Log Book Entry Required For EAA Auto Fuel STC?

[S2D]

Just a side note on log book entries. An annual inspection need only be signed off in the airframe log book. It is the aircraft being annualed not the engine. But it has been done that way for so long that owners expect it now. Along with a new AD list and an entry in the prop log. Lance

The IA I've been doing my annuals wioth for the last couple years pointed this out to me. He signs off an annual inspection in the airframe logs, and a 100-hour inspection in the engine logs. At first I thought he'd screwed up, until he explained it to me.

Eric

Really don't even have to sign off a 100 hr on the engine either, just sign off work done on it and times etc. (ditto the prop) When you sign the annual in the airframe log, you are certifying you inspected everything on the aircraft and found it all to be in airworthy condition.( or list all the discrpancies you found but didn't fix)

[Indopilot]

Here is one to stir the pot.
At one of my IA seminars it was pointed out that you only had to keep the current copy of maintenance performed ie annual sign off etc, until it was redone. At that point you could legally throw the previous record away and go with the new current maintenance entry. I forget the chapter and verse they quoted, but it sure would lighten the A/C log book folder.

[GAHorn]

Here is one to stir the pot.
At one of my IA seminars it was pointed out that you only had to keep the current copy of maintenance performed ie annual sign off etc, until it was redone. At that point you could legally throw the previous record away and go with the new current maintenance entry. I forget the chapter and verse they quoted, but it sure would lighten the A/C log book folder.

Ha! Yeah, and it would sure lighten the seller's wallet when the time to get rid of it came 'round! (Of course, it'd also probably reduce the amount of fiction in the industry also.)

[Dave Clark]

Here is one to stir the pot.
At one of my IA seminars it was pointed out that you only had to keep the current copy of maintenance performed ie annual sign off etc, until it was redone. At that point you could legally throw the previous record away and go with the new current maintenance entry. I forget the chapter and verse they quoted, but it sure would lighten the A/C log book folder.

I have mine on a Progressive Inspection Program. Unlike prior aircraft I've had on a Progressive this one is set up with a sign-off right on each of the four quarterly inspection forms and of course I never sign an "Annual". I still log all repair and maintenance work done in the appropriate logbooks as well as ELT dates, Pitot Static Dates etc. It sure cleans up the logbooks.

I've looked at airplanes for sale where there was a whole slug of Annual sign offs but not much of anything else or any record of any work done at the annual. Now that's a bit suspicious I'd say.

[kimble]

Gentlemen,

Forget the letter of the Law? Not necessarily, but Good bookeeping pratices should prevail within the letter of the law. The log book entry and the 337 tied together.

Example:
I maintained a PA-36 for a period of ten years or better. In that time there had been numerious 337s. Well into the maintenance period, I decided to obtain a CD record of the 337s on file in OKC. Good, except four 337s were not recorded in the OKC files. Sorry to say but the FAA also makes mistakes. The concept of the whole process should be to eleminate all possible error, whether it be IA, owner or FAA.

When I file a 337, I make three signed originals, one for me, one for the owner and one for the FAA. I also make a log book entry indicating the work accomplished, completion of any 337s and any other data I think necessary for tracibility purposes.

Records get lost, IA, AP, FAA and owners make mistakes.
After all, who is responsible for the keeping the 337 records?
Do you think most owners ever look at the 337 records or even knows it is their responsibility to keep those records?
I never cease to be amazed at the records the owner presents at time of an annual. The 337 records are very seldom complete. Some time back, I had an aircarft to annual, competely devoid of 337 records and "no damage history." I had to admit the damage was hard to detect, but it had been repaired and no paper work.

Gentlemen, do as you please, but for me and my house, we will worship maintaining the most cohesive records possible. Legalistic is important, but traceable and cross referenced records are of paramount importance.

Remember the "Continued Airworthiness" statement required in the 337s. Because of this, good 337 records are a necessity.

Sorry to be so long winded, I am off my soap box. :l

Ralph

[Dave Clark]

Gentlemen,

Forget the letter of the Law? Not necessarily, but Good bookkeeping pratices should prevail within the letter of the law. The log book entry and the 337 tied together.

Example:
I maintained a PA-36 for a period of ten years or better. In that time there had been numerous 337s. Well into the maintenance period, I decided to obtain a CD record of the 337s on file in OKC. Good, except four 337s were not recorded in the OKC files. Sorry to say but the FAA also makes mistakes. The concept of the whole process should be to eleminate all possible error, whether it be IA, owner or FAA.

When I file a 337, I make three signed originals, one for me, one for the owner and one for the FAA. I also make a log book entry indicating the work accomplished, completion of any 337s and any other data I think necessary for tracibility purposes.

Records get lost, IA, AP, FAA and owners make mistakes.
After all, who is responsible for the keeping the 337 records?
Do you think most owners ever look at the 337 records or even knows it is their responsibility to keep those records?
I never cease to be amazed at the records the owner presents at time of an annual. The 337 records are very seldom complete. Some time back, I had an aircarft to annual, competely devoid of 337 records and "no damage history." I had to admit the damage was hard to detect, but it had been repaired and no paper work.

Gentlemen, do as you please, but for me and my house, we will worship maintaining the most cohesive records possible. Legalistic is important, but traceable and cross referenced records are of paramount importance.

Remember the "Continued Airworthiness" statement required in the 337s. Because of this, good 337 records are a necessity.

Sorry to be so long winded, I am off my soap box. :l

Ralph

In case anyone misinterpreted my post I agree Ralph, and well said. Many people don't know this but there are more than a few mechanics who never send the 337 in to the FAA in order to try to protect themselves from liability or some other crazy reason. For the small cost to get the FAA records I would encourage all owners to do so and review them with the logs and other records.

[bradbrady]

Hi everone,

as for the legalities of 337 and log book sign offs (thats become moot here) it's just common curtisy to sign the logs that a 337 has been met. we all try to keep the logs together but the 337's sometimes get lost (because they are seperate). and only have to be kept for two years (the feds keep them forever). so if you have a log book sign off you can go to the feds and get a copy. the STC,s for an auto fuel sign off are serial number spicific so that 337 stayes with that airframe or engine for the life of that 337 (not nessaraly the life of the airframe or engine) something could be changed on either to negate the SCT which also negates the viability of the 337. just needed to vent thanks for reading.
brad

[GAHorn]

Good comments Ralph. And Dave, you point out a possibility which actually supports my original thought on the matter, and which Brad alluded to with a slight error.
The 337s that are "kept" by repair stations are only kept for a period of time and may be disposed of after that time. (I've seen guidance that read either 2. 3, or 7 years...take your pick, but the point is that a CRS doesn't keep them forever and if you own an airplane with old work done under a 337 that work-place probably no longer has a copy.)
The FAA may have a copy. Tha'ts because they either lost it, misplaced it (perhaps under the records of a different airplane which once had your tail number, etc.) or a IA never submitted it or the USPS lost it.
I once had a 206 which had an IO-520-D engine installed quite illegally. I also hated it's instrument panel. So I hired an AP/IA to take care of both. He altered the engine to a -A via TCM Service Bulletin, and he mfr'd an entirely new and re-designed instrument panel. He gave me copies of Form 337's to support both work. He supposedly submitted copies to the FAA. Presumeably in the same envelope on the same day.
Several years later I discovered the FAA had only a copy of the engine conversion. It seems my mechanic never submitted the instrument panel work because it was a major alteration that he didn't wish to present to the FAA for field approval or STC. So he simply gave ME a copy to make me happy and trashed the one for the FAA.
It came back to bite him. My copy of that 337 was my maintenance record for the aircraft. For that reason the aircraft owner's copy of any Form 337, which is a record of work performed on that aircraft, should be kept with the aircraft records - permanently. It supplied the evidence* to satisfy the FAA that my inst. panel was indeed not something I did in my garage in my spare time, but was actually the work product of that "mechanic"... who was reprimanded by the FAA.

Personally, I keep the log entry, the 337, and the Invoices for the work perfomed, forever. Makes it a lot easier to support my valuation of the aircraft to the insurance company and any buyer.

*- The "logbook" entry on that aircraft stated "Removed/Replaced instrument panel." The only document I had which showed the extent of the work was that 337. On a subsequent annual inspection the inspector questioned that panel work, largely because Block 3 of the 337 was not signed by the FAA. He refused to approve the aircraft for return-to-service and with my permission contacted the FAA. They were not happy...until the guy who made my panel and tried to deceive me and the FAA was not happy. He surrendered his Inspection Authority for two years to avoid fines.
Keep 337s. They are a part of your aircraft's maintenance record.

[Dave Clark]

Yep George, that's exactly the thing I was talking about. I was a victim of a similar case of a mechanic intentionally not filing the 337. I can't remember a 337 that I've filed without making a log entry. But I've also been hurt by lost or discarded records from a CRS so I highly recommend if an owner uses a CRS or the like that he gets a copy of the paperwork. Mine was an engine that I didn't have the CRS paperwork for an overhaul and couldn't document a certain internal part that came under a new AD.

I don't think the average plane has that many 337's where it would become too bulky to keep them all. I use a cloth covered 3 ring binder that zips up, you know the style. I've got each 337 and the associated paperwork in those clear inserts. I could probably weed out a bit of the "associated" paper but even with the numerous mods on my plane it all fits just fine.

[bradbrady]

george and dave,
Hey thanks for reading, George I was talking about perfect sign off's and we all know that there is APIA'S out there that don't work in the mainstream thats to bad. but when things are done right you can find anything I'm working on a C-140 that has 24 337's and I can document all but one (unbelivable good paper work) so Dave some airplanes do have a mulitude of 337's (not chastizing you, but they are out there) now here's the rub, the prop was changed from the original STC from a 1A100 to a 1A101 prop with the same twist, and in the paper work is a letter stating that the FSDO at the time had no problem with the prop change but that the STC would need to be updated, I can't that info. And one of my principals at my FSDO was singing this aircraft off as meeting an annual inspection for several years before I started to work on it (actualy several years before I was an AP) Dave what would you do?

[Dave Clark]

Punt

I'm not sure I understand but I think you're saying the original prop change was done on an STC. I don't think you can update the STC unless it's your STC, like if it was a one time one and belonged to the airplane owner. So if you can't update the STC you might get it done on a field approval following the new procedure and presenting the letter from the FSDO you mentioned. But my first step would be to call the FSDO and talk to my PMI and outline the problem to him and ask what should be done because he's the one you have to satisfy.

This stuff can really be a puzzle. Somewhere, probably on this forum just before Christmas there was a thread advising people to check their aircraft registration (on line) as to accuracy and I did. It did not show my Lycoming 180hp engine so I e-mailed the FAA registration people and asked what to do. Their reply was "Submit a letter from a Flight Standards District Office Inspector or an
Application for Airworthiness which shows the O-360-A1A 180hp. The only
Applications for Airworthiness on file shows the engine as a C-145."

So like the anal good boy I am I submitted a new airworthiness application to my PMI Scottsdale FSDO. A week later I was asked to correct an error on the application and I did. Four weeks later, today, I got an answer back basically saying " Since the STC you installed did not require you to install a separate data plate on the aircraft, you did not change the basic model designation of the Cessna 170B serial number 20870. The 337/STC is the approved data for the installation of a different engine on your aircraft." Now I am confused My application was not top change the basic model designation but to only change the engine shown on the registration like the registration office suggested. I'm calling him tomorrow.

Man I'd hate to be making a living this way.

[GAHorn]

Dave, I believe the situation is, ...that current registrations are necessary because the FAA has recently decided to deny access to ATC services if registrations (owner/address info) is not up to date. We had until Feb 1 to correct registration owner/address records and avoid denial of service. (In other words...get ready everybody...the administration plans to make ATC a profit center for their buddies and privatize ATC. It's only a matter of time and we'll be paying user fees to fly around in the newly privatized airspace. They need accurate info in order to invoice us and deny service to those in arrears. The present excuse is for security reasons. Of course, foreign registered aircraft do not have to comply, however. ... Right. ... Security.)
Registration has nothing to do with your Airworthiness Certificate, which was issued under the type design/type certificate. Your STC'd engine-change altered your aircraft's basic type design....not it's registration. (FAA registration info indicates the original type design of your aircraft, and the current registered owner...not airworthiness.)

[Dave Clark]

(FAA registration info indicates the original type design of your aircraft, and the current registered owner...not airworthiness.)

OK, put that way I'll buy that. Why didn't he just say that a few months ago? Gotta call him today anyway to follow up on my dual puck field approval. Parts are here.

[bradbrady]

Dave,
I reread what I sent in and can see where you have issues with my wrighting, The aircraft in question was upgraded ? from the C-85 to the O-200A with the 1A100 prop specified on the STC then changed to the 1A101 prop by the same STC holders (all this was done between 1962 and 1968) and apparently the letter I talked about has surficed to meet prop change (until I got my anal hands on it) I have checked and found other STC's with the O-200 and the 1A101 prop for C-140's. So documintation is no problem. I was thinking the same way as you, (using a field approval) Just to cover my butt. Before I do anything, I will call my PMI and see what he wants. It's just good to hear from people I trust like you before I do anything, thanks
brad