Trust But Verify
Airworthiness Tips for Pilots of Rental and Multi-Owner Aircraft
By Susan Parson
Reprinted with permission from FAA Safety Briefing
Trust, but verify! While President Ronald Reagan popularized this Russian proverb in a very different context, it is also excellent advice for pilots who fly rental or jointly-owned aircraft.
When it comes to owner-flown aircraft, pilots have the advantage of knowing exactly how an aircraft has been operated and maintained. With rental and jointly-owned aircraft, on the other hand, the pilot has to place a certain amount of trust in both the fellow pilots of that aircraft and its owner or operator. After all, the regulations specifically state that the owner or operator of the aircraft has primary responsibility for maintaining it in an airworthy condition (14 CFR 91.403).
However, trust in the owner or operator is not enough to satisfy the FAA or, more importantly, to meet the obligations assigned to the pilot in command (PIC). As PIC, the pilot of an aircraft is the final authority with respect to its operation (14 CFR 91.3) and thus has responsibility for determining that it is in condition for safe flight (14 CFR 91.7). Whether you own, rent from the FBO, or participate in a joint ownership arrangement, you are still obligated to verify that the aircraft you are about to fly is legally airworthy, that is, it conforms to its type design and is safe to fly.
FBOs, flight schools, and well-run flying clubs are usually wise enough to keep the aircraft’s irreplaceable logbooks and maintenance records in a safe place. So, how do you meet this obligation if you do not own the aircraft or have ready access to its logbooks? Here are some tips and a few things to look for before you rent or join a partnership.
Who’s in Charge?
You have probably heard the old saying about an important task involving Everyone, Someone, Anyone, and No One. Everyone was sure that someone would do it. Anyone could have done it, but No One actually did it. The lesson: Safety is not served by confusion about who does what.
Whether it is an FBO rental or a flying club aircraft, you will want to ascertain that there is a specific named organization or individual responsible for maintenance. For example, in my flying club, the bylaws set out roles and responsibilities as follows:
The Maintenance Officer shall be responsible for coordinating and scheduling inspections, general and preventive maintenance, major overhauls, new equipment installations by certified aircraft and power plant mechanics, and compliance with applicable service bulletins. The Maintenance Officer shall ensure that maintenance record entries are completed and that the maintenance records are available in the aircraft.
Notwithstanding any of the above, and as specified in the applicable regulations (14 CFR), each shareholder acting in his capacity as PIC has the final responsibility for ensuring that all required maintenance and inspections have been performed, that applicable and required records are in the aircraft, and that the aircraft is airworthy and in a condition for safe flight each time he flies the aircraft.
Where Are the Documents?
To accommodate the PIC’s need to verify completion of required inspections and maintenance, reputable FBOs and well-run flying clubs generally make an up-to-date airworthiness and maintenance summary sheet available to everyone who flies the aircraft.
When I worked for an FBO several years ago, one of the tasks assigned to the day’s designated operations manager/dispatcher was to record, track, and report this information to renter pilots. Along with the aircraft keys, each pilot received a dispatch sheet listing due dates and/or tach times for all required maintenance and inspection events. The ops manager updated these numbers after every flight.
My flying club takes a similar approach. The organization’s maintenance officer is responsible for safeguarding and maintaining the actual aircraft logbooks. He uses this information to post an up-to-date maintenance, inspection, and airworthiness summary sheet on the club’s scheduling and information Web site. The club’s Web site also includes current weight-and-balance information as well as tips for safe and efficient operation of the aircraft.
The club also keeps a copy of the current airworthiness and maintenance status sheet in the aircraft’s Hobbs book. This book, a loose-leaf notebook that stays in the airplane, includes a number of additional items you should expect to see in any rental or jointly-owned aircraft: log sheets for aircraft usage (Hobbs sheet), VOR accuracy checks, GPS database update, fuel and oil usage, and squawks. You should also ascertain that this package includes insurance information, emergency contact data, and procedures for dealing with malfunctions that occur away from home base.
One potential ‘gotcha’ is worth noting. Part of the preflight inspection is using the ARROW mnemonic to verify that all required documents are aboard: Airworthiness certificate, Registration, Radio Station License (if flown outside the United States), Operating limitations, Weight and balance data. Pilots learn that operating limitations include signs and placards as well as those contained in the approved airplane flight manual (AFM). But, did you know that the operating limitations may also include information contained in the flight manual supplement for any equipment added after the airplane leaves the factory (e.g., an autopilot or an approved IFR GPS or moving map navigator)? Or, that some operating limitations stipulate that GPS and autopilot manuals must be aboard? I have sometimes found these items missing from rental and jointly-owned aircraft, so be sure to check and, as necessary, ask before you aviate.
It is always good to be familiar with the aircraft’s actual logbooks and to know how to find the information you need.
How Do I Know About Squawks?
The in-aircraft package provided by reputable FBOs and flying clubs includes a discrepancy log, more commonly known as the “squawk sheet.” When operating a rental or jointly-owned aircraft, look for a clearly-stated procedure for dealing with discrepancies. The governing regulation is 14 CFR 91.213(d), which addresses inoperative instruments and equipment for aircraft that do not have an approved Minimum Equipment List (MEL). Many FBOs and facilities include a checklist summary of this regulation in the aircraft’s Hobbs book. For example:
- Is the affected equipment required by the aircraft’s type certificate?
- Is the affected equipment listed as required on the aircraft’s equipment list or Kinds of Operation Equipment List (KOEL)?
- Is the affected equipment required for the kind of operation being conducted (e.g., VFR, IFR, night)?
- Is the affected equipment required by any other regulation?
- Is the affected equipment required by an airworthiness directive?
If the answer to any of these questions is yes, then the aircraft must be grounded. If the answer to all of these questions is no, then the last step is to ensure that a qualified person removes or deactivates the affected item and marks it as inoperative. You will want to verify that the FBO or flying club you patronize has a clear method for compliance with this regulation. The FBO where I worked included this checklist in every Hobbs book, but it also had a policy of never dispatching an aircraft with open squawks.
Now that you have a few basic tips for verification, we would love to hear your ideas and most effective practices for ensuring the airworthiness of rental and jointly-owned aircraft.
Susan Parson is a special assistant in the FAA Flight Standards Service and editor of FAA Safety Briefing. She is an active general aviation pilot and flight instructor.
For More Information
The May/June 2009 issue of FAA Aviation News focuses on the FAA’s responsibility to set standards for aircraft certification and airworthiness and the important role that pilots and mechanics play in ensuring safety. You can read it at www.faa.gov/news/safety_briefing/2009/media/mayjun2009.pdf.