Thanks for the replies. Good point about not being required to retain logs. But here's the thing..

First, the owner does have the logs and there's nothing in there regarding a repair after the date of the accident. That makes this an undocumented repair. Ok, maybe so what?

But, second, there's no 337 with the owner's records. It seems "substantial damage" should have generated one. So maybe the so what concept gets more serious?

I ordered the records/title search on Friday, should have the 337's the FAA has on Monday.

I also sent an email to my ASI regarding this as a generic situation so we'll see what he says.

Will post more.

Thanks again.

There could be several scenarios there, but I totally understand your concerns. Ultimately, if questions persist as to airworthiness, the owner could hire a DAR to verify airworthiness. That'd cost some $$$, but would make the damage history and repairs a moot point, at least as far as the FAA is concerned.

MTV

I’d look at it like your job is to verify airworthiness as a snapshot at present time, not the provenance of the serial number.

Right. Airworthiness is the issue. But again, we're talking about legality, not whether it's safe to fly.

The FAA definition of airworthy found in 14CFR part 3:5 is - "the aircraft conforms to its type design and is in a condition for safe operation."

Part of an IA signing off an annual is verifying the aircraft conforms to its type design. And unfortunately, with an undocumented repair, I don't see how that can happen, since that puts a burden on the IA to verify a repair of unknown damage was properly repaired using appropriate parts and data.

The same goes for a DAR. How can he/she legally verify airworthiness in a case like this and then document that so it doesn't come up again, to the satisfaction of the FAA?

Again, looking for factual/legal answers, not argument.

Thanks..

Interesting discussion.
Welcome to the IA club.
You are the backstop in the system.
I would question an NTSB report as being part of the aircraft record required by the FAR’s. It is additional info but you have to go by what’s in the logbooks.

Trust but Verify. Verify by inspection and know what you are looking at. Know what you are looking for.

I looked at a 170 years ago that had a similar situation. NTSB report of it going over on its back, no log entry on the repairs. It looked good.
It’s still flying.
Cheers,
Dave

You can not determine conformity by reading a logbook. Logbooks are nothing more than the story someone wants to tell.

You determine conformity by performing an inspection of the aircraft, and IF you find a repair suspect, then research whether that repair meets the approving data, which should be outlined in block 8 of the 337.

In the (likely) event that a 337 went missing from the logs, AND it was miss-filed by the FAA admin person, then we must do a bit more research. Cessna manual has a pretty good chapter on many structural repairs. Then there’s AC43.13. And Finally, if you don’t find what makes you feel good, then we go down the road of requesting engineering data, from DER or Cessna (who will likely refer to DER)

NOTICE how nowhere in there do we reach out to the FAA for anything other than the records they may/might/maybe have in their system. They don’t have the time, man-power, knowledge, or give-a-f@#$ to do your engineering data research. That’s on you.

If your research through approved data, or get DER data, finds the repair to be in compliance, then you fill out a 337 describing the work done “by persons unknown and time unknown”.

If you ultimately find said repair to not be in compliance, then you remove and repair it, so as to meet compliance, filing the appropriate paperwork of work accomplished.

So, Step ONE is…. Exercise that shiny new “Inspection Authorization” of yours, and look at the plane.

And, when in the very likely event that you don’t find anything at all, and the 182 looks like and smells like a 182 that Cessna built, than you just verified that the airplane complies with type design.

Ok. So, again, as a new IA, let me see if I have this straight.. You're saying I can fill out a 337 for this aircraft, saying in block 6 that repairs were made by persons unknown and I can certify this in block 7 as an IA even though I don't know what damage was done and what repairs were made? And the FAA will accept this?

And what do I put in block 8, "Description of work accomplished", since I don't know what was damaged and what work was actually done?

Are you sure about this?

Again, I'm not trying to argue with anyone, I just want to know how to (if I can) make this airplane legal based on the regulatory environment we have.

I'm starting to get the feeling I should ignore this kind of thing because nobody wants to deal with it strictly IAW the regs. Maybe that's the difference between an old IA and a new one..

Sometimes I think it's great that new people come along with new ideas and challenge the status quo..keeps all of us on our toes..until they get ground down to a nub and give up..

Thanks..

Trimetric wrote:Ok. So, again, as a new IA, let me see if I have this straight.. You're saying I can fill out a 337 for this aircraft, saying in block 6 that repairs were made by persons unknown and I can certify this in block 7 as an IA even though I don't know what damage was done and what repairs were made? And the FAA will accept this?

And what do I put in block 8, "Description of work accomplished", since I don't know what was damaged and what work was actually done?

Are you sure about this?

Again, I'm not trying to argue with anyone, I just want to know how to (if I can) make this airplane legal based on the regulatory environment we have.

I'm starting to get the feeling I should ignore this kind of thing because nobody wants to deal with it strictly IAW the regs. Maybe that's the difference between an old IA and a new one..

Sometimes I think it's great that new people come along with new ideas and challenge the status quo..keeps all of us on our toes..until they get ground down to a nub and give up..

Thanks..

I think what he was suggesting was that IF you find repairs, AND the repairs meet the required criteria, THEN you can submit such a 337.

But, if you cannot find any repairs after a careful search of the airframe, then you should be able to argue that the airplane conforms to its type design and meets airworthiness standards. If the repairer performed repairs so well that you as an IA can't detect them.....

That, of course, requires a very serious inspection of said aircraft.

MTV

That sounds reasonable.

Thank you MTV, that’s what I was trying to say.

Trimetric, you can certainly make this airplane’s documentation compliant with the requirements of the CFR.

Again, we have to inspect the aircraft first.

But, if you find an undocumented repair, that would meet the requirements to qualify as a major repair, and it is deemed to be a proper repair, then you are simply filling out a 337 so that the repair is documented into the permanent file for the aircraft.

Sec 6 is unknown

You are signing 7 returning the aircraft to service for just that repair

Sec 8 is a description of the repair as you find it.

If, upon completing the inspection of this aircraft, and no undocumented major repairs are found, then the aircraft meets its type design.

You’ve done everything a prudent and reasonable IA can do.

The NTSB report is circumstantial. We have to inspect the aircraft to find any physical evidence.

Thanks guys, great information. I hope this helps others.

As luck would have it, I just received the records (from AIC Title) of another aircraft I was looking at and lo and behold there was just such a 337 in those records.

I was impressed that someone would go to the trouble to clear up a small legal issue like this.

Anyway, so there is a way to fix these annoying legal issues.

I attached a screen shot of the 337. If it doesn't come through I'll do it another way.

Thanks again -