Who keeps aircraft logbooks under EASA?

[peterh337]

I've just bumped into this interesting owner's site (http://blog.gotoair.com/) and one of the first things which strikes me is this

Entering all flights for journey log into Aircraft log books. 60.00

I cannot even begin to imagine paying somebody to write up the logbooks. Do EASA Part M companies insist on keeping these?

[silverknapper]

Any airplane I've been involved with that's been the case. Though the decent maintenance providers don't charge for this, or for Part M for that matter.

The not so decent ones have seen it as the money making exercise it is and pounced on it eagerly.

[wigglyamp]

Whilst not directly related to the OP, I have a question for owners: When GMP replaces LAMP soon, who should pay the CAMO to write the new customised maintenance programme? I know it'll probably be based on the manufacturers schedule plus ADs and SBs that the owner has agreed to include but if a maintenance company or CAMO has the aircraft on a programme like CAFAM, there will be quite a time cost involved for setting up the new schedule. Do owners expect to pay for the writing and set-up or do they expect the CAMO to cover this as an overhead?

[maxred]

Well I have been shat on a couple of times due to the Maintenance Co holding the log books. It goes something like this-

please quote me for annual. 40 hours @ 40.00 per hour. Plus charges for admin, plus any parts. plus CAA fees. So....app £2000,00. Yes that is correct, owner please be transparent with any additional works. No problem sir.

Invoice arrives for 6 grand. Excuse me!!!! Pay or else says the Maintenance co. No way says owner, well, we have the logs, so your are stuffed:)

My new company:), and now I am on N reg, owner keeps logs. Any ****, then at least you can move shop, and attempt to negotiate any invoice discrepancies. That said, just make sure the shop is reputable prior to going there.

My understanding is that several CAMO's want to charge for the re write, and that is fair. All costs however, should be quoted prior to any work, saves the usual, but you said.........:\ Oh and I was told by the CAA that the logs STAY WITH THE AEROPLANE. So if it is at the shop, then the logs are also there. If it moves out, so should the logs, although I used to keep them at the shop.

[peterh337]

The reason I was baffled at that chap leaving his maintenance logs at the MO is that it is such an obvious way to end up over a barrel (if the MO is dishonest) and losing them if/when they go bust (which happens regardless of whether they are honest or not) and ending up with a plane whose value could be demolished if certain things cannot be established.

The other thing - I am on the N-reg - is that AIUI the logs have to be up to date, so not writing them up for anything up to a year is not on. Mine are written up for every 50hr check i.e. about 3 times a year and the A&P/IA signs each check (which I do with him, largely but not necessarily within pilot maint privileges).

The £60 charge for writing up the books (presumably the airframe, engine and prop logbooks; I was on G-reg for 3 years myself) from the journey log, together with the owner's mention of doing 60hrs/year, shows what ripoff merchants there are out there. He got charged £60 for about 10 mins' work.

I bought the plane new from Air Touring who as everybody knows went bust a few years ago. I did get a wad of stuff passed to me by the liquidator. I am sure they were amused when I asked them how much there was so (if a lot) I could drive up to Biggin Hill to collect it in person. So without asking me they sent it by Royal Mail Special Delivery without any stamps or franking so I got to pay for it anyway :) Anyway it was only a fraction of what AT had. Various avionics work I never got work packs for because when I asked for the work pack the chap said it is "intellectual property".

Before AT went bust, they tried to shaft me for about £1500 of "warranty work" which the factory refused to reimburse them for because it was a "non mandatory SB" and only "mandatory SBs" are covered in warranty :E Along with most other similarly affected TB owners (there were quite a few, but some paid up) I didn't pay so they didn't play ball after that...

Obviously some shops are honest and some are not, but life is a case of "trust but verify", and it seems that some people don't bother to do the "verify" bit at all.

On Wigglyamp's Q, my view would be that the owner should pay but any documentation thus produced should obviously be his property, so he can take it with him when he moves CAMOs. Charging somebody for work and then retaining the property in the work is what professional photographers do :) And (I know 1 or 2 of those are reading this :) ) most of the ones I know are trying to leave that particular business because the easy work has gradually disappeared.

[wigglyamp]

Peter337

Thanks for your comments - it's what I hoped owner's would accept. In the case of a new GMP produced by the CAMO ( we're talking about EASA aircraft only), it will be custom to the individual aircraft so of course it belongs with the aircraft records and we would not expect to charge the owner to take the data with him. We do hold logbooks on behalf of some owners but others turn up with them the day a check is due and then expect a review to take place instantly. Ideally if we have the books, we can do a forecast of what's due before we get the aircraft in so we don't delay completion of maintenance.

[robin]

I have the logbooks and send my CAMO the flight records every 3 months. They get the logbooks once a year and for very short periods

[Victorian]

In a recent in depth survey of two potential new maintenance organisations, one insisted it was essential to keep the logbooks and the other was happy for me to keep them. A no-brainer really.

This does raise the issue of flying with the logbooks in the aircraft if the maintainer is not at home base of course.

Regarding the new maintenance schedules, I'm hoping that some benefactor is going to publish a 'fill in your own details here' type of document in spreadsheet format for PA-28. Since much of the customisation relates to individual lifed components like hoses etc., non original equipment like radios and applicability of SB's etc to individual models of aircraft and engine, it out to be possible to have a template document.

Any takers out there? The deal could be that each owner publishes their amended version building up a cpllective database. Or we could all go N reg.

[peterh337]

This does raise the issue of flying with the logbooks in the aircraft if the maintainer is not at home base of course.

Did you know there is a "JAA approved" fireproof container for carrying logbooks?

Not kidding!

Or we could all go N reg.

That would actually be quite smart.

Although, paradoxically, it is easier to do a lot of common avionics mods under EASA now, because the NY IFU has washed its hands of 337 approvals so forcing other, potentially much more costly, routes. Well, so long as you install products produced by the Owner of the Known Universe (Garmin).

[peterh337]

there has to be a solution for getting 337s approved and filed.

There is indeed ;)

[wigglyamp]

There is no issue in getting 337s cleared in Europe. There are plenty of FAA repair stations and also IAs who will do it. The main problem is getting an AFM supplement cleared if it's not included with an AML STC. Approved data can be obtained easily from US-based DERs for when you're not using an existing STC.

[peterh337]

An IA needs to sign a 337 to certify the finished work conforms to it, but how do you get the 337 checked and approved by an FAA FSDO before the work is commenced?

AIUI there are only 2 routes: a prior approval via the FSDO and sending the IA-signed 337 after the job is done direct to AFS-750 for filing (which is the gold plated method, with no comeback), or skipping the FSDO pre-approval step and sending the IA-signed 337 after the job is done direct to AFS-750 for filing (which could come back and bite you one day, but not likely to if a DER was used to generate the Approved Data, or the a.d. is a directly applicable STC).

This was explained to me by a senior FAA inspector. Of course he may have been laying it on a bit thick, too...

[wigglyamp]

The method of getting the 337 signed by the FSDO only relates to a field-approval I.e where the modification data needs to get approved. We always use approved data - either an STC, or we get our own data approved by a DER. in this case, we clear the 337 under our repair station approval ( we used to use an IA) and then send it for filing with confidence that it won't bounce.

[BWBI]

My Engineer is so Paranoid about log books that he will not allow them to travel in the Aircraft and I have to deliver and collect them in Person, 2 hours drive away. He says without log books the aircraft is worth little in financial or insurance terms.

His son also an engineer who carries out most of the work also collects and flies the aircraft back for me after maintenance which adds to the feel good factor and gives him a chance to see how it flies.

It also saves the hassle of Ferry flights ( they leave their aircraft with me which means it encourages them to complete the work quickly ) I just pay the fuel and a big boys breakfast at collection and return in the airport cafe.

I like engineers who fly aircraft they have worked on but they seem to be a rare breed these days! By the way I fly a LAA Permit aircraft so nothing flash or complicated!

I complete the flight entries in the aircraft log books and my engineer ( the father ) writes up the necessary endorsements.

[peterh337]

A 337 is an application for a Major Alteration.

It needs to be supported by Approved Data.

What constitutes approved data can be found in AC43-210 (http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/31bed1c77a32c64886256e43006da997/$FILE/AC43-210.pdf).

There are many things which can be used.

Some are high grade e.g. an STC for the specific S/N range, or an AML STC, and nobody will argue with those.

Similarly, using a DER to produce Approved Data, and delivering an 8110-3 design package, is a pretty good way for an installer to cover his 6 o'clock. This can be awfully pricey - I have seen a quote from a US DER for $10,000 for basically 1 or 2 days' work knocking up a wiring diagram from the back of installation manuals.

Then you get onto other acceptable categories of approved data, but they are less "good" and more open to opinion, especially if something went wrong. You can use the contents of an STC (but not the STC # itself) for a different type (but somewhat similar) aircraft, you can throw in all the installation manuals you can find (if they are FAA approved), etc.

AIUI, European installers are basically limited to using high grade approved data i.e. an airframe S/N range specific STC, an AML STC (and hey guess who owns that particular universe.... Garmin :) ), or use a DER to produce it. This does away with the need to get the FAA to pre-approve the application.

The routes which involve the traditional pre-approval method using a US FSDO can be done but the official FSDO covering Europe is not doing it anymore. I don't know why - may be some "funny business" going on in there. But there is no fundamental reason why any US FSDO cannot do it - you just need to get them to deal with you.

[Coriolis]

In response to the OP's question, and in an attempt to cut through some of the hysterical nonsense in this thread:

Who keeps the logbooks? Whoever the Owner wishes - can be himself, or someone else, at the Owner's sole discretion.

Moving on - why should anyone pay to fill in logbooks/raise a Maint Programme? Why indeed.... and the LAMP or proposed GMP remains available to Owner to raise his own document as prescribed, and pay nobody anything.

It would not seem unreasonable for a company charged with maintaining records and logbooks and planning maintenance and assessing ADs and Service Bulletins etc to expect to hold the said records, but if you wish to keep your own then of course you can - but in that case it's not reasonable to expect to arrive carrying the records and then expect the organisation to be able to produce a full workscope instantly without doing (sometimes a considerable amount of) research, which is often inconsistent with the Owner's desire to fly away this afternoon.

In my experience, many Owners have neither the necessary knowledge (or more likely, the necessary interest) to produce such a document, and look to an organisation to do this task for them - in which case, why should the organisation not make a charge for this? (the charge being estimated/quoted/agreed beforehand, if the Owner has any sense, as with any other task)

If an organisation quotes one price and tries to hike your charges without good reason, my advice is twofold:
1 Argue until you win the inflated bill issue
2 Do the job yourself in future

After all, if you have the necessary to gain a pilot's licence, you probabaly have the necessary to gain a maintenance licence too, it ain't rocket science..... so perhaps we just think someone should provide a service for nothing?

But if you do decide to raise your own programme and keep your own logbooks and manage your own maintenance (and if you are aware of the Regulations you will know this has been a legal requirement for a good number of years now), don't forget this will also include facing an ACAM audit should your aircraft be selected, and I have seen some people change their view of what the Part M service is worth when they have been asked to demonstrate how they do the necessary tasks....

[A and C]

Quote:- Switching to N-register at your earliest possible convenience would not be a bad idea.

EASA is stopping this as an option in Europe.

[peterh337]

Is it? When?

[Coriolis]

Silvaire,
I'm sure what you say is entirely reasonable, given my rather limited experience with FARs. Perhaps I should have qualified my earlier post by emphasising it's the situation under EASA in UK (being also aware that EASA elsewhere can be interpreted differently!).

It's an interesting notion (your post #12) about challenging the 'nuttiness' in court. I'm from a background of over 40 years in aviation maintenance across several disciplines, and this has conditioned me into obeying the law until someone changes it, which I admit can make me slow to challenge something which others may view as unreasonable. But nevertheless, until the law IS changed it stands as written and I believe it's a brave or very foolish man who ignores the law because he doesn't agree with it.

By all means challenge, but until the battle is won you're less likely to suffer if you obey it for the time being...... and it's certainly the case that in my experience the old (soon to be superseded) UK LAMP system has only rarely been used the way it was intended, and I do think that GMP will be more aligned with what the OEM recommendations are, which for many SHOULD mean lower charges as there will be less time spent arguing about what should or shouldn't be done at any particular input.

Bottom line: Accurate planning usually means less wasted time and effort, and therefore less likelyhood of being overcharged (barring rip-off merchants, of course) :)

[maxred]

The planning aspect is all well and good, and longer term, should, reduce cost, alternatively, make cost TRANSPARENT. However, that cost will not reduce if the regime is to align GA to the same disciplines as airliner/commercial groups.

Following a GMP/LAMP schedule, to the letter, only increases the cost to the owner/operator. Example:-

Manufacturers manual recommends overhaul of a gear motor at 1500hrs.
Under LAMP/GMP, this would in EASA mandatory, under FAR 'on condition'.

The owner, assuming a duty of care and diligent owner, may well plan for that overhaul at a time interval that will average his cost. Under the LAMP/GMP, that choice is removed. The issue is that every nut and bolt and hydraulic hose, would appear to be mandatory replacement out-with FAR.

[jxk]

Well until its established who eventually takes responsibilty for issuing the ARC (part G/I), maintenance companies will have to ensure that they cover all issues and implications of safety compliance. For instance could a C172 owner elect not to have their seat belts changed if they were good condition?
I cannot see how there won't be additional cost in submitting the GMB!

[Coriolis]

I can't disagree with much in posts 25, 26 & 27 above, but the reality in UK EASAland (and the original question was about logbooks in EASAland) is that the rules exist which require the aircraft to be managed.

Either by the Owner/Pilot or by an organisation approved to do it.

As I said earlier, if an Owner does it for himself he can avoid all the costs of having someone do it for him, and there's no reason he shouldn't choose to do just that - and if he gets himself suitably qualified he can also avoid the charges made by other qualified people (LAEs) he may ask to do the actual maintenance tasks.

But many Owners either don't have those skills or the inclination to get the necessary qualifications (presumably they have other things they'd rather do with their time, and why not?).....hence the alternative of asking a company or organisation or even your mate who knows how, to do it for you. If you choose to ask someone to help, why is it unreasonable to pay for their efforts?

And no, I don't sell ANY annuals for $200 - and couldn't even get close, but then we are discussing and operating under EASA rules not FAA (and no, I'm not interested in a 'my rules make safer aircraft' discussion, because it's a pointless thing to do) - if someone wants to play in this park these are the rules to follow - if you don't like the rules, either play in a different park or get in at the NPA stage and make your case for the rules to be changed - let me know how you get on :-)

But I do have some N-Reg (and G-Reg) Customers who don't want me to manage their aircraft but still want me to tell them what's due, or can I tell them about/send them a copy of this or that - to me that's rather like asking a restaurant to let you eat your own food at their tables
...

Regarding what you might have to change under GMP - please just look at the requirements - all you have to do is assess the various recommendations from the different OEMs and make a reasoned decision about what's right for YOUR aircraft, then put those into YOUR maintenance programme.
If Mr Cessna suggests you change the seat belts at 10 years, while Am-Safe suggest on condition - your aircraft may fly 1500 hours/year and be parked outside in all weathers, or it may only be used 50 hours/year and be kept in a cool dry dark hangar - make your own judgement and put that in your MP. THEN you must stick to it, because you must follow the MP....and if circumstances change, then amend your MP to suit.
All you have to do then is keep an eye on the ADs, SBs etc and make similar assessments and decisions, and have your friendly spanner-bender do the jobs for you.

YOU can make your aircraft as over- or under-maintained as you can get past the CAA - or....

If you'd like me to do it for you I can do that, but I have to eat too, so please don't be offended if I ask you to pay me for my time and efforts (I didn't make the rules, I'm just trying to help you follow them, and I repeat, if you don't like these rules you can change the place you play or change something else until you get the result you want)

....but if you're going to ask me to do it for you, I know very well that, should something unfortunate happen, you'll be banging on my door right quick wanting to know why, so you'll forgive me for trying my best to incorporate every chance to make you safer - even if more safety costs more money (you do remember that, don't you? it's why NASA's budget is/was so high) - but if you DON'T want me to change your seatbelts, simply tell me (in writing please) and I can hold on to that just in case we end up having to show why we didn't..... if you see what I mean :8

And because it's not long till Christmas, and it's my 50th post since 2001, I'll now waive my 50 guinea consultation fee (see, I even reduced it from 250 before waiving it!)

Be safe ;)

[Phororhacos]

I have awful handwriting, so the Engineers keep mine:O.