Pinger 2015

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U.S. Department o f Transportatton Federal Aviation Administration OCT 20 2015 Kevin R Pinger Office of the Chief Counsel 800 Independence Ave., S.W.

Washington, D.C. 20591

Re: Legal Interpretation on Wbetber 14 C.F.R. § 43.11, or Any Other Regulation, Requires the Maintenance Record Entry Approving an Aircraft for Return to Service Following an Annual Inspection to State the Inspection was Performed in Accordance with Appendix D to Part 43

Dear Mr. Pinger:

We recently received your request for interpretation of Title 14 Code of Federal Regulations (14 C.F.R.) § 43.11. Specifically, you asked whether§ 43.11 or any other regulation requires that a logbook entry for an annual inspection state that the inspection was performed "in accordance with Part 43 Appendix D." The answer is no. You also provided an airframe logbook entry and asked whether it met the requirements of§ 43 .11. Based on our review of your entry and the regulation, the entry meets the elements set forth in § 43 . 11 (a) ( 1) through (4 ), for the approval for return to service of an aircraft determined to be in an airworthy condition following completion of an annual inspectio11.

As to your first question, 14 CFR § 43 .11 (a) states, in pe1t inent part, that the person approving or disapproving an aircraft for return to seTVice after an amrnal inspection sh al I make an entry in the maintenance record of that aircraft containing tbe following information: (1) The type of inspection and a bdef 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 retum to service the aircraft .... (4) [I]f the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement- "l certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition."

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Section 43 .1 1 does not explicitly require t hat the logbook entry for an annual inspection state that it was performed "in accordance with Part 43 Appendix D." Section 43.11 does not state the scope for an annual inspection under pa1t 43, rather§ 43.15 provides details on the requirements of the inspection. Section 43.15(c) states:

(c) Annual and 100-hour inspections. (1) Each person performing an annual or 100-hour inspection shall use a checklist while performing the inspection. The checklist may be of the person's own design, one provided by the manufacturer of the equipment being inspected or one obtained from another source. This checklist must include the scope and detai l of the items contained in appendix D to th.is part and paragraph (b) of this section.

Any checklist utilized in performing an annual inspection must contain at least the scope and detail of the items contained in appendix D, as required by§ 43.15; however, the maintenance record entry does not have to state that. If the Piper P A28- l 81 manual 100 hour check list you used as a guide contains at least the scope and detail of the appendix D items, you have complied with§ 43.15. Moreover,§ 43. l l(a)(4) requires only that the referenced statement "or a similarly worded statement" be used. It is our opinion that your signed statement that "[t]his aircraft is in an airworthy condition and approved for return to service" meets the certification requirement of the regulation.

I hope th.is information has been helpful. This response was coordinated with the Aircraft Maintenance Division (AFS-300) in the FAA's Flight Standards Service. If you have further questions concerning this response, please contact Sabrina Jawed on my staff at 202-267-3073.

Sincerely,

cf~~ Lorelei Peter Acting Assistant Chief Counsel for Regulations, AGC-200