your possession (but not necessarily personal possession). If you didn't paste that sticker in, plain reading says you aren't legal, even if you keep the sticker somewhere, no less lose it. For that reason, if I lost that sticker before getting it into my logbook (which could occur only in the time it takes for me to get back to my logbook), I'd be right back to get a new sticker. Also, the instructor involved is required by 61.189(a) to sign your logbook for the training given as part of the flight review. If you don't have your logbook there at that time, how does that get done? Or do you get a second sticker for that flight's line in your logbook?

I suspect that this would only become relevant in the case of an accident/inspector's demand for the logbook - in which case you would have time to get your logbook into shape before presenting it.

Usually, but if you happen to have your logbook with you when the demand is made, you can't refuse to hand it over on the spot.

Is it _overly_ risky to fly as PIC?

That's a question of your own personal risk tolerance.

I realize that this isn't the best way to handle logging, but given this situation, what do you think?

I think the best choice is to forestall the situation by having your logbook with you when you get a flight review so the instructor can sign it for the training given and enter the endorsement in the back. If you go on the sticker basis, and lose the sticker before you get it to your logbook, you should immediately get another sticker from that instructor. If that instructor isn't available, you should get a new endorsement from another instructor before you reach the point where you have to rely on the lost endorsement to be legal.

BTW, it's a violation against the instructor to give you official training without signing your logbook. As an instructor, I always make sure my trainees know they must have their logbook with them for me to sign upon completion of the training. If the instructor plays by this rule, then there should be no problems later with lost stickers.

 

[sba55]

BTW, it's a violation against the instructor to give you official training without signing your logbook. As an instructor, I always make sure my trainees know they must have their logbook with them for me to sign upon completion of the training. If the instructor plays by this rule, then there should be no problems later with lost stickers.

Great, thanks Ron. I hadn't though about most of what you wrote, and didn't know this particular fact.

 

[gismo]

Now, to specifics...Let's start with the relevant portion of the rule:
As written, you aren't legal until you have the endorsement in your logbook and the logbook in your possession (but not necessarily personal possession). If you didn't paste that sticker in, plain reading says you aren't legal, even if you keep the sticker somewhere...

I'm finding this difficult to swallow. I know of nothing that says my logs must be in a specific format, contained in one book or located in one place and I don't see any legal difference between temporarily considering the sticker as the start of a new log until it get's added to an existing one with room for it. Also, given that endorsements in logbooks are often located at the end, there seems to be no need for log entries (especially endosements) to be kept in chronological order.

For that reason, if I lost that sticker before getting it into my logbook (which could occur only in the time it takes for me to get back to my logbook), I'd be right back to get a new sticker. Also, the instructor involved is required by 61.189(a) to sign your logbook for the training given as part of the flight review. If you don't have your logbook there at that time, how does that get done? Or do you get a second sticker for that flight's line in your logbook?

Isn't the signature on the sticker good for both as long as the required language is included?

 

[poadeleted20]

I'm finding this difficult to swallow. I know of nothing that says my logs must be in a specific format, contained in one book or located in one place and I don't see any legal difference between temporarily considering the sticker as the start of a new log until it get's added to an existing one with room for it. Also, given that endorsements in logbooks are often located at the end, there seems to be no need for log entries (especially endosements) to be kept in chronological order.


Isn't the signature on the sticker good for both as long as the required language is included?

The sticker is useless if you don't have it any more, and that was the issue under discussion. As for the issue of signing the log for training, I suppose that if the sticker includes all the data required by 61.51 (including flight and ground training data) and the instructor's signature as well as the 61.56 flight review endorsement, I see no reason that couldn't do for the 61.51 side of the issue -- as long as you have the sticker and present it as part of whatever you call your "logbook" when demanded.

But it's no good if you can't produce it, and I can't see the FAA accepting the endorsement signature in the back of the log as being valid to cover a date/time/hours/etc entry in the middle of the log. Remember that a flight review may be accomplished over several days or even weeks, and the standard endorsement only shows when it was completed. See AC 61-65:

55. Completion of a flight review: section 61.56(a) and (c).​

[FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT][FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT]

I certify that (​

[/FONT]​

[/FONT][FONT=JFILBL+TimesNewRomanPS,Times New Roman PS][FONT=JFILBL+TimesNewRomanPS,Times New Roman PS]First name, MI, Last name[/FONT][/FONT][FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT][FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT]), ([/FONT][/FONT][FONT=JFILBL+TimesNewRomanPS,Times New Roman PS][FONT=JFILBL+TimesNewRomanPS,Times New Roman PS]pilot certificate[/FONT][/FONT][FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT][FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT]), ([/FONT][/FONT][FONT=JFILBL+TimesNewRomanPS,Times New Roman PS][FONT=JFILBL+TimesNewRomanPS,Times New Roman PS]certificate number[/FONT][/FONT][FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT][FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT]), has satisfactorily completed a flight review of section 61.56(a) on ([/FONT][/FONT][FONT=JFILBL+TimesNewRomanPS,Times New Roman PS][FONT=JFILBL+TimesNewRomanPS,Times New Roman PS]date[/FONT][/FONT][FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT][FONT=JFIKGN+TimesNewRomanPSMT,Times New Roman PSMT]). ​

/s/ [date] J. J. Jones 987654321CFI Exp. 12-31-05
[/FONT][/FONT]

...with emphasis added.

BTW, I suppose that if you have an e-log, you can stick it to your hard drive or something like that.:wink2:

 

[Palmpilot]

Let me start by saying it's my observation that when it comes to training and endorsements, the FAA agrees with Dr. Catherine Ryan: "If it isn't written down, it didn't happen."

I take that view with regard to FAA interpretations of their regs.

 

[midlifeflyer]

I'm finding this difficult to swallow. I know of nothing that says my logs must be in a specific format, contained in one book or located in one place and I don't see any legal difference between temporarily considering the sticker as the start of a new log until it get's added to an existing one with room for it.

Ah, the old "flight time on a cocktail napkin" bit

Sure. No problem with your "logbook" being a bunch of scattered napkins, backs of business cards, sticky notes and other bits and pieces collected in a shoebox.

Unless of course, the FAA has reason to check your logbook and you give them the shoebox with a big smile on your face. Then one might, with the best of unintention, end up with finding out what "in a manner unacceptable to the administrator means." Or at best, since most logbook checks are because of an incident under investigation, being treated about about as well as one could reasonably expect to be when handing a box of unfiltered crap to an investigator when you are under investigation of any kind.

Interesting that this subject was brought up. A few years ago I put together a flight review card modeled after one that the FAA once used (http://www.thecfi.com/frCertificate.pdf). I got a call just last week about it from a CFI in Alaska who was asking about it legality. My answer to him now was the same as in the letter in the pdf with the form: it's not official and it doesn't substitute for a logbook endorsement.

 

[jason]

I would suspect that the same applies to other types of currency as well. For instance, if you can't prove that you've flown in the last 90 days, then how can you prove that you're legal to carry passengers? If you can't show instrument currency, how can you be legal to fly IFR? Etc....

 

[Everskyward]

I'm finding this difficult to swallow. I know of nothing that says my logs must be in a specific format, contained in one book or located in one place and I don't see any legal difference between temporarily considering the sticker as the start of a new log until it get's added to an existing one with room for it. Also, given that endorsements in logbooks are often located at the end, there seems to be no need for log entries (especially endosements) to be kept in chronological order.

I agree. In all the times I have gone to sim training for both initial and recurrent I have never taken a logbook let alone had one signed. In thinking about it I've never seen any other customer with a logbook either. The Part 135 customers get 8410 forms and the Part 91 customers get stickers.

 

[poadeleted20]

BTW, my comment about "if it isn't written down, it didn't happen" isn't absolute. The FAA will not accept the fact that you didn't log a flight where something went wrong as proof that it wasn't you flying the plane that crashed/broke the rules.