Inaccurate logbook entries

[Dalmatian]

My apologies if I am asking questions that have been covered elsewhere – when searching the forums I found this thread http://www.pprune.org/dg-p-general-aviation-questions/376633-log-book-forgery.html , but I was looking for more specific information that did not seem to be answered there, and am hoping more clever and wiser minds than mine can answer some questions.
My questions are about log book fraud/ false entries/’massaging’ of flight time in Australia.
I have been told that some slight adjustment of figures is common, especially amongst low hour pilots (e.g. adding an additional 0.1 to some flights).
Is this actually common practice?
If so, at what point do you ppruners think this becomes excessive/fraudulent?( Is 0.1 on some flights allowable? Is 0.1, 0.2, 0.3, or 0.4 too much for a flight? Is any ‘adjustment’ just plain fraudulent?)
According to the CASA website : Civil Aviation Safety Authority - Pilot Log Books (http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_90100) , falsification of flight time is a criminal offence. CAR 5.51 has a note saying “Note It is an offence against regulation 283 for a person to make a false or misleading statement in his or her personal log book , but CAR 283 doesn’t exist – it seems to have dropped out of the Regulations sometime in the last 10 years or so.
For current legislation:
CAR 5.51 http://www.comlaw.gov.au/ComLaw/Legislation/LegislativeInstrumentCompilation1.nsf/0/BCCE65FD1D68B4B5CA257737000C6D13/$file/CivilAviation1988Vol2.pdf
CAR 282 - 286 http://www.comlaw.gov.au/comlaw/Legislation/LegislativeInstrumentCompilation1.nsf/0/68D1FC51BC8E183CCA257737000C6DB4/$file/CivilAviation1988Vol3.pdf

So if CASA do take regulatory action against a pilot, under what laws/parts of law are they acting?
What evidence is required to prove suspected logbook fraud? Is exaggeration of flight hours the same as falsification?
If you are made aware that someone is currently, or has in the past been exaggerating flight time in their log book what are your legal obligations?
Are there any implications for an organizations Chief Pilot if they are aware that a pilot employed in their organization has inflated flight time in the past? If they continue to do so while employed by the organization as a pilot?
What are the insurance implications for the organization if they allow that pilot to use their aircraft, knowing that there may be false or inflated flight time?
Would you employ a pilot if you had suspicions about the accuracy of their log book? Does this reflect on their general integrity, would this person be a risk of breaches of professionalism in other aspects of their flying, or is it a common enough occurance to be allowable under some circumstances with careful monitoring?
Your comments and advice are appreciated.
Cheers,
Spotty Dog

[tail wheel]

CIVIL AVIATION REGULATIONS 1988 - REG 5.52
What must be recorded in a personal log book?
(1) The holder of a flight crew licence, a special pilot licence or a certificate of validation must record in his or her personal log book:

(a) the holder's full name, address, date of birth and aviation reference number; and

(b) any information about each flight undertaken by the holder that CASA directs be recorded in the log book; and

(c) the time spent by the holder practising simulated flight in an approved synthetic flight trainer.

Penalty: 10 penalty units.

Note : It is an offence against regulation 283 for a person to make a false or misleading statement in his or her personal log book.

(2) CASA may give directions in Civil Aviation Orders setting out the information about each flight undertaken by the holder of a flight crew licence, a special pilot licence or a certificate of validation that the holder must record in his or her personal log book.

(3) CASA must not give a direction under subregulation (2) unless it is necessary to do so in the interests of the safety of air navigation.

(4) A person must not contravene a direction under subregulation (2).

Penalty: 10 penalty units.

(5) A direction does not have effect in relation to a person until it is given to the person.

(5A) An offence against subregulation (1) or (4) is an offence of strict liability.

Note For strict liability , see section 6.1 of the Criminal Code .

(6) In this regulation:

"aviation reference number" means the number given to the holder of a flight crew licence, a special pilot licence or a certificate of validation by CASA when his or her first licence or certificate is issued.

The reference to:

Note : It is an offence against regulation 283 for a person to make a false or misleading statement in his or her personal log book.

Is a reference note only and does not in any way lessen or vary the requirements of CAR5.52. CAR283 has been superceded by provisions of the Crimes Act (Sect 6.1?), although it appears CASA have not "got around" to removing the note from CAR 5.51.

(I doubt anyone in the aviation industry would be surprised the CARs contain an incorrect reference, after all it has only taken 22 years so far for CASA to carry our their review.......)

Intentionally fudging a Log Book by 0.1, 1.0 or 10 hours is fraudulent and an offense under the Crimes Act.

There are no shades of grey. You can't be "a little bit guilty".

If CASA audits a pilot's Log Book they will reconcile pilot's logged hours against the aircraft MR (and/or other flight records) and ASA records.

The accuracy of your Log Book is your personal responsibility. Fudge your Log Book and you will be personally liable.

Don't even think about it. :=

[The Green Goblin]

This is a very interesting topic, and I'm glad you have brought it up (Gillard 2010 :p).

In all seriousness I have seen all sorts of rules of thumb during my time in GA. The first company I worked for it was all logged off the VDO however these have a tendency to run too slow on the ground so some Pilots added extra to the VDO to compensate.

Another company I worked for added 0.1 to each landing and measured flight time as your wheels off wheels on time. In a bungles queue you could wait an extra 20 mins some days to get airborne and it would not be logged, as you only logged 0.1 for all ground time.

This is against the regs as you are technically not logging all your flight time!

Another company added 0.3 per landing which was for IFR or 0.1 a taxi and 0.2 for a run-up.

In the end I just logged my chocks to chocks time, although this usually equaled about 0.3 a sector which IMO is a pretty good rule of thumb.

[Jober.as.a.Sudge]

I wonder if what you're thinking of is the relatively common practice of adding 0.1 to flight-times, to allow for taxi-times at the start/end of a flight. A practice that as far as I'm aware is quite legal.

Now, it's been a long time since I studied aviation law -and then, that was in NZ; but within the CAR's, there used to be -as a definition of loggable time- words to the effect of: "from the time the aircraft 1st moves under it's own power for the purpose of flight, until the aircraft comes to rest at the end of that flight". Given that most operators record aircraft total-times, MR flight times etc. on squat-switch timers, tacho timers or pre-determined block-times, the practice of adding 0.1/0.2 to those times where appropriate is both legal and bl@@dy nearly mandated in law IMO!

One thing I can freely guarantee you right now is, your question is going to be the catalyst for some pretty serious and robust debate here -starting any minute now :E

Grab some popcorn and settle in for the entertainment!!!

[tail wheel]

In the end I just logged my chocks to chocks time.....

And that is precisely what you are legally required to log. :ok:

Any other "rule of thumb" could potentially run you into conflict with CASA.

[glekichi]

If the rules of thumb are going to land you in trouble, I'd like to know what accuracy is required when logging the times then.

Nearest 0.1hr? Nearest 0.01hr? Nearest 1hr?

Typical Aussie GA... my way is correct and any other method is wrong and you will all be prosecuted to the full extent of the law. :ugh:

Use any reasonable rule of thumb you like, with a dash of common sense!

[bagchucka]

CAO 48 definition.

flight time means the total time from the moment when the aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of the flight.

Simple really.

[VH-XXX]

From an aircraft operators perspective, my LAME told me on the weekend that I should be logging the engine run time, less 10% (for taxi time) and writing that in the maintenance release. Everyone seems to have their own rules for this stuff.

[Jabawocky]

Quote:
In the end I just logged my chocks to chocks time.....
And that is precisely what you are legally required to log. http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/thumbs.gif

TW

And that is the problem, the airswitch or timers driven by other digital inputs vary quite a bit.

The engine data for our a/c, and we do not sit around any longer than required to warm up the oil to the minimum temperature, and we do not do many flights under 30 min and many are 1-3 hours, shows a Hobbs/Tach ratio of 1.193, so thats about 0.2 of an hour per every hour flown.

If you want to be realistic in your averages then you need to take the TACH time and add about 0.2 or 0.3 per flight if you are being truthfull. I have timed it many times and it is usually a total of around 12 minutes for both taxi's and fuelling etc so on a fair and accurate estimate that I would be prepared to stand up in court and prove, 0.2 is it.

Food for thought :cool:

[empacher48]

Easiest method I ever used back before I joined the airlines was SUDS (Start Up Down Stop).

Up and Down went into the aircraft tech log. Start and Stop went into my logbook.

No fuss working off tachos, air switches or "rules of thumb".

[mates rates]

It's as per CAO 48 definition with an allowable error of -/+ 3 minutes as .1 of an hour is 6 mins.So 9mins is .1 and 10 mins is .2 etc.And as it's a LEGAL requirement to carry a TIMEPIECE (not mobile phone digital time read-out) measuring hours/minutes/seconds under CAO20.18.Hopefully we can all read the time!!Any other interpretation of this by operators is ILLEGAL.

[Fly-by-Desire]

Why is a mobile phone not a timepiece?

[glekichi]

Any other interpretation of this by operators is ILLEGAL.

Why is it then that my ops manual, as approved by CASA, states to use airswitch plus 0.1 as a rule but more as appropriate?

In my last job I recorded actual taxi and takeoff times because that was what worked best on that particular operation.

mates rates, I hope you haven't been incorrectly teaching your students that the ONLY way to calculate logged time is to measure it exactly on your watch!

This is exactly what I was referring to in my first post on this thread. The ones that get all high and mighty telling everyone how it MUST be done usually are the ones that get it wrong.

(BTW, if you are going to use that method, which is fine, when your watch says 9 minutes its 0.2. You don't need to wait for it to say 10 minutes. Have a think about it.)

Back on topic, however, I have heard of a bunch of instructors at a particular flying school beefing up their multi time (and saving money at the same time because they were only paying airswitch) by taxiing to the runup bay and spending a significant amount of time there, flying a couple of quick circuits, and calling it a day. Perfectly within the rules but sickens me nonetheless. They would have spent even less and got a whole lot more out of doing a few hours ICUS on some real operations in a PA31. What ya reckon GG? :}

[Jober.as.a.Sudge]

Why is a mobile phone not a timepiece?

Used to be that the requirement for legal timekeeping in-flight was for an hour and minute hand, with sweep-hand indicating seconds. Sorry, no ref available -it was a while ago ;)

Additionally when I was studying all this (and I suspect when the rules/regs were written) it was all pre-cellphones! That may have some bearing also :}

[BurntheBlue]

Oxford Dictionary
timepiece,
noun,
an instrument, such as a clock or watch, for measuring time
Since my phone displays hours, minutes and seconds, its legal.

If I do 4 sectors in a day with 5mins worth of taxiing at each end + 10mins for a RunUp at the beginning of the day thats 0.6 added to the Switch for my Logbook.
If I had instead added a 'standard' 0.2 per sector that makes 0.8 to be added for my logbook.
That's a difference of 0.2 per day, 1.0 per week...... adding up isn't it. A years worth of logging like this and I could easily inflate by 40-50hours per year.

You need to be accurate with this stuff, avoid using the 'rule of thumb'. How you time it is up to you but I also use 'Blocks to Blocks' on a stopwatch. That "Start, Up, Down, Stop" idea also sounds pretty good though.

[Jabawocky]

If you are taking a shot at my 0.2, bare in mind different ops will have different numbers. Mine are private/business and like Saturdays flight to NBR and back it was say 1h50 down and about 1hr30 back plus a warm up and taxi/backtrack and a refuel and taxi at the end of the day. So 2 sectors only.

If you are doing lots of sectors in a day and smaller durations then 0.2 would be way over the top.

In my example above the flight time on the engine TACH time was 3.4 and logged as 3.8, or only 11% which is far below the 19% average.

You need to have a reliable and accurate method of doing this that you can prove.

J:ok:

[puff]

Exactly Jaba In certain ops airswitch plus .1 is simply no where near an accurate indication of chocks on to chocks off in say circuit ops in a Baron/Bo on a short runway where for safety each landing is a full stop and taxi back to the end of the runway - perhaps wait at the holding point etc etc. A session of circuits of .5 airswitch could be up to 1.0 in chocks to chocks time.

[glekichi]

And another one......

If I do 4 sectors in a day with 5mins worth of taxiing at each end + 10mins for a RunUp at the beginning of the day thats 0.6 added to the Switch for my Logbook.
If I had instead added a 'standard' 0.2 per sector that makes 0.8 to be added for my logbook.
That's a difference of 0.2 per day, 1.0 per week...... adding up isn't it. A years worth of logging like this and I could easily inflate by 40-50hours per year.

4 x 10 mins of taxiing plus 10 mins is 50 minutes, which to most people is 0.8.
The same as 0.2 per sector.

You need to be accurate with this stuff,

You have shown that the two are the same in your particular operation. I log 0.1 per sector as per my company's ops manual because on average the total taxi time is going to be less than 9 minutes.

This is an accepted method of complying with the rules of logging flight time. What part of that do some of you not understand?

[mates rates]

Just read the CAO's which for once in this case,are simply written and apply them.

[BurntheBlue]

4 x 10 mins of taxiing plus 10 mins is 50 minutes, which to most people is 0.8.
The same as 0.2 per sector.
You are correct, but I said 5 mins at each end, which is 2 and a half to taxi in and 2 and a half to taxi out. The first taxi out of the day takes a little longer due to initial A/C setup... subsequent sets of checks run smoother, faster.

Jaba
I didn't intend on having to explain the details in my numbers, these are just the actual times that I have recorded from chocks to chocks. My intention was to illustrate how important it is to log accurate times. i.e. what you are actually flying rather than settling for a 'rule of thumb'. It isn't hard to note your chocks out at the start and chocks in at the end and using the difference.

[tail wheel]

If you read the spotted dog's first post above, the second sentence (and second paragraph) states:

My questions are about log book fraud/ false entries/’massaging’ of flight time in Australia.

You can split hairs in calculating taxi time etc but it is only pointless thread drift. :=

I suspect - and hope I am very wrong - that the spotted dog was asking ways to fudge a log book and get away with it.

We're not interested in any illegal schemes to fudge Log Books being posted on PPRuNe, but he does raise an interesting question about the reference to CAR283 in CAR5.52. I called my local FOI who mumbled his way through a response by suggesting the reference to CAR283 is now replaced with provisions of the Crimes Act.

[Jabawocky]

Well there are probably plenty of ways to dodgy your log books.....and still not ever be proven otherwise. But who really has such a desperate need to do so?:=

Do the right thing, and you cant go too far wrong!

J:ok:

[BurntheBlue]

bickering over taxi times may be splitting hairs but it is, as has already been said, an easily defendable way to inflate.

Do the right thing, and you cant go too far wrong!

Here here.

[helopat]

Easiest method I ever used back before I joined the airlines was SUDS (Start Up Down Stop).

Up and Down went into the aircraft tech log. Start and Stop went into my logbook.

This is EXACTLY what we do. Makes it easier as its part of our Ops Manual (which is sanctioned by CASA and, I hope, reflects a legal practice).

HP

[LeadSled]

Folks,
Our esteemed moderator, Tailwheel, has spelled it out quite clearly: This is one of the few areas that are quite clear in the regulations.

Both pilot and aircraft log books are a happy hunting ground for CASA investigators, and the charge is criminal fraud per the Commonwealth Crimes Act.

Comes in very handy when CASA/DPP want to beef up a case that is a bit thin, nothing like a "substantial" list of alleged offenses to impress the Judge that you are a serial offender and a serious threat to aviation safety, and not just somebody who has made an isolated mistake.

Believe me: My CFI/LAME/good mate/boss/rabbito/I'm given to believe/Friday night aero club legal x-spert/ etc / told me "rules of thumb" (or alternative body parts) has no standing when it come to the "interpretation" of block time and air time.

Tootle pip!!

PS: Something different to the Act/CARs/CASRs/CAOs in a log book, or in an Operation Manual, unless based on a Legislative Instrument, has no standing ---- CASA do not "approve" Operations Manuals, they "accept" same, an important difference.

[Counter-rotation]

Yeah, it's been answered well and truly!! Can't believe I'm wasting time writing here... :}

All those with "rules of thumb" etc, repeat after me:

"Rules of thumb for logging of flight time are for JOKERS - people who can't be bothered looking at a timepiece twice in a flight, or doing sh!t properly in general..." :D

Got it? It is about the easiest part of your job!!

So why am I wasting time writing this post? Someone mentioned Ops manuals, and I was reminded of a previous job where a total peanut CP (we've all had 'em! :}) insisted that I use his rule of thumb for logging flight time :hmm:

I said "ping off" and he started crapping on about getting it inserted into the Ops Manual if neccessary! Ha ha good times :yuk:

CR.

[tail wheel]

LeadSled's post reminds me - if CASA get bloody-minded, each occurrence your Log Book does not reflect the actual recordable flight time as per the CAO is a separate offense.

Is it worth risking fifty or more criminal charges for fraudulent Log Book entries, each 0.1 hour?

A reliable time piece is less than one hundred bucks. Isn't your flying career worth that small investment? :confused:

I recall one of the charges initiated by CASA against an AOC holder was a 3 hour overrun on a 100 hourly inspection, due entirely to a self confessed innocent pilot error in addition on the MR. And CASA discovered the error some 300 airframe hours (and 3 hundred hourly inspections) later.

It does not matter what your Ops Manual states. Where an Ops Manual states or implies anything contrary to the Act, Regulations or Orders, the Act, Regulations or Orders prevails.

The law is ..... well, the law! Knowingly or unknowingly vary it at your peril.

The same questions about Log Book entries comes up time and time again on PPRuNe, every year for the past 12 or 13 years to my knowledge.

Log Book Forgery (http://www.pprune.org/dg-p-general-aviation-questions/376633-log-book-forgery.html)

Time entries for a logbook when there is no VDO (http://www.pprune.org/dg-p-general-aviation-questions/407330-time-entries-logbook-when-there-no-vdo.html)

Fake instrument flight time logged (http://www.pprune.org/dg-p-general-aviation-questions/403194-fake-instrument-flight-time-logged.html)

And those three are only in 2010. :{

I think the subject has more than been done to death?

[A37575]

I remember the case of the Virgin Blue captain after flying Brisbane to Melbourne gin clear weather all the way and on autopilot too. After shut down he says to the F/O who is writing up the times sheet "Put me down for an hour I/F will you?'

How's that for integrity....:mad:

[glekichi]

Some genius please tell me which part of the CAO is being broken by adding an average figure, when appropriate, to the accurate air time figure from the GPS to calculate the flight time?

"Rules of thumb for logging of flight time are for JOKERS - people who can't be bothered looking at a timepiece twice in a flight, or doing sh!t properly in general..."

You're saying all the pilots that follow the ops manual at my operator are jokers?

There is more than one way to skin a cat and there are more ways than just counting the minutes and converting that into a decimal figure to satisfy the CAOs.

Leadie, yeah, ok. Are suggesting that the ops manual would be accepted even if CASA did not consider the method an acceptable means of complying with the rules? Its a pretty major turboprop operator I'm talking about here.

[Peter Fanelli]

How frikkin' hard can it be to note the time when you release and set the brakes at the beginning and end of the flight.

Oh wait, I get it. the new generation of pilots is unable to subtract 10:58 from 12:37, is that it?

:ugh:

[gutso-blundo]

Not necessarily, Peter...
I was all for using clock time for logging my MR and Log times, but in my current company this is frowned upon - apparently last time CASA came for an audit they were astounded some people were taking 0.3 to taxi. So the FOI suggested we use MR time + 0.1 for each landing.

Great consistency with the letter of the law there... :hmm:

[Xcel]

It's written in our ops manual +0.1 Vfr and +0.2 ifr. Ops manual is Casa approved and is a direct relationship with Our actual ops so good enough for me. Even then 0.1 is freakin quick even if you take off from a taxi way.

[Dalmatian]

From post #21
I suspect - and hope I am very wrong - that the spotted dog was asking ways to fudge a log book and get away with it.

Nothing so sinister I assure you. Quite the contrary in fact. Nor was I trying to open a debate about 'rules of thumb'. And as far as I am aware my log book reflects time logged strictly in accordance with the CAOs and CARs and I am happy to have it audited at any time.

My main aim in posting was to get answers to the following questions:

1) If you are made aware that someone is currently, or has in the past been exaggerating flight time in their log book what are your legal obligations?

2) Are there any implications for an organizations Chief Pilot if they are aware that a pilot employed in their organization has inflated flight time in the past? If they continue to do so while employed by the organization as a pilot?

3) What are the insurance implications for the organization if they allow that pilot to use their aircraft, knowing that there may be false or inflated flight time?

4)Would you employ a pilot if you had suspicions about the accuracy of their log book? Does this reflect on their general integrity, would this person be a risk of breaches of professionalism in other aspects of their flying, or is it a common enough occurance to be allowable under some circumstances with careful monitoring?

I'd love to get your opinions on those questions.
Thanks,

Spotted Dog

[Counter-rotation]

glekichi
You're saying all the pilots that follow the ops manual at my operator are jokers?

Ah, yeah fair call mate - that was a bit robust! I was feeling a bit sporty when I wrote it!! (It does however reflect my personal opinion, and we know about opinions, don't we?!)

Can I retract that? And more correctly, redirect it to the knob :} who wrote it in your Ops Manual?! And the CASA knob :ok: who "approved" it?!!!

And it touches on another point, of the "relevance" of Ops Manuals in many instances, I reckon. They should be for guidance on company policy, and "expanding" on compliance issues. Too often they are written by twiddlers who want to put exactly this sort of dribble in 'em. They should never be at odds with published regulations!!

Where Ops Manuals and Regs conflict, guess which one wins? Why do these sorts of statements exist in Ops Manuals? Poor authoring in the first place, and poor vetting during the "approval" process!

Just my opinion :O

CR

[goldypilot]

My 2 cents: all these people that are claiming more hours then what they are actually doing. You are cheating yourselves as you are doing this to get into somthing bigger and better i am guessing. Why are you in such a rush???? Enjoy the bug smashers and the your career to the airlines/the top. Personally i enjoy flying and they only let me do 900hrs a year so i am not going to log one second over what i actually am allowed to do otherwise i would be sitting on the ground for a few weeks.

[PA39]

Log book hours are in my opinion over rated. Why would you really bother fudging hours?? I once conducted an AFR on a bloke with more than 5000 logged hours, only to find he had became lost on a 50nm navex, although he absolutely GREASED them on every landing. When i quizzed him during the debrief he advised me that nearly every one of those hours were logged in a glider tug!! So to me personally hours logged don't mean much, you can tell before the guy (or gal) even fires the thing up whether he can fly an aircraft, just in the way they handle and prepare themselves in the cockpit.

[LeadSled]

Some genius please tell me which part of the CAO is being broken by adding an average figure, when appropriate, to the accurate air time figure from the GPS to calculate the flight time?

glekichi,

Are you serious???? Or just extracting the Michael????

Read what Tailwheel has said, go back and read the exact legislative references, look it up on the ComLaw web site (the reference source for lawyers and judges, the people who are going to convict you if you don't do what the law says).

And, as I have said time and again, and as an increasing number of pilots and LAMEs have found out the hard way, a criminal charge (for US it doesn't even have to be a conviction) or conviction for any aviation related offence will see you barred from many countries. This can be professionally career limiting, who wants to hire a pilot that can't fly outside Australia, as well as a personal embarrassment.

As has been said, time and again, both "flight time" and "air time" are defined in the Civil Aviation Act 1988 and Civil Aviation Regulations. So, quote Tailwheel as the genius.

Tootle pip!!

PS: As been said, time and again, CASA DO NOT APPROVE Operations Manuals, they "accept" same, and legally there is a world of difference.
Just because there is garbage in the manual for a kero burner makes not the slightest difference, garbage is garbage, and does not amend the law.

That THE LAW is THE LAW seems to be a concept beyond the understanding of far to many who post on pprune.

jus publicum privatorum pactis mutari non potest
public law cannot be changed by the agreements of private individuals

[Sunfish]

Is the engine hour Hobbs meter a suitable time reference for the log book?

[glekichi]

LS, I have checked against all the documents you have suggested and still cannot find a reference to say that one must start a stopwatch at the start of taxiing before a flight and stop said stopwatch as soon as taxiing has finished post flight.

What I can find, is that the flight time, which includes taxi time, must be recorded. I can see nothing whatsoever to suggest that the method used by my company is in conflict with this rule, nor have I seen or heard of any indication from CASA that this is not an acceptable means of complying with the rule.

We are logging flight time in a method that is proven to be both reliable and accurate.

You sound like exactly the kind of person that gives CASA a bad name. You have read something into a law that is simply not there and are now running around trying to force that interpretation onto others using scare tactics about prosecution and shouting about how people's careers will be ended.

[Lasiorhinus]

How hard is it to just note the time when you start moving, and the time when you stop moving???:ugh::ugh:

[LeadSled]

You have read something into a law that is simply not there and are now running around trying to force that interpretation onto others using scare tactics about prosecution and shouting about how people's careers will be ended.glekichi,

Grow up.

I have lost count of the number of matters, in which I have had some involvement over the years, where CASA and it's predecessors have done over a pilot for personal log book errors, or an operator for "false entries" ---- being inaccurate times entered in an MR.

This is nothing new, but the latest one, of which I am aware, is likely to be listed for hearing in the next month or so, once the DPP finally decides how long the list will be.

The number of pilots I have personally dealt with, that are barred from the US is 11, including two chaps who used to go to Oskosh every couple of years --- but no more, sadly. Two other of the pilots were working for a corporation, but no more. Now they are effectively limited to Australian territory, and will not be considered by any Australian ( or any other) airline for employment.

One poor sod was prevented from accepting a USAF invitation to attend 60th Anniversary of VE Day functions, he has flown with the 15th Army Air Force in WWII.

I suggest Tailwheel has been in the aviation business since before many posters on this site were born, read his words very carefully.

As for CASA "approving" a manual, CASA DO NOT approve manuals, they "accept" them, there is a very significant difference. Various CASA FOIs directing amendments to manuals as several have suggested only reveals the lack of basic standards of knowledge and lack of CASA training of FOIs ---- a matter raised in successive ICAO audits.

As to the guy booking IF time in the gin clear, I suggest whoever criticized that, go re-read the relevant CAO, it's quite legal.

Much of the time in Australia, if you had to be in actual IF conditions to log IF time, it would be well nigh impossible to log the time required for recency ---- the CAO recognizes this fact ---- and it can be on autopilot, contrary to opinions I have seen elsewhere on this site.

Tootle pip!!

PS: Most operators of large aircraft, to avoid these problems, use automatic time recording, and have done for may years. They literally read park brakes off to park brakes on for flight time, and air time off and on is triggered by the U/C squat switches.

Not mentioning the airline by name, just let's describe it as a very long standing Australian based international airline, got into an interesting stoush because the Operations Manual purported to direct the aircrew to log time in a manner contrary to the Act and Regulation. That problem has long since been corrected to reflect ICAO Annex 1, which means there is a Legislative Instrument to allow a variation from the non-ICAO parts of the Australian regulations.

All legally neat and tidy, as it should be.

[Sunfish]

Can anyone tell me if Hobbs meter engine time is a legal basis for logging flight time? If it isn't then there are Tens of thousands of illegal entries in thousands of log books, because that is what I was taught.

Furthermore does CASA understand and apply the concept of materiality in making decisions to prosecute? Sounds like they don't.

[LeadSled]

Clinton,

With respect, re. my posts on this subject, differentiate between pilots and engineers who have a conviction for log book mis-recording, of whatever variety, and pilots and LAMEs who have found their travel rather restricted, as a result of any conviction on an aviation matter.

As I am certain you are aware, the US in particular takes a very dim view of anybody with a conviction on an aviation matter trying to enter the US.

I first became aware of how serious this is taken, when a LAME well known to me arrived in KLAX with family in tow, for a holiday built around a visit to Disneyland.

Much to his surprise, disappointment, and expense, he was refused entry, and was on a flight back to Australia the same day.

Several posters on this thread have made light of this type of matter, for their information, see the following:
A Guide To

Framing Commonwealth Offences, Civil Penalties And Enforcement PowersSee P 11, of the 2007 doc., and the serious consequences of a criminal conviction, quite apart from any immediate penalty.

Perhaps the most important factor to be considered in determining whether a provision should be criminal or civil, is the effect of a criminal conviction. Conviction for a crime carries with it a range of consequences beyond the immediate penalty (eg imprisonment or a fine).

- A person who is convicted of certain offences will be ineligible to hold public office and may be removed from a position they already hold. For example a person who has been convicted of an offence punishable by imprisonment for 12 months or longer cannot become a Senator or member of the House of Representatives, Commonwealth Constitution section 44(ii).
- Subject to the spent conviction provisions in Part VIIC of the Crimes Act 1914, a person may be required to disclose the fact of their criminal conviction in a range of circumstances. For example, disclosure may be required in seeking employment to care for minors or work in a law enforcement agency.
- The person may be ineligible to travel to many countries.
- A conviction may affect also the right of a non-citizen to remain in Australia under the Migration Act 1958.
- A person, whether a natural person or a body corporate, may be disqualified from becoming accredited under various legislation. [ added by me: Holding an ASIC card ??]
- A person may be ineligible to be a director, principal officer or auditor of a company, for example section 245 of the Life Insurance Act 1995.

In addition, a criminal conviction carries with it a social stigma, particularly where the conviction is accompanied by imprisonment. As with the other consequences discussed above, this will have more impact on a natural person than on a body corporate.
Given the extent of the criminal offences in the aviation law, is it wise to ignore relatively simple compliance with the logging of hours, in favour of "rules of thumb" that have no legal basis, and are clearly contrary to law ----- no matter how long they may have been in "general use".

Tootle pip!!

[glekichi]

LS, nobody on here has once suggested that rules should be ignored, yet that's 4 times you've told us why they shouldn't.

Can you please tell me which part of the rule you think my company's method is "clearly" not complying with?

[LeadSled]

Clinton,
Fitting unapproved parts ---- but it was far from straightforward, he had accepted parts under a release note from a CASA CAR 30 approved organisation.

The argument that he lost concerned what he should have done to verify that the parts were airworthy, other than take the release note ( a local DA-1, not an import under an 8130) at face value. I never understood how he was convicted, but he was!

You should know that pilot or maintenance logs have long been a happy hunting ground for inspectors since aviation regulation was invented ----- the one aviation area where Australia was years ahead of the US, and by volume or weight, we still are the world leader in aviation legislation.

As I have told just about every student I have ever had, it is usually just as easy to do the right thing as the wrong thing, and this certainly applies to all flight records.

Why give the CASA a free kick ???

All you appear to be saying is that if a person gets convicted of a criminal offence, there are serious consequences for the person. Thanks for that.

Quite a few of the posters here do not seem to understand that, if, and it's a big if, I can help to get the message across, I will have achieved something.

Something I really hate having to do, is tell a young and enthusiastic pilot that his job application cannot be considered, because of a conviction.

Tootle pip!!

[Torres]

Clinton

You may recall a decade ago in your previous employment that one of the many trivial matters used by CASA to justify suspension of an Air Operator's Certificate and ending up in the Administrative Appeals Tribunal, involved a three hour over run on an Islander Maintenance Release. The error was the result of an innocent pilot error in addition. It was "discovered" by CASA (actually pointed out to CASA) over 300 hours and three hundred hourly inspections later.

The same innocent error was also used in the subsequent action to remove the Maintenance Controller's LAME license.

Whilst I suspect flight time plus 0.1 hours for log book time may be reasonable, it is not in accordance with the regulatory requirements and would no doubt delight some vindictive, bureaucratic FOI seeking to make a name for himself.

Considering your previous employment and your profession I would have thought your advice would be simply that all pilots should follow the regulatory requirements when recording flight time and completing their Log Book?

Which is what Leadsled is suggesting?

Sunfish

As you would know, a Hobbs Meter is only a timing device. I have seen them connected to an air switch (to record MR time); and to an engine oil pressure switch (which would approximate pilot's Log Book flight hours). Considering Hobb's claimed accuracy of ±200ppm, (±0.02% over the entire voltage and temperature range) any reasonable CASA FOI should accept that the hours indicated by a Hobbs Meter, switched by an engine oil pressure switch, would reasonably equate flight time for pilot Log Book recording purposes.

But I also recall a CASA AWI requiring a Hobbs Meter disconnected and removed until the aircraft owner obtained a CAR35 Engineering Order for the Hobbs Meter installation, despite it originally being installed by an E&I LAME. That may invalidate Hobbs Meter hours recorded on an MR or in a Pilot Log Book? :ugh:

[Torres]

The grounds relied upon by CASA were never ‘trivial’.

I guess that is a matter of opinion.

Everyone else: Most of what I’ve heard on this subject for the last 3 decades is the same broken record. I'm only new, but I'm told by those who've been around for a while that the record's been broken ever since pilots were invented. My inexpert advice: Find a real expert, and follow their advice.

For new pilots, that sarcastic advice is about as useful as an ash tray on a motor bike.

[33amc]

Sorry to butt in on this clearly off topic piece, but to bring it slightly back to topic...

With modern technology, ie. computerized records, your flight training school, if you still go to one, should have a up to date record of your hours flown. I know mine does, and i know a lot of other clubs around do as well. It is ultimately the responsibility of the pilot to take charge of how he/she writes up their log book, however, if the C.I is doing their job properly, they should be keeping a sharp lookout on fraud.

We all have to see a CI at some stage in our training. Now i don't know about you guys, but i'm asked to present my log book to him before a flight. I had to to it for my PPL and he crossed checked it with the clubs records. It is and should be at that point that certain people will be crapping their pants OR happily smiling for once at their C.I.

well thats my 2 cents anyway.

[LeadSled]

Clinton,
Why was I unable to understand the judgment ---- because the opinion of the eminent SC for the defense (and this is what most LAME would understand) was that the LAME was entitled to rely on the certification accompanying the overhauled components obtained and fitted, and wasn't further required to strip down the component ( an overhauled cylinder assembly) to ensure it was airworthy. After all, the release note was created by the CAR 30 approved overhauler of the cylinder assembly. The relevant section of CAR 42 (CAR 42W(1) ??)had been satisfied.

But that was not the judgment of the court. As I recall, LAME was not able to finance an appeal.

Back to the thread, the definitions of flight time and "air time" are quite straightforward, but that seems to be too simple for some, as does the idea that the CFI/Instructor/ LAME/whoever can "order" that times be logged contrary to the law. About as common as the practice of schools/clubs purporting to direct pilots that they do not have "the authority" to enter defects on the MR, despite the fact that they were the pilot in command of the aircraft.

As for checking logbooks against school/club records, what use is that, if the school/club method of logging is not compliant ---- as many are not. After all, it seem to me that the law is quite clear about who is responsible for a personal log book.

I hark back to the speeding analogy, that lots of people do it doesn't change the law.

As to not hiring young pilots due a criminal record, in the years gone by, when my brother and I had a charter company based in Cooktown, or when I was a school CFI, it never happened. The good old days, when a figurative "clip under the ear" by an Examiner of Airman was the order of the day, not "100% enforcement" ---- you will probably remember that statement.

In more recent years, sitting on a review panel for applicants, too often, including several quite recently, and I do not intend to be specific about times, dates and places.

Although I have not been able to confirm it, it would seem to be the case that the US wants to even know about administrative fines, if they are aviation related.

The matter of pilots so easily acquiring a criminal record for matters that are quite trivial, is not a trivial matter.

Tootle pip!!

[werbil]

So can anyone tell me how to determine when a seaplane comes to rest on the water at the end of its flight? :confused:

[Lasiorhinus]

Surely, when it stops moving with respect to the water.

[Sunfish]

Lasiorhinus:

Surely, when it stops moving with respect to the water.

It's always moving with respect to the water, unless the water is dead flat and there is no current or tidal component. Don't you mean "with respect to the land"?

[ZappBrannigan]

Every time this thread comes up it spins me out a little. There are a lot of grey areas in aviation law - but I didn't think log time was one of them. First movement under own power to rest at completion of flight. Not rocket surgery, and I honestly can't believe the number of operators/ops manuals that specify applying a "standard" addition to airswitch time - or LAMEs requiring MR time to be a "percentage of engine run time". It doesn't take more than a second to note Startup, Wheels Off, Wheels On, Shutdown.

Do the guys doing this think I'm fudging my logbook by adding 0.6 to the beginning of my wheels-off time because it was 35 mins from initial taxi to airborne, as happened a couple of days ago (due to lots of jet traffic in and out, causing congestion)? Because this is not only legal, it's what's required by the regs.

[Lasiorhinus]

It's always moving with respect to the water, unless the water is dead flat and there is no current or tidal component. Don't you mean "with respect to the land"?

That'd be true if it was moored at a jetty or wharf. But if you come to a stop in the middle of a bay? Then it'd be motion relative to the water you'd be concerned about...:ok:

[LeadSled]

Zapp,
You have it in one.
Amazing, isn't it, the number of people who want to defend "what I was told was ----" in the face of simple and unambiguous regulations.
Tootle pip!!

[neville_nobody]

Amazing, isn't it, the number of people who want to defend "what I was told was ----" in the face of simple and unambiguous regulations.
Tootle pip!!

I think the issue is more to do with the fact that CASA approve ops manuals that require you to add .1 per landing. If your ops manual say add .1 you have to do it regardless of what the regs say.

[glekichi]

The "accepted" ops manual says to add 0.1 to airswitch or longer as appropriate when delays in taxiing are experienced.

Leadsled still won't explain why he thinks this is in disagreement with the rules, but I tell you what, I'm not going to ignore my ops manual based on an internet discussion. That is a whole lot more likely to end up getting me in all that strife Leadsled is concerned about.

To those that think its just laziness - this particular operation already requires us to record several other times amongst the other amounts of paperwork, and I for one appreciate the slight saving in time.

What amazes me is that people can bag the airswitch plus appropriate amount of time method, yet then say that engine oil pressure driven VDO time is appropriate. Now there is a method that is clearly not doing what the rules say! I am not condoning it either - its still accurate enough for 99% of the flight schools out there - I just find it funny that people can take offence to the airswitch+ method of calculating total flight time yet are happy to accurately record engine start up to engine shut down and call it chocks to blocks when it clearly isn't. Perhaps engine hobbs time -0.1 would be better :}:}

[Tankengine]

Do you idiots not own watches???:ugh:

[Torres]

I think the issue is more to do with the fact that CASA approve ops manuals that require you to add .1 per landing. If your ops manual say add .1 you have to do it regardless of what the regs say.

Not correct. CASA "accepts" an Operations Manual, errors, omissions, mistakes, spelling errors, warts and all. CASA never approves an Operations Manual.

If the Ops Manual contains any matter which is contrary to provisions of the Act, Regulations or Orders, then the Act, Regulations or Oders shall prevail - not the Ops Manual. CAAPs are advisory documents, not legislation.

May I ask which part of Tankengine's rather precise, common sense posting do pilots not understand. :}

You raise an interesting point Clinton, although you may be splitting hairs. Whilst not detailed in legislation (but may be in the CAAPs?) I suspect any movement by the aircraft for the purposes and intent of flight - movement for refuelling, engine run ups etc - by the pilot intending to operate the aircraft on that flight, should be recorded by the pilot as flight time.

If a pilot were to taxi an aircraft for the purposes and intent of flight and subsequently return prior to take off due to a maintenance defect, I suspect that should also be logged as flight time.

Conversely, taxi of an aircraft for the sole purposes of maintenance (e.g. to a hangar) would not constitute flight time and should not be logged, in the same manner that a LAME with taxi approval is not required to log time when he taxis an aircraft for maintenance purposes. However, that time would be included in the pilot's Duty Hours.

I don't claim to be correct, merely a personal assumption without research. If I needed to know I would make appropriate inquiries.

[QFF]

If I taxi to the run-up area and stop to do run-up checks, then taxi to the holding point for the active runway and stop to wait for an aircraft on short final, then line up and wait on instructions from ATC, then commence the take-off roll, what is the point at which the aircraft first moves under its own power for the purpose of taking off?

From the time of initial taxi to the run-up area.

If all that activity is part of the ‘purpose of taking off’ – albeit eventually - what if I taxi to the fuel bowser and shut down to get fuel, on the way to taking off – eventually. Does the taxi time from the parking area to the bowser, and during refuelling, count as part of the ‘flight time’ for the eventual flight. If not why not?

No. Cos there was no "flight" between start-up & shut-down.

If I taxi out to the run-up area and do run-up checks, then taxi to the holding point for the active runway but find something wrong with aircraft during pre-take off checks, so taxi back, does that count as flight time?

No.

For those who say ‘no’, why should that taxi time count only if I subsequently take off then land?

Again, cos there was no "flight".

It is, after all, logging of FLIGHT time. There - hair split.

My own understanding of the current legislation, of course.:)

[The Green Goblin]

Quote:
If I taxi out to the run-up area and do run-up checks, then taxi to the holding point for the active runway but find something wrong with aircraft during pre-take off checks, so taxi back, does that count as flight time?
No.

Actually you can log this and I have done in the past as it is for the purpose of flight.

Quite often a wx radar tests serviceable in the preflight and then when it is activated on the runway prior to takeoff in the wet season it is found to be U/S. It's a no go item and the taxi time can still be logged.

[b_sta]

Yep, as GG says above, as long as the intent is flight, you don't actually have to fly for it to be loggable. Along the same lines, if you taxied out and had a rejected takeoff before taxying back to the apron for whatever reason, you'd absolutely be logging it, even though there was no actual flight.

[tmpffisch]

Yep, as GG says above, as long as the intent is flight, you don't actually have to fly for it to be loggable. Along the same lines, if you taxied out and had a rejected takeoff before taxying back to the apron for whatever reason, you'd absolutely be logging it, even though there was no actual flight.

Think about rejected takeoff's as part of an endorsement for instance, I bet everyone here has logged that, and I've always done them at the end of endorsements, before taxying back to the flightline (so no actual flight afterwards, though flight before).

[The Green Goblin]

Watch out GG and b sta: you could be in line for one of those CASA strict liability prosecutions and confinements to (Australian) barracks.

The rules are ‘clear’.

Or perhaps not.

The CASA definition of flight time in the orders is: flight time means the total time from the moment when the aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of the flight.

It does not state you have to 'take-off' merely that you need to be taxiing for the purpose of takeoff.

For an ex FOI I thought you would have been pretty clear on that one (although I'd prefer not to cross swords with you). This is taught pretty much from day dot as a student and is accepted practice in every flying school/company I have been involved with.

[neville_nobody]

If the Ops Manual contains any matter which is contrary to provisions of the Act, Regulations or Orders, then the Act, Regulations or Oders shall prevail - not the Ops Manual. CAAPs are advisory documents, not legislation.

I am not sure that is the correct interpretation here are a few examples

You company ops manual says the company TO minima is 200m yet this is way below the minima published in the regs which takes precedence?

Your company has an approval in the ops manual to fly 12 hour duty day which is beyond the regs which one is right?

If ops manual says to add .1 per landing yet the regs say start to shut down on a ramp check what is the FOI going to say?? And the answer is follow the ops manual because I have had this very thing happen!!!

[LeadSled]

Neville,
The answer to your first two examples is easy --- both will be covered by Legislative Instruments , have a look at the CASA web site for many examples for minima below standard minima.

If you have a "tailored" Jepp, they will print your actual minima, not the IAL minima.

As for the last, another example of the fact that FOIs come out of industry, and due to nil/inadequate training, they just continue on with all the misconceptions they "absorbed" before being elevated to godlike status (at least in their --- in some cases own eyes).

See the last two ICAO audit reports, it's all public information.

Tootle pip!!

[Sunfish]

This thread is depressing on so many levels.

It is depressing because there should be a simple clear cut answer to the question of logging time that is either embodied in the legislation itself or if not so embodied, CASA should provide a simple direction and explanation, written in plain English, of what is acceptable and not acceptable to it, supported by examples if necessary. CASA should then require its own staff to abide by that direction.

The mere fact that we are discussing the subject of "inaccuracy" indicates that no such direction exists, at least not in a useable form. I do not accept that an explanation of the matter gleaned from interpolating the legislation, regulations, orders and a CAAP (which is after all "advisory") is sufficient.

That such a simple matter has NOT been settled leads me to suspect, CASA being populated by intelligent individuals, is that CASA, for it's own internal reasons, does not wish for the matter to be cut and dried. The only reason I can think of at present for that possibility is that CASA wishes its FOI's to be able to make their own determination of compliance, a practice that to my mind is unusual in the public sector since it invests certain public servants with very considerable power that is not transparently open to review. This is not a good thing.... and, since I was not born yesterday, don't try and fob me off with the excuse "The Legislation means what it says."

The damage to the aviation community is compounded if Leadsleds (and others) allegations of witch-hunts followed by vindictive and malicious prosecution are true. I have no doubt of the consequences of conviction either. The little legal concept of "Materiality" seems to be lost or ignored by CASA, if the reports of prosecution for a Three hour historical error on an MR, and LAME loss of licence are to be believed, which also begs the question of whether Qantas or VB have ever been prosecuted for similar errors.

At a personal level, I have now realised that my logbook, which should be a treasured possession, is actually a millstone around my neck.

My logbook contains errors, going back to early student days that were corrected by the liberal application of "white out". It is "mostly" correct, in that I cannot guarantee that simple "finger trouble" has not intervened, but there is at least one entry where I've conflated about Five flights over a weeks tour into one sixteen hour entry. Individual flights have always been recorded from Hobbes engine hours, which I believe are a reasonable facsimile of what CASA apparently wants because, since I'm paying for them, the aircraft is moving pretty soon after start up.

To put it another way, each page on my logbook should have the words "E and OE accepted" printed on it like most invoices.

The prospect of a detailed logbook analysis by an unsympathetic FOI, perhaps following an accident, does not exactly thrill me. I've already indicated on Pprune (http://www.pprune.org/dg-p-general-aviation-questions/422507-last-asic-last-medical.html) that I am far from thrilled by the bureaucracy and infighting that appears be going on and that is making the holding of a PPL considerably less attractive than it should be.

I can put up with most things and cope with most uncertainties, but the ongoing reports of Aviation related maladministration and capricious prosecution, coupled with the far reaching consequences of such behaviour as depicted in this thread, are one more reason to give the game away permanently. The log book? I'll burn it.

[Torres]

For an ex FOI I thought you would have been pretty clear on that one...

I don't believe Clinton was ever an FOI.

Sunfish ..... CAA/CASA recognised the CARs were inadequate in 1988 and launched into regulatory reform. You have been here long enough to be familiar with THIS (http://www.pprune.org/dg-p-reporting-points/164130-regulatory-reform-program-will-drift-along-forever.html) thread, commenced in 2005.

We have an entire generation of young pilots who trained and now operates under a set of Regulations which at very least are inadequate and ambiguous.

This month is the 22nd anniversary of CASA's regulatory review. I doubt CASA is competent or capable of ever completing the task.

[djpil]

Sunfish, you need cheering up. How about a flying holiday in the USA where you'll see how pleasant flying can be? For example, no FAA requirement to log every flight - only what is required to meet certain specific requirements per their regs. (Professional pilots may have other reasons to log their flights however`)

For my own flight time here I use the bezel on my watch to mark start of the flight (per our regs of course) and when I stop the flight a quick glance indicates the time that I need to know to put in my logbook. I wonder if anyone will ever check it against the flying school's records which have the VDO (engine running) time. It records to the nearest 0.1 hr at the start and at the end. (I know there are some VDO's which record time in minutes but not ours) My flights are typically 1 hr so in terms of measuring my flight time the VDO has an accuracy of +/- 10%. i.e. on average it is OK but for any one flight the VDO could be 0.1 hr less or greater than my watch time.

One of my friends was recently put out because I logged the time per my watch rather than tacho time on his aeroplane as it cost him more money to buy my time. No thought to him cheating me out of money if we had used tacho time as the deal was $ per hour not $ per unit on some other device.

[Tee Emm]

One VH registered airline operating 737 Classics and operating to Nauru on a scheduled service uses Cruise captains. These are first officers who are authorised by CASA to log in command time when the captain is on rest but are not permitted to log command time for take off and landings or below a certain altitude. There is nothing in the Australian Regulations that permit this and one wonders if this practice is authorised by a local FOI with the knowledge of CASA Head Office? Certainly a very useful way of building command hours on a large jet - but what is the CASA Regulation that permits this practice? And if there isn't one then surely this is illegal. According to the Regulations there can only be one captain for the whole flight from take off to landing even if he is absent from the flight deck for an indeterminate time.

[Torres]

"....and you know what: I don't know of any person - not one person - who's been prosecuted as a consequence of the content of their logbook,..."

I note your careful use of the term "prosecuted" Clinton. When an organisation is funded by 8 million tax paying shareholders and that organisation has extensive "administrative powers", prosecution is often un-necessary to achieve the organisation's desired outcome.

I am aware of at least one instance where the regulator insinuated (not alleged) that a pilot's Log Book contained fraudulent entries whilst that pilot was working overseas. That pilot was hassled by various CASA FOIs in every job he accepted around Australia to the point he gave up flying. Indeed, it was suggested the nexus of the issue related back to the RAAF, before the pilot held a civil pilot license.

To give credit Clinton, it was after you left the Halls of Doom and Gloom, but a number of your former colleagues were very involved.

I will not comment on the veracity of that pilot's Log Book as I simply do not know whether it contained fraudulent entries or not. Perhaps if the matter had been heard in an appropriate Court any evidence could have been tested and we may have known the truth with the pilot either vindicated or convicted, a basic precept of our democracy.

The need for clear, concise and unambiguous Regulations, together with an accountable and transparent Regulator, is long over due.

Which I think is precisely what Leadie is alluding to!

djpil. I urge caution in using "tacho time" in recording any time required by CASA. Most tachometers display accurate time only at a pre-determined engine RPM. (I think early Cessna singles were calibrated to indicate accurate time only at 2,400 RPM.) Operating the engine at any RPM above or below the pre determined RPM will result in a corresponding error in time.

[djpil]

Agreed Torres, wrt pilot logbook times.

I have a copy of AAC 198-2 - I don't see it on the CASA website but it is still mentioned there as a reference on the subject of aircraft time in service.
This article replaces AAAC 120-5, and is in response to requests from industry to clarify the situation regarding the various methods used to record time in service for aircraft operating in the general aviation industry.It goes on to describe the methods which may be used to record TIS.Watch time as noted by the pilot.
An "approved automatic time recording instrument, installed so that it will record an elapsed time that is equal to or greater than the defined "time in service" ...
engine oil pressure switches; airspeed switches (including external vanes); main landing gear squat switches; and/or mechanical tachometers that also record engine hours.
...
In all cases where recording of time in service is achieved through use of an instrument which records a greater time than the defined "time in service" eg: mechanical tachometer, no reduction or factoring of recorded hours for maintenance purposes shall be made.

[6DOD]

This appears to be a great area of confusion. Would it not be simpler to just take the time that you are the pilot in charge from start up to shut down. Simplifies and is easier to check times?

[The Green Goblin]

It would 6DOD, however Australian aviation needs to be overcomplicated to keep the status quo :p