Common Aircraft Paperwork Errors
It’s the first nice day of spring and you can’t wait to pull your airplane out and go flying—but is your airplane ready? Sure, you’ve checked the oil and flight controls, but have you checked your paperwork? As an FAA- and EASA-certified repair station, we see a wide variety of aircraft come through our hangar doors. With that comes some common paperwork errors that both pilots and owner/operators should be watching for.
As pilot-in-command, you are responsible for determining if an aircraft is in airworthy condition prior to each flight (FAR 91.7). FAA Order 8130.2G defines "airworthy" and lists two conditions necessary to meet the definition.
1.) The aircraft must conform to its type design. Conformity to the type design is considered attained when the aircraft configuration and the engine, propeller, and articles installed are consistent with the drawings, specifications, and other data that are part of the Type Certificate (TC). This includes any Supplemental Type Certificates (STC) and repairs and alterations incorporated into the aircraft.
2.) The aircraft must be in a condition for safe operation. This refers to the condition of the aircraft relative to wear and deterioration; for example, skin corrosion, window delamination/crazing, fluid leaks, and tire wear.
Both conditions must be met for the aircraft to meet the definition of airworthy, so if the paperwork is not correct, the aircraft is not airworthy.
The aircraft’s maintenance records consist of many pieces, including airframe logs, engine logs, propeller logs, and modification and repair documentation. Some of the items that must be present include STCs, which are approvals for modifications to a particular aircraft; this means that they are serial-number specific. If the STC is not present in the paperwork or does not reference the correct aircraft, the modification is illegal.
Don’t forget that a current Airplane Flight Manual (AFM), commonly referred to as the Pilots Operating Handbook (POH), is required to be in all aircraft for which it is available. Remember that the AFM is serial number-specific, whereas a Pilots Information Manual (PIM) contains generic information that will not reflect the exact configuration of the aircraft. The POH typically contains an AFM section that is specific to the particular aircraft and its configuration. Another important item is an Airplane Flight Manual Supplement (AFMS) for aircraft with modifications requiring an AFMS. The AFMS addresses characteristics and considerations particular to a modification that the pilot must be familiar with. This supplement must be included with the AFM. Per Advisory Circular AC60-6B, the AFM, approved manual materials, markings, and placards "must be current and available in the airplane during operation." Note: Airplane Flight Manuals were not required for most light aircraft manufactured prior to March 1, 1979.
Remember, the owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition (FAR 91.403). This means the owner/operator must properly communicate the work that must be performed on the aircraft to maintain its airworthiness, as well as ensure that it has been completed and signed off correctly by the maintenance provider. Don’t get this confused with FAR 91.7, which states that it is the pilot-in-command’s responsibility to determine that the aircraft is in an airworthy condition before flying it. If you are the owner and pilot, both responsibilities fall on your shoulders.
If you fly or operate a turbine aircraft, tracking time as well as cycles is vital. A cycle is defined as one landing and one takeoff. This is a different requirement than is present for piston aircraft, so be sure to monitor this if you are transitioning to a turbine aircraft. It’s a change of pace that is easily overlooked, but necessary for tracking life-limited parts. Recall that both airframe and engine components can be life-limited and should be tracked accordingly.
Another simple one that we encounter is the annual inspection requirement. Per FAR 91.409, "no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by 43.7 of this chapter." The key term here is "12 calendar months." While this topic is covered on the pilot knowledge tests, it can be easy to forget. If your last annual
inspection was performed and signed off on May 15, 2012, your next annual is due at the end of the month in which the previous inspection was signed off—or May 31, 2013 in this case. If your authorized inspector finds a lengthy list of discrepancies to fix and doesn’t sign the airplane off until June 3, 2013, your next annual is now due by the end of June 2014.
Your aircraft maintenance provider works to ensure that your aircraft has the proper paperwork to return to service, but only you ,as the owner/operator, know the full story, especially if the aircraft has been to multiple service providers. As a pilot, you should be familiar with the records for both determining airworthiness prior to flying, as well as for learning about your aircraft. We wish you a safe season of legal flying!