Keeping your aircraft maintenance records complete and up to date is critical to providing good quality and regulatory-compliant aircraft for rental and training. Failure to do so can mean your customers will have trouble completing checkrides and, in some cases, certificate action against the pilot and/or the owner/operator of the aircraft. Don’t think it can come to that? Who would know anyway? As an FAA examiner, I have encountered exactly this situation.
I arrived at a scheduled practical test to find that the aircraft had no records of airworthiness directives (AD) compliance or if there were any recurring ADs that needed to be tracked. This alone was a stopping point for a practical test. As an examiner, I am required to verify that the aircraft used for the practical test complies with FAA maintenance requirements to proceed. Not a terrible thing, just a delay, right? In this case, it got worse.
As I looked at the maintenance logbooks in more detail, I noticed that the last two 100-hour inspections times were listed in Hobbs time (not the typical tach time that “runs a little slower”) and totaled 147 and 143 hours respectively between inspections.
According to FAA regulations, an aircraft that is being rented is required to have 100-hour inspections that are, well, no more than 100 hours apart. Sure, there is a 10-hour overage allowed if the aircraft is being flown back to the maintenance location, but 10 is very different than 47 and 43 hours over. There definitely was a problem.
The instructor and the aircraft owner were nowhere to be found, so the applicant was left there hanging on his own. He didn’t get a test that day.
I called the flight school operator who also owned the aircraft, and he assured me that it was just a mistake—the times should have been written in tach time and when he got the corrected numbers in there it would all be OK. I went home, giving him the homework to correct the discrepancies.
About halfway home, I got a call from the owner stating that the correct numbers using tach time put the inspections at an improved 123 and 119 hours apart. I informed him that this was still well over the FAA requirements. He said he would get back to me.
Here is where it went from bad to worse for the applicant and the operator.
FAA examiners are required to provide their practical test schedule to their local FAA office. When a checkride is not completed on a day when the weather is good and there are no obvious reasons why it would be scratched, the local FAA inspector might give the examiner a call to inquire as to why the checkride didn’t take place. That’s exactly what happened in this case. I briefly told the inspector what I had observed regarding the logbooks and the 100-hour inspections and indicated that I told the operator that we couldn’t proceed with a checkride until the issues had been resolved.
This triggered some extra FAA attention to the flight training operator. Several aircraft were grounded for noncompliance, and its customers were unable to continue training at least for a short period of time.
A month later, I rescheduled the test because the operator had indicated that all the paperwork was in order and we could proceed.
Remember, the FAA knows the examiner’s schedule of tests. When I arrived to do the test again, we were joined by staff from our local FAA office who also was there to see if the paperwork was in order. Let’s just say it wasn’t.
We now found an annual inspection that was done to remedy the overflown 100-hour inspection issue (an annual inspection can reset a 100-hour inspection time). When I first went to do the checkride, there were 100-hour inspections listed for June 30 and July 27, but somehow when we returned on August 30, an annual inspection had suddenly appeared from July 30 that wasn’t there on my first visit. I know I am not crazy and didn’t just miss it, because I had pictures of the logbook pages from my previous visit.
At the point, we were skeptical. First, what airframe and powerplant technician worth his salt does an annual inspection on the last day or two of the month? Most I know will do it so they can sign off on the first of the month and get the extra month of inspection currency going forward. Second, as I dug into the aircraft use log (it was on a clipboard used with the dispatch form) I could see that the aircraft had flown with renters July 28, 29, and 30.
Hmm. How was an annual inspection being done if the aircraft was flown on those days? Third, if the annual inspection was completed on July 30, why wasn’t it in the logbook when I first saw the entries on August 3?
Again, the applicant was there all alone, no instructor, no flight training provider/aircraft owner to help. Again, a call was made to the flight training provider/aircraft owner—this time by the FAA staff—and no test was given. Over the next month the operator had a lot of interaction with the FAA office to make the aircraft compliant for rental (and practical tests) again.
We were finally able to complete the test for the applicant 66 days after it was originally scheduled. In the meantime, the applicant spent time and money staying current and not getting the test done, all because proper maintenance records were not being recorded.
Let’s put this in context of how it affects a business providing aircraft rental or flight training. The result was a significantly delayed customer who, with good reason, was rather disgruntled with the operation from which he was renting the aircraft not being able to provide a compliant aircraft. Another result was that the local FAA office now had little confidence in the flight school operator, resulting in more oversight than most operators would ideally want.
Fortunately for this business, the customer didn’t just go find a different operator from which to receive training and rent an aircraft, but it wouldn’t be hard to imagine a customer doing so in this case.
The FAA typically works with individuals to become compliant when a discrepancy is identified, but it does not mean that the agency never issues a violation if it is necessary. When errors or omissions become common, negligent, or even willful, the FAA is forced to act appropriately for the safety of the public.
So who could be at fault in a situation like this? Well, pretty much everyone, including me if I hadn’t caught it and allowed the test to proceed.
A commercial provider of aircraft as the owner/operator must make sure it has provided an aircraft that is in compliance. It is the mechanic’s responsibility if he has signed off an aircraft (either for an annual inspection or a 100-hour inspection) to ensure that all areas of compliance were met. Additionally, the pilots are required to ensure that the aircraft they plan to fly meets all requirements to be legally operated. So, the owner who provided an unairworthy aircraft, a mechanic who signed off an unairworthy aircraft, and a pilot who flies an unairworthy aircraft are all potentially subject to FAA action.
It’s not only bad business for flight schools to allow aircraft to be flown without proper maintenance records, but it could also result in FAA action, nullification of insurance coverage, or even civil or criminal ramifications if an accident occurs.
Getting the maintenance records correct can be tedious and time consuming for any operator, but it is a critical part of providing a compliant aircraft for business. Take the time as an operator to get it right. Make sure your instructors understand the maintenance requirements and explain them as well as demonstrate them to your customers before checkride day. If your staff and customers understand what should be there, and are actively looking on a regular basis at aircraft maintenance logs, they will even be an additional check.