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Out of curiosity, where does it say that?

 

Part 43. Have you read it?

 

43.5(a) requires the maintenance record entry.

 

91.417(B)(2) requires that the maintenance entry be retained until superceded, or at least one year after the work has been performed. While there is value in maintaining a permanent record of 100 hour inspections and annuals, showing compliance with the maintenance of the aircraft, airworthiness directives, alterations and major repairs and modifications, etc, and keeping that log for the lifetime of the aircraft, there is little value in maintaining a lengthy permanent record that says "removed X. Reinstalled X. Removed X again. Reinstalled X again. Removed X once more. Reinstalled X one more time, ad infinitum."

 

The same form you have for writing up a squawk will generally have a place to sign the form, then a place to show the disposition and status of the writeup. Is it deferred? Has it been repaired? Did you remove something that you are entitled to remove and did you put it back? Do you really want those repeat, routine removals in the permanent record? You're not required to put them there, and a temporary record that's kept until superceded for such items is standard, and is usually maintained in on ongoing maintenance log in the aircraft, later transferred to other records, or disposed, as necessary.

 

So on the same daily squawk sheet that I might write "red position light out" I'm supposed to write that I took the dual controls out and right door off and have w & b figures to show the aircraft still within limits, then when I get back I need to write that I put them both back on?

 

 

 

If that's the format that your school, company, or rental facility uses, then yes. Many operators use a squawk for that has a place to enter a discrepancy, then a place adjacent to that for a repair entry, or a deferral under the MEL, etc. The discrepancy log (goes under a number of different names) IS part of the aircraft maintenance record, but generally constitutes a temporary one. Items entered there that need to be kept permanently are generally also completed separately in the permanent aircraft maintenance record. In this case, you don't need a permanent record that the controls or door have been removed.

 

The weight and balance is a separate matter. The aircraft must be weighed periodically and a record kept of its weight and center of gravity. This record is generally kept as a signed document in the aircraft flight manual in light aircraft, and is unique to that specific aircraft. For aircraft that see routine configuration changes, sometimes it's weighed twice with both configuration changes with a separate document for both, but more commonly it's calculated to show the empty weight/CG with and without the configuration change.

 

If the documentation for the aircraft you fly doesn't include that, because you've actually changed the configuration of the aircraft and not simply added fuel or baggage or passengers, the weight and balance document must be amended. That is over and above any weight and balance calculations you do; by performing maintenance and removing structure, even if it's just a radio, you need to amend the weight and balance document.

 

If you're not certificated to make that amendment, then you need someone who is, which is why operators who make frequent configuration changes have already got that paperwork done for both configurations (or each configuration, if more than two).

 

Remember, while the flight manual may provide for door-off operation, or removal of flight controls, that does not give you authority to do so. It's authorization for operation of the aircraft in that configuration. What it is NOT is authorization for you to do the work. Likewise, when other requirements occur, such as amending the weight and balance, the fact that the work needs to be done does not authorize you to do it.

 

Review Part 43. You should be teaching it to your students, and regardless of whether you fly privately, instruct, or fly commercially, you should be very familiar with Part 43 and 91. You're responsible for it when you fly, and if you happen to be an owner/operator, you're responsible for it at all times. If you're simply flying it, you're responsible for ensuring that the aircraft is airworthy, and that does include the maintenance records necessary to make it so, whether you review them, or take a risk and trust someone else who does.

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We utilize a technical logbook or “Tech Log” for each of our machines. This log includes inspection times, AD compliance times, preflight sign offs and such. This sheet includes a “Preflight Action” section and a “Discrepancy” section with a corresponding “Corrective Action” section. On an additional page we have an “Equipment Sign-off” sheet which includes removal/installation of dual controls, seat reconfigurations, nightsun removal/installations, etc, and as already stated, it becomes a permanent record for which we keep foeveah (as AvBug pointed out). On this form is a statement that the signee has been trained and approved to complete the task and has recalculated W&B. Each reconfiguration requires a sign-off. We also keep documentation of the training each crewmember has undergone to appropriately accomplish these tasks. We also utilize a separate discrepancy maintenance record which the PIC must go into further detail regarding any deferred issues i.e. the “what”, “when” “why” and “how” information with a suggested corrective action and the actual action taken to return the machine to service.…..

 

It’s all about CYA…..

Edited by Spike
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Part 43. Have you read it?

 

43.5(a) requires the maintenance record entry.

 

What's Part 43? Guess I'll give it a try....I'm reading..."shall make an entry in the maintenance record..." I'm not seeing "annotate in any official or non official maintenance record". Listen, I'm not saying you're wrong, because god knows you know your stuff better than I do, and half the people on here. I'm just trying to get the correct information so we can better ourselves as a flight school.

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We utilize a technical logbook or “Tech Log” for each of our machines. This log includes inspection times, AD compliance times, preflight sign offs and such. This sheet includes a “Preflight Action” section and a “Discrepancy” section with a corresponding “Corrective Action” section. On an additional page we have an “Equipment Sign-off” sheet which includes removal/installation of dual controls, seat reconfigurations, nightsun removal/installations, etc, and as already stated, it becomes a permanent record for which we keep foeveah (as AvBug pointed out). On this form is a statement that the signee has been trained and approved to complete the task and has recalculated W&B. Each reconfiguration requires a sign-off. We also keep documentation of the training each crewmember has undergone to appropriately accomplish these tasks. We also utilize a separate discrepancy maintenance record which the PIC must go into further detail regarding any deferred issues i.e. the “what”, “when” “why” and “how” information with a suggested corrective action and the actual action taken to return the machine to service.…..

 

It’s all about CYA…..

 

I like that system. We're having a meeting tomorrow and I think I'll bring something like that up. A sheet that has everything on it, Configurations, Weight and Balance (doors on and off), Squawks. Sounds pretty cool.

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What's Part 43? Guess I'll give it a try....I'm reading..."shall make an entry in the maintenance record..." I'm not seeing "annotate in any official or non official maintenance record". Listen, I'm not saying you're wrong, because god knows you know your stuff better than I do, and half the people on here. I'm just trying to get the correct information so we can better ourselves as a flight school.

 

You're already familiar with Parts 61 and 91, to some degree, as they set forth your privileges and operating limitations as a private pilot, instructor, commercial pilot, and so on. Part 43 is another subpart of Title 14 of the Code of Federal Regulations, usually referred to in short as 14 CFR 43, and often simply incorrectly called "The FAR's".

 

Part 43 governs maintenance, is it's something that every student needs to be taught, because it has a direct bearing on the airworthiness and maintenance of the machine that they fly.

 

Students should also be made familiar with AC 43.13, which is the acceptable techniques and methods of repair. When you see a fiberlock nut, do you know how many threads must be protruding above the fiberlock? How about the correct installation of safety wire, or a cotter pin? Where can fiber lock be used, and where can it not be used? What about a crack in plexiglass? How do you tell on inspection if a clevis is installed correctly? What is acceptable, and what is not? How do you know if it's airworthy? Every student ought to know this, and it's found in the advisory circular. When I was learning to fly, we made it required reading, and we were expected to know the contents of that manual.

 

Likewise, many students have never seen the maintenance publications; they should. Most are content, as are their instructors, with the dumbed-down information found in the aircraft flight manual. There's more to the aircraft, and getting to know the aircraft and it's systems may be crucial to one's survival. There have been many time for me over the years when knowing my aircraft paid off in big dividends. It's why I'm here to type this now.

 

The system described by Spike is fairly standard for charter and other operations, and many corporate offices work the same way. Government operations expect to see this too, especially for contractors. Part 135 operators nearly all have something very similar.

 

Something you won't find in the books, that I always tell every student, is to carry a camera. It's common today with everyone carrying a smart phone, but when you have a discrepancy, try to get a picture. It might be damage, it might be a leak. Get a picture. I've worked for companies that liked to try to make writeups disappear. I always make photocopies of my writeups, and if I'm not in a place to do it, I take photographs. Photographs taken at the time have saved my bacon on more than a few occasions.

 

Some years ago overseas, some damage occurred to an aircraft. The maintenance department was adamant that it was pilot error. I inspected the aircraft and took a lot of photographs. I found a broken control rod with a clevis end, attached to a fitting on a surface; the fitting was broken in two. It was secured with four bolt holes, but two bolts on the broken part were missing, and the paint where they should have been was undisturbed. The nutplates where the bolts should have been showed no thread damage, and I was able to determine that maintenance had failed to install two of the four bolts. The pictures proved it. After a week long grounding and dispute, the maintenance department came clean and admitted that it wasn't pilot error. At stake was my job, as well as my reputation, and future career. A few simple photos can save you and will do more to back up your story than any length of narrative.

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Still wondering where it says a Squawk Sheet is a legal Maintenance Record

 

Squawk sheet is a generic term for discrepancy sheet, list or log.

 

 

§43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.

 

(a) Maintenance record entries. The 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, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:

 

(1) The type of inspection and a brief description of the extent of the inspection.

 

(2) The date of the inspection and aircraft total time in service.

 

(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.

 

(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”

 

(5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator.”

 

(6) For progressive inspections, the following or a similarly worded statement—“I certify that in accordance with a progressive inspection program, a routine inspection of (identify whether aircraft or components) and a detailed inspection of (identify components) were performed and the (aircraft or components) are (approved or disapproved) for return to service.” If disapproved, the entry will further state “and a list of discrepancies and unairworthy items dated (date) has been provided to the aircraft owner or operator.”

 

(7) If an inspection is conducted under an inspection program provided for in part 91, 125, or §135.411(a)(1), the entry must identify the inspection program, that part of the inspection program accomplished, and contain a statement that the inspection was performed in accordance with the inspections and procedures for that particular program.

 

( b )Listing of discrepancies and placards. If the person performing any inspection required by part 91 or 125 or §135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicable type certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that persons must give the owner or lessee a signed and dated list of those discrepancies. For those items permitted to be inoperative under §91.213(d)(2) of this chapter, that person shall place a placard, that meets the aircraft's airworthiness certification regulations, on each inoperative instrument and the cockpit control of each item of inoperative equipment, marking it “Inoperative,” and shall add the items to the signed and dated list of discrepancies given to the owner or lessee.

 

Edited by Spike

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The maintenance entries can be (and often are) put on stickers that are put into a logbook; they may be written on a note, put in the "squawk sheet" or "airworthiness log" that's kept in the airplane, etc.

 

Most airlines, in fact all airlines, use a very similar system to what Spike described. Each page, generally having three places for a maintenance write-uip, in the discrepancy log or airworthiness log (or "squawk sheet") will have room for the pilot or mechanic to write something up, and then room for it to be deferred or signed off by maintenance personnel. Sometimes that form is kept separately from the flight log, but more often it's on the same sheet of paper. Generally the crew will keep copies of the last ten pages or so on board, with everything else returned to the company to go into the records.

 

Not only is that process common, but approved, and is the chief means of record keeping in most airline and charter operations.

 

Still wondering where it says a Squawk Sheet is a legal Maintenance Record.

 

 

Did you review 91.417, as previously given?

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Guest pokey

Sec. 91.417

Maintenance records.

(a) Except for work performed in accordance with Secs. 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (B) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include--
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.
[ (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the
next action is required.]
(vi) Copies of the forms prescribed by Sec. 43.9(a) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
(B) The owner or operator shall retain the following records for the periods prescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under Sec. 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
© The owner or operator shall make all maintenance records required to be kept by this section available for inspection by the Administrator or any authorized representative of the National Transportation Safety Board (NTSB). In addition, the owner or operator shall present Form 337 described in paragraph (d) of this section for inspection upon request of any law
enforcement officer.
(d) When a fuel tank is installed within the passenger compartment or a baggage compartment pursuant to part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner or operator.




Amdt. 91-311, Eff. 4/2/10

expand.gifComments

collapse.gifDocument History
Notice of Proposed Rulemaking Actions:
Not Applicable.

Final Rule Actions:
Final Rule. Docket No. 2007-29015; Issued on 1/22/10

 

here is what 91,417 really says,,, read it with a healthy dose of bugspray and enjoy :D

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The real problem, as Avbug points out, is that the FAA really doesn't specify any standard way of making logbook entries. The typical little airframe and engine logbooks that we sometimes see are nice, but they are not required. All the FAA really requires is that a reliable record be kept.

 

Some years ago I worked for an operator that came under scrutiny of the FAA. Their contention was that a particular modification to an engine (via Service Bulletin) was not done. It involved converting a RR-250-C20 to a -C20B. Our contention was that the mod *had* been done and properly signed-off. We presented our evidence, and the FAA could not dispute it even though the format that the mechanic used to make the entry was not "conventional." Our stance was simple: "Show us where the FAA spells out how maintenance entries have to be made." They could not. As long as the entires *are* made, and the records *are* kept, then you're good to go. In this case, we prevailed.

 

The situation got me thinking about logbook entries, how vague the FAA's guidance on them is, and specifically how they relate to us pilots (I'm not an A&P).

 

If you remove the doors from your helicopter and thus change the empty weight c.g. even a tiny bit (no matter what FAR part you operate under), then you better reflect that in the aircraft's W&B page *and* you better make a record noting the door removal in the "logbook." To us pilots it might seem insignificant. But to the FAA, such things are VERY significant.

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Guest pokey

very true NR, and? they don't say where the entry has to be made, my one instructor in A&P school eons ago, told us that we could even make a logbook entry on the bathroom door, as long as we gave it to the owner/operator. (BTW) he was also the one who, on my 1st day of class said: "once you graduate with your shiny new license, do NOT think that you can go out and ground an aircraft, ONLY the FAA has that authority" :P

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Referenced for the third time, 91.417( B)(1):

 

§91.417 Maintenance records.

( B) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

The informed operator retains the records indefinitely; it's the only record or evidence that the work had been done and properly signed off, and is a snapshot in time. The FAA always has the option of revisiting an allegation or complaint; I've avoided difficulties in the past precisely because I did have the records to back me up, when the FAA came calling.
--for whatever reason, the software here won't allow the proper citation of the regulation without turning it into an emoticon. It should be 91.417 ( b ) ( 1 )
Edited by avbug

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If you remove the doors from your helicopter and thus change the empty weight c.g. even a tiny bit (no matter what FAR part you operate under), then you better reflect that in the aircraft's W&B page *and* you better make a record noting the door removal in the "logbook." To us pilots it might seem insignificant. But to the FAA, such things are VERY significant.

 

 

This issue must have come up at robinson at some point, because during my initial training in the r22 we had no figures for the doors or removable controls. Then one day there was an RFM revision sent out which included their weight and position. However beyond calculating a w & b for each flight I've never seen an r22's w & b page (the one specific to that aircraft) that accounted for doors and/or controls removal, and I've flown quite a few of them?

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Guest pokey

 

Referenced for the third time, 91.417( B)(1):

 

 

 

 

 

the 3rd time is a charm, what part of it do you think we don't understand?

 

son of a !! i'm outtah bugspray again

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Alright peeps, where does it say that the valid Weight and Balance has to be present in the POH? For the 300 for example, the only place we can find is that on the Type Certificate, under the notes section, it says "has to be provided". We cannot find anything (Like 91.9 (B)(1) for the POH) that specifies that a current weight and balance data sheet has to be in the POH.

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Alright peeps, where does it say that the valid Weight and Balance has to be present in the POH? For the 300 for example, the only place we can find is that on the Type Certificate, under the notes section, it says "has to be provided". We cannot find anything (Like 91.9 ( B)(1) for the POH) that specifies that a current weight and balance data sheet has to be in the POH.

 

 

Don't know about the 300 it may have been certified under a different part, like the 206, but when I looked for it regarding the r22 the closest I got was 27.1581-27.1589 that mentions "loading info" must be in the rotorcraft flight manual.

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Alright peeps, where does it say that the valid Weight and Balance has to be present in the POH? For the 300 for example, the only place we can find is that on the Type Certificate, under the notes section, it says "has to be provided". We cannot find anything (Like 91.9 ( B)(1) for the POH) that specifies that a current weight and balance data sheet has to be in the POH.

 

14 CFR 23.1581 sets the initial requirement for weight and balance data inclusion in the aircraft flight manual or pilot operating handbook.

 

Any data placed in the AFM must be kept current, to include manufacturer updates and revisions, changes in airworthiness requirements or limitations, procedures, added equipment or system changes or modifications, and additionally, updates to the weight and balance.

 

Additionally, 23.1589 sets a requirement for loading information, including each item or piece of equipment that can be easily removed, relocated, or replaced (such as doors), in the AFM.

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Not sure I understand this. Why would the normal category airplane certification requirements carry over to Part 27 normal category rotorcraft certification? I can see this pertaining to the Weight and Balance sections in the aircraft's POH but not the W&B done by maintenance. It mentions, "The weight and center of gravity limits required by 27.25 and 27.27, respectively, must be furnished." To me this means made availible to the buyer, owner / operator, but this doesn't read in the POH as a maintenance weight. Just as a section suplied in the POH, which there is.

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Not sure I understand this. Why would the normal category airplane certification requirements carry over to Part 27 normal category rotorcraft certification? I can see this pertaining to the Weight and Balance sections in the aircraft's POH but not the W&B done by maintenance. It mentions, "The weight and center of gravity limits required by 27.25 and 27.27, respectively, must be furnished." To me this means made availible to the buyer, owner / operator, but this doesn't read in the POH as a maintenance weight. Just as a section suplied in the POH, which there is.

Take a look at the following: (As Astro in the post 41 has already quoted)

 

14 CFR 21.5 and 14 CFR 27.1581

 

The Bell 206 and S300 (269s) started under CAR 6

 

Chapter 1—Civil Aeronautics Board

Subchapter A —Civil Air Regulations

Part 6 —Rotorcraft Airworthiness; Normal Category

 

See §6.740 and §6.741

 

 

Civil Aeronautics Regulations

Edited by iChris

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21.5 says that a POH must be made availible to owner at time of deliver, and that it must contain the following info.... Limitation, Placards, Max temp demonstrated for engine cooling.... And 27.1581 says that a POH must be in the aircraft (hence 91.9 b 2), also it states the things that the POH has to show... I'm sorry, but maybe I'm just not reading it right or something, but I do not see anything that says the "maintenance W&B" needs to be in the POH. Just the W&B stuff that is already furnished in the POH by the manufacturer.

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I'm sorry, but maybe I'm just not reading it right or something, but I do not see anything that says the "maintenance W&B" needs to be in the POH. Just the W&B stuff that is already furnished in the POH by the manufacturer.

 

You don’t see it because you're looking for the wrong format. Some commercial operations require specific guidelines on how the W&B is determined. Some even require hard copies or recordkeeping of all W&B determinations.

 

As an example, commercial operations are issued operations specifications with regard to W&B calculations, like A096 – A099, or E096.

 

§27.1581 General.

 

(a) Furnishing information. A Rotorcraft Flight Manual must be furnished with each rotorcraft, and it must contain the following..

 

Information and data must be provide to allow you to made a determination by calculation of the current W&B prior to flight, to ensure you remain within the aircraft’s limitations.

 

They provide the information and data; you complete the W&B and keep the W&B record (aka Chart C) current in the RFM.

 

The W&B record (aka Chart C) and the "Actual Weight Record" are included and current with all new aircraft.

 

 

It mentions, "The weight and center of gravity limits required by 27.25 and 27.27, respectively, must be furnished." To me this means made availible to the buyer, owner / operator, but this doesn't read in the POH as a maintenance weight. Just as a section suplied in the POH, which there is.

 

That's it, You got it. It's that page in the R22 RFM that maintenance keeps current. This is your running record of weight and center of gravity.

 

The problem is some students in these flight schools have never looked inside the helicopters actual RFM. Schools have you buy off the shelf copies and you just pencil in the weight and CG for each aircraft, you don’t learn were to find the real information.

 

Schools don’t want a bunch of students tearing through their original RFM that includes all the official information, which may include copies of STCs, RFM supplements, W&B record (aka Chart C), Equipment List (aka Chart A) and other information applicable to that specific aircraft.

 

Pagesfromr22_poh_6_unlocked_zps72c352cd.

 

N3276K_Wieght_Balance_Page_1_zps7e5115cf

Scan-1_zps041755c3.jpg

Screenshot2014-05-03at71110PM_zpsda99250

Edited by iChris

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I'm sorry, but maybe I'm just not reading it right or something, but I do not see anything that says the "maintenance W&B" needs to be in the POH. Just the W&B stuff that is already furnished in the POH by the manufacturer.

 

There is no “maintenance W&B”. In the RFM, it’s the W&B. And, the W&B which is provides the particular aircrafts current W&B information which is maintained by the maintenance folks. Over time and when equipment changes are made, each previous W&B is superseded and a new recalculated W&B is provided so the pilot has the most up-to-date information. After that, you as a pilot must compute the W&B for each flight per 91……

 

Just out of curiosity, with all of this great information provided, what are you going to do with it and why?

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Sorry guys. Still confused. So you are all saying that the W&B section of a POH that contains all that good (Part 27) required stuff is the same as the W&B sheets that maintenance provides that is ADDED to the POH. It's one in the same. Not two separate entities. Because to me all Part 27 talks about is the POH W&B section. P.S. I need this info for check rides. Our examiners apparently want our students to know how to build and certify an aircraft per part 27 and be an A&P.

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So if an examiner asks one of my students why the W&B sheets (updated by Maint, not part of the manufacturers W&B section) have to be in the POH, they can say Part 27 and that will be the end of it?

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So if an examiner asks one of my students why the W&B sheets (updated by Maint, not part of the manufacturers W&B section) have to be in the POH, they can say Part 27 and that will be the end of it?

 

Because it provides the most current W&B information for calculating W&B and provides the equipment list for installed equipment…….

 

IMO, the examiner is seeing if the applicant understands where the current info is kept and, (more importantly) where the equipment list is located as most training operators do not maintain an MEL. Again, IMO, nothing to do with 27……

Edited by Spike

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