Avionics Shop - IFR Certification

[Acreel264]

I had my mooney in the shop for some avionics work. I requested they do an IFR cert while it was there. This was done on Jan. 31, 2023. The shop knew I would not be able to pick the plane up until Feb. 1, 2023. I asked them to date the the service as Feb. 1, 2023. They wouldn't do it and responded with this statement:

THE WORKED WAS PERFORMED ON THAT DATE THAT IS THE DAY WE SIGN IT OFF IT IS OUR COMPANY POILCY TO FOLLOW FAA RULES SO WE DON’T HAVE TO EXPLAIN OUR SELFS IN A LAWERS OFFICE.

My question is: Would my request to date the IFR cert as Feb. 1, 2023 have violated an FAA regulation since the plane did not leave the shop until that day?

Obviously, I have some personal thoughts on this and I'll refrain from sharing them.  

[EricJ]

FAR 43.9 says maintenance entries are dated the date the work was completed.   So, yes, it would be a FAR violation to put a different date on it.

[ArtVandelay]

FAR 43.9 says maintenance entries are dated the date the work was completed.   So, yes, it would be a FAR violation to put a different date on it.

Well, if they had not written up the log sticker, then the work would not have been completed, since a log entry is part of the work.

[GeeBee]

Or leave a screw out of a panel until 2-1. Good grief

[EricJ]

Yes, there are easy ways to delay the completion of the work, but I think they're saying it was completed on Jan 31st, so they're correct that it would be a violation to change the date after the fact.

 

[carusoam]

Everything takes planning and discussions…

Even getting the most out of an annual…. A good CB plans the annual to be the last week of the month so the docs are signed on the first day of the next month…  

A new challenge arises… each year, the annual is done a month later… December and January are great for down time… July and August are not…

Once the docs are signed and dated… it is a bit late to start the discussion… 
 

Keep in mind… it was AW when they finished the job… a day later, a bug could take up residency in the pitot tube…  so, it’s even difficult to have a mechanic try to be flexible without prior planning…

PP thoughts only, not a mechanic…

Best regards,

-a-

 

[Dick Denenny]

They are being chicken shit. Could have done anything they wanted as to as to total completion date. Would never go back to them and would let the world know all about it. 

[Minivation]

Ah, just about everything in GA maintenance has two answers - real and legal. In reality, bumping the record by 24 hours 99.9999% won't mean anything. But legally? Oooh.

I agree with EricJ in that I have a feeling the work and logbook signoff was completed and marked as 31 January 2023. At that point everything is finished and it would be very fishy to go back and bump the date. The thing about 91.411's and 413's is that they not only involve logbook entries but an entire set of cert documents based on Part 43 Appendix E and F of which one copy usually gets appended to said logbook entry and the other kept with the CRS for a few years. Chicken shit? Maybe, but CRS's get visited by the FSDO quite often and those inspectors look at this stuff. I've seen repair stations get SLAMMED with ridiculous fees and penalties for the smallest stuff (a CRS near me was fined $5k for forgetting to note the ELT battery expiration date on the logbook entry) so I wouldn't be surprised if they're just trying to watch their six.

I'm sorry to hear about your situation though. If I may add my $0.02, I suggest next time around explicitly mentioning that you'd like the IFR cert inspections performed and signed a specific date - most avionics shops would be happy to accommodate that for you if they're given a heads up.

 

[carusoam]

@Minivation are you currently in S. Korea….  With your Mooney?

Just wondering…

MS… active 24/7!

Best regards,

-a-

[Minivation]

10 minutes ago, carusoam said:

@Minivation are you currently in S. Korea….  With your Mooney?

Just wondering…

MS… active 24/7!

Best regards,

-a-

I wish!

I used to fly a friend's M20J before leaving for Korea at the end of 2021. I've been in here for a year and will be here for at least another to serve the mandatory military conscription that applies to all Korean citizens. Hopefuly I'll find my way back Stateside after this.

Speaking of Mooneys in Korea, I believe there is one M20R based in Taean Airport (RKTA) registered as HL1108. Not sure who owns it or if it flies regularly at all since ADS-B Out is not mandated here. There also used to be a fleet of at least five 201AT's based out of Seoul before they were crated and shipped to Canada. One of them is now C-GLNP and another C-GLNI.

A big bucket list item is owning a Mooney and flying it back to Korea just for kicks and giggles.

Edited February 4, 2023 by Minivation
G-GLNI -> C-GLNI

[carusoam]

There are a few Mooniacs that have flown around the globe…

It makes a great trip…

Thanks and best regards,

-a-

[hubcap]

So the actual “harm” is that the next IFR cert will need to be done 1 month sooner?
 

There are more important things than that for me to worry about.

[skykrawler]

Within the preceding 24 months........

Don't you still get 24 months?  If it was done on the 1st you could get almost 25 months.    You can game the dates, but it sometimes be hard to schedule with a shop.  I'm usually happy to just get it done.

Not much to burn an ulcer about.

[takair]

As Eric and Minivation indicated there is an entire paper trail behind the scenes and sometimes multiple people signing that paper trail. To change a date opens up a can of worms for them and a red flag for the FAA auditors whose job it is to look for paperwork anomalies.  Most FAA visits are purely paperwork visits. It can even have an affect on the operator. When I ran a shop, I had the occasion of a missed signature or other anomaly and they can ask the question if the plane flew away, implying an operational violation. Never got fined, but the implication were  there. Best to always cooperate. When I set up my PMA, a nice lady at the FAA (and I do mean that) told me, “document what you do, and do exactly what you document” and you will never have a problem. Yes, they are scared, but their livelihood is at stake and it is a legitimate fear in the repair station industry. 
 

[EricJ]

1 hour ago, takair said:

As Eric and Minivation indicated there is an entire paper trail behind the scenes and sometimes multiple people signing that paper trail. To change a date opens up a can of worms for them and a red flag for the FAA auditors whose job it is to look for paperwork anomalies.  Most FAA visits are purely paperwork visits. It can even have an affect on the operator. When I ran a shop, I had the occasion of a missed signature or other anomaly and they can ask the question if the plane flew away, implying an operational violation. Never got fined, but the implication were  there. Best to always cooperate. When I set up my PMA, a nice lady at the FAA (and I do mean that) told me, “document what you do, and do exactly what you document” and you will never have a problem. Yes, they are scared, but their livelihood is at stake and it is a legitimate fear in the repair station industry. 
 

Yes.   And falsification of records is something that can be taken very seriously, and also something that a judge can easily understand.   Misread a borescope?   That's something where a judge or jury can potentially be persuaded either way.    Misdate a record?   Everybody understands that, and the FAR is pretty clear about it, so it is understandable that a shop would be reluctant to deviate from practice, especially if they've already had a bad experience around that.

Often the IFR cert is done by a subcontractor with their own certs (repair station), and if they did the cert the day before and made the record, that's done and the shop can't do anything about it.

If the shop has control over the work (e.g., the cert isn't subcontracted) and you know you want it dated on a particular date, letting them know ahead of time may give them flexibility to accomodate you.

[BravoWhiskey]

I’m not saying this is the reason but was your request to date the IFR certification a phone discussion or an email… looks like you/they have a record of an email.  Just sayin’