Log Book Entry Required For EAA Auto Fuel STC?

[CBogle]

Dear Fellow Cessna 170 Members:

According to the EAA Auto Fuel STC that I have for my 170, they list, in addition to others, the following two requirements:

4. The aircraft must be inspected by your IA for compliance with the Supplemental Type Certificate, and an appropriate entry must be made in the aircraft log and engine log.

5. Two FAA 337 forms, one for the aircraft and one for the engine, must be completed and submitted to the FAA by an IA Mechanic, since the FAA considers this change a major modification of the aircraft and engine.

My IA submitted the following two 337's.

The first is for a powerplant modification stating the following; "Modified Continental engine to operate on unleaded automotive gasoline as per STC no. SE693GL from the EAA Aviation Founcation, Inc."

The second is for an airframe modification stating the following: "Modified airplane to fly on unleaded automotive gasoline as per STC no. SA762GL from the EAA Aviation Foundation, inc."

My first question is, although it appears that the IA complied with the requirements for a 337 on both the powerplant and airframe, why do the STC's have different numbers? Does the EAA issue different numbers for the powerpland versus the airframe?

Also, my IA made no logbook entry in either the aircraft log or the powerplant log for this auto fuel STC. Does this mean that the aircraft is not yet legal to fly on auto fuel until I get the IA to sign the log books? If so, this doesn't make sense to me as I have numerous other 337 modifications that have 337's, but no logbook entry, such as P. Ponk landing gear attachment, Bass pull handles, TSO's shoulder harnesses, etc. etc.

In other words, the vast majority of my modifications with 337's for avionics, airframe modifications, etc. have no corresponding engine or airframe logbook entry. Why should the auto STC be any different?

Thanks,

Curt Bogle

[GAHorn]

The reason the two STC's have different numbers is because they are seperate STC's...one for the engine...and one for the airframe.
The 337's are part and parcel of your aircraft's maintenance records, also commonly including the term "logbooks". The declaration made by your IA on the 337's constitute the necessary sign offs. While it would be nice for the seperate logs to also contain references to the work and the 337's (in case the 337's were ever lost they could be replaced from FAA microfiche...but the logs could not)...it sounds as if your airplane is good to go.

[mit]

You should find a log book entry for every modification that has been done. Minor of Major.

The Unleaded STC is 2 separate STC's one for Eng and one for Airframe.

So you have to make an entry in each corresponding log book.

[CBogle]

GA:

Thanks...your assessment that the signed and submitted 337's are in fact a log book entry makes sense. This aircraft has numerous 337's dating back to 1948 submitted by numerous A&P's and IA's and very very few also have a corresponding entry in the aircraft or enging log books (which I have all the way back to the beginning). It can't be that all of the A&P's and IA's were negligent in not making a corresponding log book entry for the 337's that they signed and submitted. A few of these I know personally and have excellent reputations and much experience.

Thanks...I appreciate the education.

Best regards,

Curt

[mit]

The reason the two STC's have different numbers is because they are seperate STC's...one for the engine...and one for the airframe.
The 337's are part and parcel of your aircraft's maintenance records, also commonly including the term "logbooks". The declaration made by your IA on the 337's constitute the necessary sign offs. While it would be nice for the seperate logs to also contain references to the work and the 337's (in case the 337's were ever lost they could be replaced from FAA microfiche...but the logs could not)...it sounds as if your airplane is good to go.

Not wanting to get in a argument but 43.9 is pretty clear that you make a Log book entry and put in a 337. I know it doesn't always get done I may have forgot to do it before, but both should be there.

[GAHorn]

Yeah, Tim, ..I know. But in my opinion, if the 337 copy is included within the aircraft mx records....the rule is complied with. (The actual Form 337 is sent to the feds, and the copy is kept for the aircraft records.) To my knowlege...there's absolutely no law that requires that the mx records of the airplane be a "logbook" or "bound record" or "book". All the rule requires is that a "record" be kept. Most of us use the little paperback or bound books called "logbooks", but the law does not actually require we use those convenient forms. (Pilot logbooks used to also be required for ATP applicants. For example, the rule USED to say that a military pilot applicant for an ATP must present his flight records in a "bound record" ...which everyone knew and accepted was a "logbook". Military pilots looking for ratings based upon their military experience were greatly inconvenienced because the military kept such records in a computer, and provided the pilot with a computer printout...which was a folding, perforated, pleated document...completely UN-bound. It didn't meet the rule requiring a "bound" logbook. A few clever boys simply went to a shoemaker or saddlemaker and had them use their industrial sewing machine to run a sewn seam up one side so the document could meet the "bound" rule! The Feds gave up. The rule no longer uses that wording. Now the rule simply uses the phrase - "record".

Similarly, an aircrafts "maintenance records" also do not actually have to be "bound" into a "book". They just have to be kept. (If anyone can show me something thats CURRENT that says otherwise, I'd sure like to see it so I can correct myself.)

Therefore, in my opinion, the act of keeping a copy of the work performed which was documented on a copy of the Form 337 sent to the FAA... and included in the "records" of the aircraft... meet the rule.

There are two FARs which describe the FORM the records must take. Those applicable FARs never use the word "logbook", and are:

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.

(b) Each holder of an air carrier operating certificate or an operating certificate issued under Part 121 or 135, that is required by its approved operations specifications to provide for a continuous airworthiness maintenance program, shall make a record of the maintenance, preventive maintenance, rebuilding, and alteration, on aircraft, airframes, aircraft engines, propellers, appliances, or component parts which it operates in accordance with the applicable provisions of Part 121 or 135 of this chapter, as appropriate.

(c) This section does not apply to persons performing inspections in accordance with Part 91, 125, §135.411(a)(1), or §135.419 of this chapter.

(d) In addition to the entry required by paragraph (a) of this section, major repairs and major alterations shall be entered on a form, and the form disposed of, in the manner prescribed in appendix B, by the person performing the work.

[Amdt. 43–23, 47 FR 41085, Sept. 16, 1982, as amended by Amdt. 43–37, 66 FR 21066, Apr. 27, 2001; Amdt. 43–39, 69 FR 44863, July 27, 2004]

And:

43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.
(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with Part 91, 123, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:

(1) The type of inspection and a brief description of the extent of the inspection.

(2) The date of the inspection and aircraft total time in service.

(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.

(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”

(5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator.”

(6) For progressive inspections, the following or a similarly worded statement—“I certify that in accordance with a progressive inspection program, a routine inspection of (identify whether aircraft or components) and a detailed inspection of (identify components) were performed and the (aircraft or components) are (approved or disapproved) for return to service.” If disapproved, the entry will further state “and a list of discrepancies and unairworthy items dated (date) has been provided to the aircraft owner or operator.”

(7) If an inspection is conducted under an inspection program provided for in part 91, 123, 125, or §135.411(a)(1), the entry must identify the inspection program, that part of the inspection program accomplished, and contain a statement that the inspection was performed in accordance with the inspections and procedures for that particular program.

(b) Listing of discrepancies and placards. If the person performing any inspection required by part 91 or 125 or §135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicable type certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that persons must give the owner or lessee a signed and dated list of those discrepancies. For those items permitted to be inoperative under §91.213(d)(2) of this chapter, that person shall place a placard, that meets the aircraft's airworthiness certification regulations, on each inoperative instrument and the cockpit control of each item of inoperative equipment, marking it “Inoperative,” and shall add the items to the signed and dated list of discrepancies given to the owner or lessee.

[Amdt. 43–23, 47 FR 41085, Sept. 16, 1982, as amended by Amdt. 43–30, 53 FR 50195, Dec. 13, 1988; Amdt. 43–36, 61 FR 19501, May 1, 1996]

[mit]

There are two FARs which describe the FORM the records must take. Those applicable FARs never use the word "logbook", and are:

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.

SNIPPED

(d) In addition to the entry required by paragraph (a) of this section, major repairs and major alterations shall be entered on a form, and the form disposed of, in the manner prescribed in appendix B, by the person performing the work.
[Amdt. 43–23, 47 FR 41085, Sept. 16, 1982, as amended by Amdt. 43–37, 66 FR 21066, Apr. 27, 2001; Amdt. 43–39, 69 FR 44863, July 27, 2004]

George

It isn't about what type of record you have. It says as clear as any FAR can get, you make an entry and fill in a 337 as per append. B.

I don't care what an owner has for a log book, but there is suppose to be an entry in them and a 337.

and that's they way it is in the IA sudy guide too.

[GAHorn]

I understand your statement I think, Tim. But I'm trying to make a distinction here between the 337 which is submitted to the FAA ("The Form 337") ... and the "Maintenance Record", which is the copy of the document sent to the FAA...which also had an entry, identical in every respect, made upon it.
If OKC got an original, and if the owner has a copy of that original, then the owner has a record of the maintenance that meets the rule, IMHO.

[zero.one.victor]

I don't know how the FAR's spell it out, but I think there should be a coresponding logbook entry for every 337 filed. Just as good practice. 337's and weight & balance sheets have a way of disapearing, if the information was also detailed in a logbook entry it'd sure make things easier for future owners.
My current IA put an AD log in my aircraft recordbook, and lists compliance on them. This is great. BUT, I'd also like him to document specific AD compliance in the logbook entry for the annual, instead of "complied with AD's per AD log in aircraft records". There's only 2 recurring AD's applicable to my ragwing, the seat track AD & the fuel pump scfreen AD.

Eric

[Watkinsnv]

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

[GAHorn]

Not disputing anyone's thoughts here, only adding a follow-on thought.
Eric's last post brought to mind what might be an opportunity to provide additional understanding of the issue.
If the aircraft's "logbooks" are lost or destroyed, and subsequently the airplane "maintenance records" are reconstructed, then the FAA's record will provide a copy of the Form 337 which was submitted following the autogas STC modification. The airplane would still be legal to fly with autogas, of course, despite a new logs failure to document the work.
Here's a related trivia question: If the modified aircraft has catastrophic engine failure and another freshly overhauled O-300-A is purchased and installed,... is it legal for the aircraft to operate on autogas under the previous STC? (Hint: The STC covering the previous engine identified that engine by serial number.)

[S2D]

(The actual Form 337 is sent to the feds, and the copy is kept for the aircraft records.)

Agree with almost everything you say except that part GA. I believe if you read the part on disposition of 337's, you will find out it is just the opposite.

Many other things are done from industry standards, but not required to be done in that exact manner.

[GAHorn]

Well, unless you can elaborate a little, Brian,...perhaps I miss your point.
The rule actually says that both the owner and the FAA get a "copy", but in reality the FAA gets an original, signed document. In fact, I believe current policy requires that the FAA's document signature be in blue ink so that they can identify it as original as opposed to a photocopy.

The actual rule says:
"Appendix B to Part 43—Recording of Major Repairs and Major Alterations
(a) Except as provided in paragraphs (b), (c), and (d) of this appendix, each person performing a major repair or major alteration shall—

(1) Execute FAA Form 337 at least in duplicate;

(2) Give a signed copy of that form to the aircraft owner; and

(3) Forward a copy of that form to the local Flight Standards District Office within 48 hours after the aircraft, airframe, aircraft engine, propeller, or appliance is approved for return to service.

(b) For major repairs made in accordance with a manual or specifications acceptable to the Administrator, a certificated repair station may, in place of the requirements of paragraph (a)—

(1) Use the customer's work order upon which the repair is recorded;

(2) Give the aircraft owner a signed copy of the work order and retain a duplicate copy for at least two years from the date of approval for return to service of the aircraft, airframe, aircraft engine, propeller, or appliance;

(3) Give the aircraft owner a maintenance release signed by an authorized representative of the repair station and incorporating the following information:

(i) Identity of the aircraft, airframe, aircraft engine, propeller or appliance.

(ii) If an aircraft, the make, model, serial number, nationality and registration marks, and location of the repaired area.

(iii) If an airframe, aircraft engine, propeller, or appliance, give the manufacturer's name, name of the part, model, and serial numbers (if any); and

(4) Include the following or a similarly worded statement—

“The aircraft, airframe, aircraft engine, propeller, or appliance identified above was repaired and inspected in accordance with current Regulations of the Federal Aviation Agency and is approved for return to service.

Pertinent details of the repair are on file at this repair station under Order No. ___,

Date ____________________
Signed ____________________

For signature of authorized representative)

Repair station name) (Certificate No.)

____________.”

(Address)
(c) For a major repair or major alteration made by a person authorized in §43.17, the person who performs the major repair or major alteration and the person authorized by §43.17 to approve that work shall execute a FAA Form 337 at least in duplicate. A completed copy of that form shall be—

(1) Given to the aircraft owner; and

(2) Forwarded to the Federal Aviation Administration, Aircraft Registration Branch, Post Office Box 25082, Oklahoma City, Okla. 73125, within 48 hours after the work is inspected.

(d) For extended-range fuel tanks installed within the passenger compartment or a baggage compartment, the person who performs the work and the person authorized to approve the work by §43.7 of this part shall execute an FAA Form 337 in at least triplicate. One (1) copy of the FAA Form 337 shall be placed on board the aircraft as specified in §91.417 of this chapter. The remaining forms shall be distributed as required by paragraph (a)(2) and (3) or (c)(1) and (2) of this paragraph as appropriate.

(Secs. 101, 610, 72 Stat. 737, 780, 49 U.S.C. 1301, 1430)

[Doc. No. 1993, 29 FR 5451, Apr. 23, 1964, as amended by Amdt. 43–10, 33 FR 15989, Oct. 31, 1968; Amdt. 43–29, 52 FR 34101, Sept. 9, 1987; Amdt. 43–31, 54 FR 34330, Aug. 18, 1989]

[zero.one.victor]

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

[S2D]

Well, unless you can elaborate a little, Brian,...perhaps I miss your point.
The rule actually says that both the owner and the FAA get a "copy", but in reality the FAA gets an original, signed document. In fact, I believe current policy requires that the FAA's document signature be in blue ink so that they can identify it as original as opposed to a photocopy.

The actual rule says:
"Appendix B to Part 43—Recording of Major Repairs and Major Alterations
(a) Except as provided in paragraphs (b), (c), and (d) of this appendix, each person performing a major repair or major alteration shall—

(1) Execute FAA Form 337 at least in duplicate;

(2) Give a signed copy of that form to the aircraft owner; and

(3) Forward a copy of that form to the local Flight Standards District Office within 48 hours after the aircraft, airframe, aircraft engine, propeller, or appliance is approved for return to service.




]

Now don't that just beat all!!!
Funny how two different parts of the country interpret the same wording to mean two different things.
An "original " signed copy to the owner and a "copy" (of the copy) to the FAA has always been the norm around here. Been sending the FAA a Copy of the copy for years and thats been ok with them. Course now with the PDF 337 online, I just sign them all.

Notice it says give a signed copy to the owner , but it just says to give a copy to the FAA. You don't really think you could send them an unsigned copy do you, thats why it is interpreted around here to just mean a copy of the original.

But hey, just as long as they all get one, (and keep one for yourself in case the other get lost in the mail) is really all that matters. And within 48 hrs!!!