LEGAL CORNER


Documenting the Annual Inspection


By Gregory J. Reigel


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, fi rst it is important to


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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. Specifi cally, that section requires that an annual inspection be performed using a checklist


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s 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


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


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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 specifi ed 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


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