Documenting the Annual Inspection
As you know, 14 C.F.R. §91.409(a) requires that an aircraft must undergo an annual inspection every 12 calendar months or sooner in order for that aircraft to be airworthy. Once that inspection is complete, what is the holder of an inspection authorization (IA) required to do to document the annual inspection? What maintenance record entry is required and where must that entry be made?
Before we get to those questions, first it is important to understand to what the annual inspection applies. Section 91.409(a) states that an aircraft must receive an annual inspection in accordance with 14 C.F.R. Part 43. When we read Section 43.15(c), which governs annual inspections, we see, and the FAA tells us, that the annual inspection only applies to an aircraft. Specifically, that section requires that an annual inspection be performed using a checklist containing the scope and detail of items contained in Part 43, Appendix D. However, since Appendix D applies to the whole aircraft (including propeller and engine), it is the aircraft itself that receives the annual inspection rather than the individual components. This is true even though the engine and propeller assemblies are also inspected during the course of the annual inspection in accordance with Appendix D, paragraphs (d) and (h).
Now that we understand the scope of the Section 91.409(a) annual inspection and that it applies only to the aircraft as a whole, next we need to determine what maintenance record entry is required. A “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 ... shall make an entry in the maintenance record of that equipment,” reads 14 C.F.R.§ 43.11(a). Since annual inspections apply only to the aircraft, the person who approves or disapproves an aircraft for return to service after an annual inspection is performed must make an entry in the maintenance record of “that equipment,” which, according to the FAA, means “the aircraft.” Thus, a maintenance entry documenting completion of an annual inspection is required only for “the aircraft.”
Where is an IA supposed to make that entry? In the aircraft’s logbook? In a maintenance logbook for equipment other than the aircraft, such as a logbook for the aircraft’s propeller or engine? In both? To answer these questions, we need to look at 14 C.F.R. § 91.417 – Maintenance Records.
Section 91.417(a)(1) requires each registered owner or operator to keep maintenance records for each aircraft (including the airframe) and each engine, propeller, rotor and appliance of an aircraft for the periods specified in Section 91.471(b). However, Section 91.417 doesn’t say anything about “where” those records are to be kept. The regulation doesn’t require owners and operators to keep separate or individual records for the required items, nor does it require them to keep all of the maintenance records for the aircraft in a single logbook.
As a result, owners and operators may keep one logbook for all of the records for the aircraft and its appliances/components and that is acceptable to the FAA. In that situation the IA would document completion of the annual inspection for the aircraft in that one logbook. Alternatively, some owners and operators keep separate or individual logbook records for the aircraft’s airframe and appliances/components which then collectively comprise the aircraft’s records. In that situation, since the IA is only required to document the completion of the annual inspection for the aircraft, the IA may, but is not required to, document the completion of an annual inspection in each of the respective logbooks. This option is also acceptable to the FAA.
If an owner or operator maintains multiple logbooks for the aircraft, the FAA suggests that it is probably good practice for the IA to document completion of an annual inspection in each of the respective logbooks. However, if the IA documents the completion of an annual inspection in the maintenance logbook for equipment other than an aircraft, the entry in the logbook should be specifically related to that appliance/component. For example, if the IA is going to document the annual inspection in the maintenance logbook for the aircraft’s engine, he or she should use language such as, “I certify that this engine has been inspected in accordance with an annual inspection and was determined to be in an airworthy condition.”
However, it is important to note that this language is different than the language that would be used in the entry that the IA would make in the aircraft’s logbook to document completion of the annual inspection and returning the whole aircraft to service rather than its individual components. In that case, the IA would use language referencing the “aircraft” rather than an individual appliance/component such as the engine or propeller. In both cases the logbook entries would likely contain more detail regarding what was found during the inspection and any maintenance performed on the aircraft or appliance/component.
Now we know both how and where an IA is supposed to document an annual inspection in order to comply with the regulations and keep the FAA happy. We’ll save a more detailed discussion of what should and should not be included in maintenance entries for another day.
Greg Reigel is an aviation attorney, author and pilot. He holds a commercial pilot certificate with an instrument rating and can fly single-engine land and sea, as well as multi-engine land aircraft. His practice concentrates on aviation litigation, including insurance matters and creditor’s rights, FAA certificate actions and transactional matters. He represents clients throughout the country on aviation law matters. He also an adjunct professor at Minnesota State University - Mankato where he teaches aviation law and at William Mitchell College of Law where he is an instructor in the advocacy course. He can be reached via e-mail at greigel@aerolegalservices.com.© 2015 All rights reserved.