That’s really interesting and potentially useful and I bet very few people know about that option!
Exactly as I understood NCYankee (wrt IA), thank you. But could you comment on my understanding regarding repairs or alterations undertaken by an A&P or a repair station whereby the logbook entry IAW 43.9 can only be made if the work is carried out satisfactorily…. ie there is no provision in that case for the A&P to enter any other (negative) comment…
The maintenance record needs to be made regardless ICW 43.9 (a):
a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
(1) A description (or reference to data acceptable to the Administrator) of work performed.
(2) The date of completion of the work performed.
(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
The way I read the regulation, item (1) thru (3) are not dependent on the work having been completed satisfactorily. But item (4) is conditional on the work being performed satisfactorily. So, if the work was not completed, an authorized person would not want to indicate that the work was performed satisfactorily and would not do the signature which is the return to service.
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.
If the work is merely in progress, then the log book entry is not normally made until it was completed and could be returned to service. But if the work is interrupted and not intended to be completed, I would expect the log entry would be made reflecting the actual work performed without a signature for return to service.
Peter wrote:
That’s really interesting and potentially useful and I bet very few people know about that option!
There are very few FAA A&Ps that do not have Inspection Authorization.
On a slightly different note : Something that I see rather often and is obviously not understood by many EASA shops & mechanics is ONLY an FAA A&P can actually sign-off repairs.
Log entries by ANYONE OTHER THAN A PROPERLY FAA CERTIFICATED AIRMAN (owner preventative maintenance per list) OR AN A&P, RENDERS THE ACFT UN-AIRWORTHY !
Sorry for the emphasis but I am truely amazed by the number of owners & shops that just don’t understand this.
There are very few FAA A&Ps that do not have Inspection Authorization.
That may be true for A&Ps who work freelance (like you) but there are many A&Ps who work quietly inside companies, often with no authority to sign anything except via the 145 which owns the hangar.
Log entries by ANYONE OTHER THAN A PROPERLY FAA CERTIFICATED AIRMAN (owner preventative maintenance per list) OR AN A&P, RENDERS THE ACFT UN-AIRWORTHY !
I think I know what you mean but actually the wording has too many negatives 
The only logbook entry which can alone render an aircraft unairworthy is one which details some observed airworthiness noncompliance, or one noting an airframe specific AD grounding the aircraft (I’ve been told by an FSDO inspector that this is the FAA device for grounding an aircraft which they discover has some major illegal mod).
I think what you mean is that only an FAA A&P or A&P/IA (as required) is authorised to make logbook entries required for airworthiness.
Or an FAA certificated pilot, for stuff done within pilot maintenance privileges. So for example a UK PPL holder, flying an N-reg in the UK using the 61.3 privileges, can fly the plane but cannot perform or sign off an oil change.
Or a repairman working under a Repair Station which has the relevant authorizations (powerplant, airframe etc…) It seems many FAA RS in Europe do not have an FAA A&P (or IA) on their staff….
Sec. 43.7
Persons authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration.
(a) Except as provided in this section and Sec. 43.17, no person, other than the Administrator, may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service after it has undergone maintenance, preventive maintenance, rebuilding, or alteration.
(b) The holder of a mechanic certificate or an inspection authorization may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service as provided in Part 65 of this chapter.
(c) The holder of a repair station certificate may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service as provided in Part 145 of this chapter.
(d) A manufacturer may approve for return to service any aircraft, airframe, aircraft engine, propeller, appliance, or component part which that manufacturer has worked on under Sec. 43.3(j). However, except for minor alterations, the work must have been done in accordance with technical data approved by the Administrator.
(e) The holder of an air carrier operating certificate or an operating certificate issued under Part 121, 127, or 135, may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service as provided in Part 121 or 135 of this chapter, as applicable.
(f) A person holding at least a private pilot certificate may approve an aircraft for return to service after performing preventive maintenance under the provisions of Sec. 43.3(g).
[(g) The holder of a repairman certificate (light-sport aircraft) with a maintenance rating may approve an aircraft issued a special airworthiness certificate in light-sport category for return to service, as provided in part 65 of this chapter.
(h) The holder of at least a sport pilot certificate may approve an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category for return to service after performing preventive maintenance under the provisions of §43.3 (g).]
The point I was trying to make is that if a NON FAA Certified person or NON FAA Certified Repair Station does ANYTHING to an FAA certified aircraft WITHOUT supervision and log entry by an FAA Certified person or Repair Station, then that aircraft is considered UNAIRWORTHY.
Example: You ask a local EASA shop to do an oil & filter change and they put in a log entry stating such. If the log entry is NOT signed by an FAA A&P or Repair Station then they have effectively rendered the aircraft technically unairworthy.
In this case, the owner / operator should make the appropriate log-book entry, NOT the EASA shop. The problem here is that the owner /operator needs to bee an FAA " person holding at least a private pilot certificate … after performing preventive maintenance under the provisions of Sec. 43.3(g)." (PPL) so if that’s NOT the case, then ONLY an FAA A&P or FAA Repair Station can legally return the acft to service.
Michael wrote:
ONLY an FAA A&P or FAA Repair Station can legally return the acft to service.
Indeed. It is worth noting that the repair station must also have the relevant rating pertinent to the work being done…eg there are shops in the UK that have limited ratings such as airframe, instrument and radio but NOT accessory, powerplant or propeller… which to me means they are not qualified to even do an oil change… despite their protestations to the opposite… Now they may have an A&P on their staff in which case an oil change logbook entry should be signed by the A&P in his personal capacity as an A&P….not by the Repair Station..
The point I was trying to make is that if a NON FAA Certified person or NON FAA Certified Repair Station does ANYTHING to an FAA certified aircraft WITHOUT supervision and log entry by an FAA Certified person or Repair Station, then that aircraft is considered UNAIRWORTHY.
Yes, agreed. The key word is_does_.
An unauthorised logbook entry is merely worthless.
