Yeah, Tim, ..I know. But in my opinion, if the 337 copy is included within the aircraft mx records....the rule is complied with. (The actual Form 337 is sent to the feds, and the copy is kept for the aircraft records.) To my knowlege...there's absolutely no law that requires that the mx records of the airplane be a "logbook" or "bound record" or "book". All the rule requires is that a "record" be kept. Most of us use the little paperback or bound books called "logbooks", but the law does not actually require we use those convenient forms. (Pilot logbooks used to also be required for ATP applicants. For example, the rule USED to say that a military pilot applicant for an ATP must present his flight records in a "bound record" ...which everyone knew and accepted was a "logbook". Military pilots looking for ratings based upon their military experience were greatly inconvenienced because the military kept such records in a computer, and provided the pilot with a computer printout...which was a folding, perforated, pleated document...completely UN-bound. It didn't meet the rule requiring a "bound" logbook. A few clever boys simply went to a shoemaker or saddlemaker and had them use their industrial sewing machine to run a sewn seam up one side so the document could meet the "bound" rule!
![Laughing :lol:](./images/smilies/icon_lol.gif)
The Feds gave up. The rule no longer uses that wording. Now the rule simply uses the phrase - "record".
Similarly, an aircrafts "maintenance records" also do not actually have to be "bound" into a "book". They just have to be kept. (If anyone can show me something thats CURRENT that says otherwise, I'd sure like to see it so I can correct myself.)
Therefore, in my opinion, the act of keeping a copy of the work performed which was documented on a copy of the Form 337 sent to the FAA... and included in the "records" of the aircraft... meet the rule.
There are two FARs which describe the FORM the records must take. Those applicable FARs never use the word "logbook", and are:
43.9 Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records (except inspections performed in accordance with part 91, part 125, §135.411(a)(1), and §135.419 of this chapter).
(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.
(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.
(b) Each holder of an air carrier operating certificate or an operating certificate issued under Part 121 or 135, that is required by its approved operations specifications to provide for a continuous airworthiness maintenance program, shall make a record of the maintenance, preventive maintenance, rebuilding, and alteration, on aircraft, airframes, aircraft engines, propellers, appliances, or component parts which it operates in accordance with the applicable provisions of Part 121 or 135 of this chapter, as appropriate.
(c) This section does not apply to persons performing inspections in accordance with Part 91, 125, §135.411(a)(1), or §135.419 of this chapter.
(d) In addition to the entry required by paragraph (a) of this section, major repairs and major alterations shall be entered on a form, and the form disposed of, in the manner prescribed in appendix B, by the person performing the work.
[Amdt. 43–23, 47 FR 41085, Sept. 16, 1982, as amended by Amdt. 43–37, 66 FR 21066, Apr. 27, 2001; Amdt. 43–39, 69 FR 44863, July 27, 2004]
And:
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, 123, 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.â€
(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.â€
(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.â€
(7) If an inspection is conducted under an inspection program provided for in part 91, 123, 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.
[Amdt. 43–23, 47 FR 41085, Sept. 16, 1982, as amended by Amdt. 43–30, 53 FR 50195, Dec. 13, 1988; Amdt. 43–36, 61 FR 19501, May 1, 1996]