Aircraft documentation requirements

Do I need to keep a detailed record of every shop visit and what was done?
You need to keep the aircraft/engine/prop logbooks with adequate records of what was done, but not necessarily a copy of all shop records. For example, when we overhaul an engine, we put a sticker in the logbook that says we, maintenance organisation No. XX.XX.XXXX, have overhauled and bench-tested the engine No. XXXXXX at XXX hours TTSN/SMOH in accordance to such and such documentation, and certify it as airworthy, and issue an EASA Form 1, which also gets stapled into the logbook. This is sufficient. Meanwhile, our shop documentation for this overhaul is a folder 1-2 cm thick – you don’t have to have that.

Which installed items need documentation of their origins (from small stuff like hoses or door struts to beacons, avionics, etc)?
Technically, all of them, except the standard parts like screws or light bulbs. The usual evidence is Form 1, but for non-critical parts in a private aircraft you can sign a form that you approve the installation of a part without Form 1.

Is it a problem if I don’t have a detailed journey log from day one?
No. You only have to keep a journey log for the last 6 months. You need to carry over the journey log into the aircraft technical logbook, but you don’t need all the details. It’s usually one line per flying day (time and landings), but I’ve seen logbooks with one line per month.

What documentation gotchas could render the aircraft unairworthy?
Most importantly, missing records of changes that can be discovered later. If you installed anything new or if you replaced a component with a serial number, and this is not recorded in the logbook, an airworthiness inspector may ground your aircraft until you provide records traceable to the shop records of the organisation that did it.

From what I’m seeing in these records, I’m thinking I should put the airplane on CAMO just because of my ignorance. Am I overreacting?
No, CAMO is just one of the ways to manage the airworthiness. It can also be a freelance engineer holding an appropriate authorisation – the airworthiness review process is exactly the same.

Ultranomad wrote:

Meanwhile, our shop documentation for this overhaul is a folder 1-2 cm thick – you don’t have to have that.

You don’t need to have it… if you’re nuts

Don’t let a place that worked on your plane retain the aircraft records. The airframe, engine and prop logbooks themselves do not need to contain every piece of documentation on the inspection, airworthiness etc of every part installed but in order to maintain resale value as much as possible of that info can and should be maintained in separate records controlled by the current owner and passed on to any new owner with the sale. This typically means 3 ring binders with that backup info. The workshop may have its own regulatory obligation to maintain records of the work, but that is a separate issue and the owner should not in any way be relying on anybody else to maintain aircraft records that he or a subsequent owner may want to access in the future.

@Silvaire, while I agree with you in principle, some documents have a negligibly small influence on airworthiness or resale value. In the case I described, about half of the engine overhaul folder is taken up by measurement records. For example, I do 28 measurements on every connecting rod, 15 on every piston, 55 on a six-cylinder crankshaft, etc. – all these data go into the folder. The parts are then reconditioned or replaced as necessary, the engine is assembled and subjected to a 5-hour bench test. At the end, we issue a Form 1 (an equivalent of FAA form 8130), by which we as an organisation assume responsibility for the airworthiness of the engine. For as long as I’ve been working here, not a single customer requested a copy of our internal folder. If there were an aircraft accident and an investigation found reasons to suspect our workmanship, this is where the folder would be looked at. Our CAA may also look at one or two at random during a yearly audit. That’s about it.

Ultranomad wrote:

For example, I do 28 measurements on every connecting rod, 15 on every piston, 55 on a six-cylinder crankshaft, etc. – all these data go into the folder. The parts are then reconditioned or replaced as necessary, the engine is assembled and subjected to a 5-hour bench test. At the end, we issue a Form 1 (an equivalent of FAA form 8130), by which we as an organisation assume responsibility for the airworthiness of the engine.

Sure, I understand that the inspection record for a connecting rod is part of the overhaul shop’s internal process. However, the resulting Form 1 or 8130 for the connecting rod and every other part in the engine individually is the property of the aircraft owner and should be retained in his aircraft records. This is separate than the overall engine overhaul logbook entry, which is also held by the owner.

The market value for an overhauled engine that is not backed up by a ‘stack of 8130s’ is far less than one for which that documentation is provided. The engine logbook entry does not provide the fidelity of data to understand exactly what kind of overhaul was done, and the regulatory definition of overhaul is a minimal process from which a typical overhaul shop expands in cooperation with the customer. There are choices to be made that still comply with regulation and overhaul manual. Showing via a logbook entry that “it was done by a reputable shop” has close to zero market value to an educated buyer without e.g. the 8130s showing the status of each major part individually.

Silvaire wrote:

However, the resulting Form 1 or 8130 for the connecting rod and every other part in the engine individually is the property of the aircraft owner and should be retained in his aircraft records. This is separate than the overall engine overhaul logbook entry, which is also held by the owner.

Sure, but only if the Form 1 as such is issued. Not sure about FAA, but EASA regulations say a Form 1 need not be issued if the reconditioned part is installed by the same organisation that repaired it without ever leaving the shop. If a serviceable or reconditioned part comes from our stock, there will be a green or yellow tag in the folder, but if a part goes back into the same engine it came from, then it’s covered by the Form 1 for the entire engine and no other certificate is issued.

Each part has a tag of some kind after the inspection that leads to its reuse in the engine. That tag is the property of the guy who owns that part and paid for the work.

Do I need to keep a detailed record of every shop visit and what was done?

No. Only maintenance actions need to be recorded, and practically speaking only if it is legally required maintenance (e.g. if you thought you have a bad spark plug and changed it, it doesn’t matter if this is recorded or not).

Which installed items need documentation of their origins (from small stuff like hoses or door struts to beacons, avionics, etc)?

A huge topic There is this for example. But generally I keep the stuff. I have a box file and each Annual’s paperwork gets chucked in there, in a clear plastic sleeve for each Annual. If some actions are done during the year, e.g. alternator swapped, then I keep the form which came with that. But I don’t keep the EASA-1 forms which might come with engine oil; people would just laugh at me, and the only people who do that are the ones who wear yellow jackets while having lunch at Le Touquet

Is it a problem if I don’t have a detailed journey log from day one?

Ah, the journey log debate You should probably keep one, unless you can avoid landing in France

What documentation gotchas could render the aircraft unairworthy?

On an N-reg, you must have the originals of the CofA, CofR, and, on any reg, if you can’t prove legally required periodic or AD-mandated maintenance actions then you basically can’t fly it. Same with proof of import VAT paid… that one is one very big sleeping dog which most people don’t want to poke too much.

I have an N-reg related list here and a lot of it will be applicable to EASA-reg.

An aircraft owner should request and keep the work pack for any major maintenance action e.g.

• the Annual
• any intermediate service
• overhaul of any major item (the engine, a magneto, a propeller, a governor, a gear pump, etc)

And absolutely always keep all logbooks – do not let a maintenance company keep them. The MC should produce a “logbook insert” which you glue into the airframe logbook yourself

Re the comment on work packs, I almost never disagree with Ultranomad (because he knows his stuff) but from my experience the work pack thing is valuable where somebody smells a rat. For example, there are or have been many disreputable maintenance companies, and when their record becomes generally known (often this can be years, because they read forums, or their friends do, and they always threaten litigation) buyers can get suspicious. For example mentioned here. If I was buying a plane, I would probably overhaul the engine regardless, before flying it, but most people aren’t going to do that, but the smarter ones will be quite interested in who overhauled the engine and what exactly they did. The cost to you is zero; the work pack is your property, it is just an A4 envelope, and a refusal to deliver it rings massive alarm bells. I am sure the % of crooks in GA maintenance is below 50% but there are just too many…

Peter wrote:

Re the comment on work packs, I almost never disagree with Ultranomad (because he knows his stuff) but from my experience an aircraft owner should request and keep the work pack for any major maintenance action
(…)
And absolutely always keep all logbooks – do not let a maintenance company keep them. The MC should produce a “logbook insert” which you glue into the airframe logbook yourself

The workpack and all the logbooks – yes, absolutely, we aren’t in disagreement on that. I would also include defect reports and functional test reports. What I would leave at the shop is the documents that are only of use to that specific shop or technician.

Remember that the important thing is traceability.
Every time you change something significant, a component or spare part, you want evidence of that.
What I have learned is that there are many different ideas of what to keep and not. And if you wants someone’s signature you need to know what that person wants to see.

If you read ML.A.801 in Part-ML you will see what EASA requires when maintenance has been completed. A signature is actually not mandatory which means that you can enter the work yourself in the maintenance log of the aircraft. As long as you have the necessary info.
However, we get a signed work pack from our workshop and I just refer to that.