Verbiage for Annual Condition Inspection

[LSaupe]

What are you guys using for the verbiage on your annual condition inspection sign off? Are you signing off a separate one for the airframe and engine?

EAA shows a general guideline, but as Part 43 doesn't apply to EAB, it seems some modification is required in the statement. Or does Kitfox have a boilerplate statement that should be used here?

https://www.eaa.org/en/eaa/aviation-communities-and-interests/homebuilt-aircraft-and-homebuilt-aircraft-kits/frequently-asked-questions/condition-inspection

Many thanks,

Larry

[ppilotmike]

I basically use what the EAA has with a couple modifications. I certify I have inspected this aircraft in accordance with an annual condition inspection per FAR part 43 app D and found it to be in airworthy/unairworthy condition. Signature, total time, and date. If it is unairworthy I am required to give a list to the owner of the items that make it unairworthy. The owner must then repair those items and include documentation and his signature and this makes it airworthy. Keeping these records is all that is required by the FAA and when repeated they can be discarded. Mike

[jrevens]

Hi Larry,

I have a separate Engine Log Book where I document the details of any work done on the engine, as well as oil and filter changes, compression tests, etc. The Airframe Logbook is where I document my annual condition inspections. The airworthiness of the machine includes the engine, of course, so the annual inspection includes the engine. Any changes, maintenance, repairs or tests I've done specifically to the engine I detail in the Engine Log Book. I only make one entry for the Annual Condition Inspection - in the Airframe Logbook, and I use the following wording -

"I certify that this aircraft has been inspected in accordance with the scope and detail of Appendix D of FAR Part 43, and found to be in safe operating condition." Then I sign my name and my Repairman's Certificate number. Actually, every entry that I make in the Log ends with my signature and number.

I did it for the 27th time on my T-18 this year.

You also want to remember to test your ELT every year, and document that. I have an older unit in the Thorp, and the wording I use for that is-

"ELT tested in accordance with 91.207 (d) (1 through 4), and has passed all tests."

I don't know yet if that's still the proper verbiage for the newer ELTs like I have in the Kitfox.

[LSaupe]

Thanks guys.

[PapuaPilot]

I do mine very similar to John's stating, "I certify that this aircraft has been inspected in accordance with the scope and detail of FAR Part 43, Appendix D and was found to be in a condition for safe operation."

I do a separate entry for the airframe and engine.

I would not use the wording that Mike suggests, we cannot use the word "airworthy" in reference to an experimental plane. They are never airworthy according to the FAA's definition found in FAR 3.5:
"Airworthy means the aircraft conforms to its type design and is in a condition for safe operation."
EA-B aircraft do not have a FAA approved type certificate data sheet (type design) to conform to. EA-Bs can only be found in a condition for safe operation, thus the reason the inspection is called a condition inspection.

[efwd]

I'm learning something here Phil. What is it that you get from the FSDO that you must have on board the aircraft when it fly's? I always thought it was an Airworthy certificate?

[PapuaPilot]

Great question, I thought someone was going to bring this up. ;)
Yes, we need to have form 8130-7, which is a Special Airworthiness Certificate, before we can operate our EA-B aircraft.

Here is what FAA.gov says about this document:
"The FAA special airworthiness certificate (FAA Form 8130-7) is an FAA authorization to OPERATE an aircraft in the US airspace . . ."

"A special airworthiness certificate in the experimental category is issued to OPERATE an aircraft that:
- Does not have a type certificate (true for EA-Bs) or does not conform to its type certificate (this only applies to certified aircraft)
- AND is in a condition for safe operation (true for any type aircraft)"

"Additionally, this certificate is issued to OPERATE a primary category kit-built aircraft that was assembled without the supervision and quality control of the production certificate holder."

A Special Airworthiness Certificate does not make or deem an aircraft airworthy. Its purpose to to authorize us to operate the aircraft.

[dcsfoto]

The log entry to use should be in your Limitations attached to your FAA Form 8130-7.

The condition inspection entry in your airframe log covers the entire aircraft.

David Kelm
DARF DART

[PapuaPilot]

Now regarding the term airworthy. When an IA signs off a certified aircraft's annual inspection and makes the statement that it is airworthy they are by definition saying two things:

1. The aircraft conforms to its type design
This is the paperwork part of the inspection. It means the aircraft conforms to the data contained in the Type Certificate Data Sheet (TCDS), or its altered state by Supplemental Type Certificates (STCs), field approvals, applicable Airworthiness Directives have been complied with, etc.

2. And is in a condition for safe operation
This is the actual physical inspection of the aircraft. It has to do with its condition and wear and tear. FAR Part 43, Appendix D can be used as a bare minimum checklist of things inspect.

If a certified plane is found to be perfectly safe for operation, but the propeller is not listed in the TCDS or an STC; the aircraft is not airworthy. But we can put any prop we want on an EA-B aircraft. If it is determined to be in a condition for safe flight we are allowed to fly the plane and the FAA really cannot do anything about it. The responsibility lies on our shoulders.

[PapuaPilot]

Thanks for the reminder David.

I looked at my Operating Limitations and it gives a statement that can be used to sign off the condition inspection. FYI it does not have to be that exact wording. My Operating Limitations says ". . . showing the following, or a similarly worded statement".

[ppilotmike]

Interesting. I have been using that or a similar statement on certified and EAB aircraft since I got my first IA in 1986. Never had a problem but as we all know there is no problem until something goes wrong and the feds get involved. Mike:)

[HighWing]

By now this is a bit redundant, but when N338S was inspected the guy from the FSDO gave me several stickers to put in my log book and fill out on completion of the Annual Condition Inspection. Attached is a copy from the log book.

[beeryboats]

I have worked as a mech under an FBO's station licence. I've never had an A&P, but have even been an inspector. Funny, right? Anyway all that has been on certified aircraft or components. With my IV, I've had to change a few things that the builder didn't do to my liking. But the only components that have been changed are the tires and the prop. I know I'll have to do a weight and balance, but what has to be entered in the log? I have an A&P to look over my work, but should he enter what I did? Tundra tires and Warp drive prop.

[Timberwolf]

Jay, you can put those into the logbook yourself. No need for an A&P to do it. Also annotate that updated weight and balance has been performed and added into the aircraft records.

However, this constitutes a major change with the new prop and will need to be put back into phase 1. The FSDO will give you the operating area for the Phase 1 flight test and probably give you that restriction for 5 hours, after which it will be put in the log book and put back into phase 2. Since the prop type remains the same (fixed pitch) you will not need to file a new 8130-6.

[Slyfox]

I certify that this aircraft has been inspected on _____________ in accordance with the scope and detail of appendix D of part 43 and found to be in a condition for safe operation

I certify that this engine has been inspected on ___________ in accordance with the scope and detail of appendix D of part 43 and found to be in a condition for safe operation


simple and to the point. I do this for both aircraft. I don't even do oil changes unless it's time for it.

[Danzer1]

It sounds to me like Jay purchased the aircraft and may not hold the repairmans certificate. If that is the case he would need an A&P to sign off on any major change or one that could be concieved as affecting weight and balance. Correct me if I'm wrong? It wouldn't be the 1st time.

Greg

[beeryboats]

It sounds to me like Jay purchased the aircraft and may not hold the repairmans certificate. If that is the case he would need an A&P to sign off on any major change or one that could be concieved as affecting weight and balance. Correct me if I'm wrong? It wouldn't be the 1st time.

Greg

You are correct. Even though I've worked as one for years, it has always been under a station license.

[beeryboats]

Jay, you can put those into the logbook yourself. No need for an A&P to do it. Also annotate that updated weight and balance has been performed and added into the aircraft records.

However, this constitutes a major change with the new prop and will need to be put back into phase 1. The FSDO will give you the operating area for the Phase 1 flight test and probably give you that restriction for 5 hours, after which it will be put in the log book and put back into phase 2. Since the prop type remains the same (fixed pitch) you will not need to file a new 8130-6.

I find it hard to believe that a prop change puts you back to phase 1 test flight again.

[Timberwolf]

It sounds to me like Jay purchased the aircraft and may not hold the repairmans certificate. If that is the case he would need an A&P to sign off on any major change or one that could be concieved as affecting weight and balance. Correct me if I'm wrong? It wouldn't be the 1st time.

Greg

Greg good point. Thanks. However, technically the only logbook entries required for experimental aircraft are those for a conditional inspection....and personally I would also say anything required under 91.417, transponder, ELT, etc. It would be smart to document such a change in my opinion.

Jay, 14 CFR 21.93 dictates a major change...same for certified and experimental. Major change dictates it goes back to phase 1. I would personally draft up a plan and take it to the FSDO and tell them what you are going to do and they will most likely give you the thumbs up. If you have the original operating limitations I would also get them updated while you are at the FSDO. Sometime early in 2000, the ops limits were changed to add the sentence; "After the satisfactory completion of phase I, and the appropriate endorsement has been entered in the aircraft logbook, this aircraft may be flown in congested airways and over densely populated areas if directed by Air Traffic Control or sufficient altitude is maintained to effect a safe emergency landing in the event of a power unit failure, without hazard to persons or property on the surface."

[Danzer1]

Greg good point. Thanks. However, technically the only logbook entries required for experimental aircraft are those for a conditional inspection....and personally I would also say anything required under 91.417, transponder, ELT, etc. It would be smart to document such a change in my opinion.

Does not 91.417 apply to experimental aircraft as well?

"(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service."

It does include the wording "alteration". Again correct me if I'm wrong here!

Greg

[Timberwolf]

I would argue they absolutely do not apply unless specifically referenced or in reference to a part that is required under the FAR's such as the ELT, transponder or IFR cert. Part 43.1(b) defines what the regulations are regarding mx and records required, however it also states that this does not apply to any aircraft with an experimental certificate. There is no strict guidance what to put outside of what the operating limitations state for your aircraft.


For what you referenced it is applicable to certified aircraft only
....A description (or reference to data acceptable to the Administrator) of the work performed...

This would refer to a 337 or compliance with the aircraft mx manuals to ensure continued airworthiness. Nothing done to an experimental gets sent to or has to be proven to the administrator and no acceptable data is required to make any modification to an E-AB aircraft (negating those systems/inspections already discussed above). There is also no requirement for anyone to make any entry returning an experimental aircraft to service.

I'm not 100% sure on this part, but I've never seen an experimental on a progressive inspection, nor an annual (a conditional is different, though still every 12 calendar months)...the only one I could see is a 100 hour if you have the proper waivers to use it for flight training....but again not 100% on this.



At the end of the day, I will log all of my work done and date, sign, and put my A&P number at the end just because good record keeping never hurt in maintaining an aircraft.

[Danzer1]

Not going to get into an argument. This has been hashed over many times. There is no exemption from 91.417 for EAB.

91 specifically states "(a) This subpart prescribes rules governing the maintenance, preventive maintenance, and alterations of U.S.-registered civil aircraft operating within or outside of the United States."

No exception! You seem to be picking parts that obviously do not apply and the reg covers that to as it states "and other required or approved inspections, as appropriate, for each aircraft". So no - progressive & 100 hour do not apply.


There is no strict guidance what to put outside of what the operating limitations state for your aircraft.

Using that logic the operationg limitations need to reiterate the entirety of 14 CFR in order to be applicable. The guidance is the reg and the one that pertains here is 91.417

I'm not saying it has to be in a log book. I'm not saying the work has to be performed by an A&P. I'm not saying the work has to be signed off by an A&P. I'm saying 91.417 requires there to be a records of maintenance and alterations.

[Av8r3400]

After my thurough rebuild of the Mangy, the FISDO didn't care about anything but the changed Propellar. I had to put 5 hours of phase 1 testing in and with a log entry was back to normal operations.

Another one of the reasons why I chose not to build my airplane "from parts".

[Timberwolf]

Makes sense, thanks Greg

[beeryboats]

Jay, you can put those into the logbook yourself. No need for an A&P to do it. Also annotate that updated weight and balance has been performed and added into the aircraft records.

However, this constitutes a major change with the new prop and will need to be put back into phase 1. The FSDO will give you the operating area for the Phase 1 flight test and probably give you that restriction for 5 hours, after which it will be put in the log book and put back into phase 2. Since the prop type remains the same (fixed pitch) you will not need to file a new 8130-6.

Once again I seemed to have stirred the pot a bit. Sorry. My original question on log book entry detail is this. Do I just enter, "brake system overhauled" or should I enter "calipers cleaned and resealed, pads replaced, poly brake lines replaced, master cylinders cleaned and resealed, and both sides bled"? If the later detail is required, I'll need another log just cover what I've done.

As for the prop change, with a fresh reman two stroke engine I better be within gliding range of home anyway. At least for five hours...

[Danzer1]

Jay,

The verbiage is really up to you. Consider though, if you ever plan on selling it - most would consider the more in depth descriptions as more desirable. Leaves less to speculate about - "overhauled" could have different meanings to different people.

Greg