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CFIs, Logbooks, and Remarks

Old 01-04-2015, 11:11 PM
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Default CFIs, Logbooks, and Remarks

I know this question gets asked from time to time on this forum and others, so I just wanted to use this thread as a collector to (hopefully) get some questions answered, provide some of my $0.02, and get some wisdom from fellow CFIs so that hopefully we can all learn a little bit.

First off, I've seen some very large variance in terms of how CFIs log flights in both their students' and their own logbooks, and although I still have some questions of my own, I think there’s enough guidance out there that I don't think any of us should be that far off base. For instance, some instructors will put a general summary of what was covered in the student's remarks, but only their student's name in the remarks of their own logbook, while others will "clone" what was placed in their student's logbook into their own. Some instructors may even draw a circle with a point in the center to represent turns around a point as well. I’m not going to go out and say any of these things are wrong – but I will say there are regulations that explain at least to an extent what we’re supposed to do. Since most CFIs typically work with student pilots in single engine land airplanes pursuing private or perhaps a sport pilot certificate, I’ll use 61.87(d) as the first example:

(d) Maneuvers and procedures for pre-solo flight training in a single-engine airplane. A student pilot who is receiving training for a single-engine airplane rating or privileges must receive and log flight training for the following maneuvers and procedures:
(1) Proper flight preparation procedures, including preflight planning and preparation, powerplant operation, and aircraft systems;

What follows is the 15 required maneuvers/procedures for pre-solo flight training which I’m sure we’re all familiar with. Based on the snippet above, I think it’s safe to say that those key words described in 61.87(d)(1) through (15) should be logged verbatim in the remarks as part of the flight training conducted, could we all agree on that? Obviously this is preparing for a worst case scenario – the student crashes and God forbid is killed, the CFI is taken to court, and the logbook analyzed. If those maneuvers are in there word for word, there would hypothetically be no problem, at least from a record standpoint. However let’s say the term “preflight inspection” is placed in the remarks for one of the flights and the term “preflight preparation” (which is part of 61.87(d)(1) as above, and could be argued to mean the same thing) is never used. The relevance of this semantics would probably depend on the cause of the crash, i.e. if the student crashed because of something related to preflight inspection/preparation, then it would be scrutinized more, if not then it probably won’t. Obviously in reality I don’t think that many CFIs consistently do this in practice (including myself, but I’m trying to get better), since we fall into the habit of just writing “touch and go’s” “preflight” “stalls” etc. Obviously none of this really matters unless something bad happens. Cross-country flight training for student pilots is also similar, in that specific maneuvers/procedures are listed and must be “logged” (61**). I guess the question for everyone pertaining to what I’ve said above is, can we agree that ideally we’re supposed to write these maneuvers/procedures in the remarks verbatim (at least in this case for student pilots)?

My next question relates to Part 141 instructors/students. What I discussed above definitely pertains to the individual instructor training a student under Part 61, mainly due to the fact that the student’s and instructor’s logbooks can legally be the sole record of training. But what about an instructor employed at a Part 141 school training a student pilot pursuing private under Part 141? Part 141 schools have additional recordkeeping requirements; does that more or less alleviate the instructor in this regard? Obviously the student and instructor must have their own logbooks and log the flights, but would pre-solo remarks be of less importance due to the school’s recordkeeping? Also, one of the main points of a Part 141 school is to use an approved syllabus – as a result, would it be more proper for an instructor to log the lessons accomplished per that approved syllabus in the student’s logbook instead of just scratching in “slow flight” “stalls” etc? There is no real guidance in Part 141 in this regard as there is in 61, so I’m wondering if there’s overlap or if it is indeed more appropriate to just log the syllabus lessons.

Shifting gears again, I’ll go ahead and touch on the topic of “cloning” what you place in the student’s logbook in your own, vs. not doing so. I’ll start with an example – I knew an instructor that had a student that busted George Bush’s 50 some odd mile TFR around his ranch back in the day. An FAA inspector wanted to interview both of them and go through their logbooks. The instructor fortunately didn’t get in trouble (perhaps there were bigger fish to fry), but he got railed for not having logbook entries that matched his students identically. I’m not even talking about a lack of remarks with just a student’s name in his logbook, I’m talking about maneuvers being listed in a different order, or summarized to greater extent. Using a hypothetical scenario, let’s say a student crashes and kills themselves on a solo. They’re probably carrying their logbook with the appropriate endorsements, so chances are it would burn up. As a result, the instructor’s logbook is the sole surviving record of the training given. If it doesn’t have what was included in the student’s logbook, then most may view it as if the training had never happened. Just things to think about, I’m curious as to others’ opinions on this.

Lastly I’ll just touch on some other common CFI actions that relate to all this. Flight reviews! Here’s 61.56(a):

(a) Except as provided in paragraphs (b) and (f) of this section, a flight review consists of a minimum of 1 hour of flight training and 1 hour of ground training. The review must include:
(1) A review of the current general operating and flight rules of part 91 of this chapter; and
(2) A review of those maneuvers and procedures that, at the discretion of the person giving the review, are necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate.

It’s looking to me like that minimum ground portion of the flight review should be logged and that the remarks for that ground state something like “reviewed current general operation and flight rules of 14 CFR Part 91.” I say this since the ground is considered to be “training” per the regs, not an oral or anything. How many here do this? I know whenever I’ve gotten a flight review no instructor does this, nor have I seen one that does. As for the flight remarks, it was said at an AOPA CFI refresher seminar that instructors should write “flight review completed satisfactory” when an applicant successfully completed the flight review, and NOT to itemize the maneuvers performed, since this can be more easily picked apart in court if the worst happens. On a similar note, let’s look at 61.31(e ):

(e) Additional training required for operating complex airplanes. (1) Except as provided in paragraph (e)(2) of this section, no person may act as pilot in command of a complex airplane, unless the person has—
(i) Received and logged ground and flight training from an authorized instructor in a complex airplane, or in a flight simulator or flight training device that is representative of a complex airplane, and has been found proficient in the operation and systems of the airplane; and
(ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a complex airplane.

We probably all know about the flight and endorsement that we need to give for a complex checkout, and any good flight instructor will go over the systems with reference to the POH, but how many here log that ground? I ask because I haven’t seen any that do, and I’ve operated with freelancers, in different schools, and even in different states! But the regs seem pretty clear on what should be done. What do you think?

This has turned out to be quite a bit lengthier than I expected, so kudos to those who actually read all of this! I hope we can all learn something from this, or perhaps I’m just the slow kid in the group .
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Old 01-05-2015, 07:36 AM
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There's AC-61-65e that gives examples of signoffs. "I certify that Joe Pilot, PVT 1234566 has satisfactorily completed a flight review of section 61.56 on 05 JAN 2015." I'm not a lawyer but by citing the reg and saying you've complied with the reg you should be covered especially since that's how the FAA says to sign it off. Having a lesson plan you can produce for flight reviews, complex checkouts, etc that meets the details in the reg would be a good idea.

I never did 141 instruction but for part 61 I cloned everything in the student's logbook in mine. I knew guys who photocopied their student's logbook.
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Old 01-05-2015, 02:34 PM
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A bit OCD are we?
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Old 01-05-2015, 03:40 PM
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I didn't even make it through all that. But to answer the question...

AC 61-65 will keep you out of trouble with the FAA. Technically, the documents used in 141 would suffice for most logging requirements, ie as long as the details are in the 141 record they don't need to be in the student's logbook (obvious exception for required endorsements). But this could create problems for the student if he leaves the school and tries to finish up part 61...he won't have detailed records of all the required training.

But you also have to consider liability...if you only log the details in the student's book that could be destroyed in a crash, lost prior to the crash, never located after the crash, or "lost" by the plaintiffs if it weakens their case. If I had to do it over, I would have kept duplicate records of everything I put in the student's book (I had that in the school records for my 141 students). I wouldn't actually clutter up my logbook with all I'd just use my phone to take a legible photo of each entry and endorsement I make in a student's book.
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Old 01-05-2015, 09:28 PM
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Yeah the length is excessive, just got off on a tangent late at night.... As for being OCD, well, although I might be, I don't keep mine nor my students' logbooks that ideally up-to-snuff - just trying to pick brains and see what others do.

rickair7777 (and Twin Wasp, I'm not leaving you out ), you say AC 61-65 will keep someone out of trouble with the FAA, but let's say you're training a student pilot and give them all the appropriate endorsements (verbatim per 61-65) for a local solo: Presolo aeronautical knowledge endorsement, endorse their student pilot certificate, and the presolo flight training endorsement in the logbook (ensuring it's 90 days current). The presolo flight training endorsement basically says that the student has received training in, and is proficient in, the maneuvers listed in 61.87 (d for airplane single engine). I don't want to twist your words here, but I'll ask, are you saying that endorsement alone is adequate and what the instructor writes in the remarks for each of the flights is more or less irrelevant? I know you didn't say this explicitly but that's the topic I'm trying to attack.

My thinking is that the REMARKS for the flights leading up to that endorsement and solo must contain the key words for those maneuvers/procedures in 61.87(d) since 61.87(c) says:

"Prior to conducting a solo flight, a student pilot must have: Received and logged flight training for the maneuvers and procedures of this section..."

Additionally, the requirement for the instructor to endorse the student pilot's logbook is a separate regulation and actually repeated twice, both from the student's perspective and the instructor's:

(n) Limitations on student pilots operating an aircraft in solo flight. A student pilot may not operate an aircraft in solo flight unless that student pilot has received:
(2) An endorsement in the student's logbook for the specific make and model aircraft to be flown by an authorized instructor, who gave the training within the 90 days preceding the date of the flight.

(p) Limitations on flight instructors authorizing solo flight. No instructor may authorize a student pilot to perform a solo flight unless that instructor has—
(5) Endorsed the student pilot's logbook for the specific make and model aircraft to be flown, and that endorsement remains current for solo flight privileges, provided an authorized instructor updates the student's logbook every 90 days thereafter.

All of the above pertains to Part 61. For Part 141, you mentioned that if the student leaves there might be a problem. So I guess the question is, is it more important for a Part 141 instructor to show compliance to the school's approved course/syllabus, or to make the student's logbook easy to use for any potential future instructor? I think writing "Jeppesen - Private Pilot - Airplane Single Engine (v1.03) - Stage I - Lesson 2" should be adequate, but obviously that means the future instructor must reference that syllabus when reviewing the student's logbook (those come with the kit right?).

Does that clear it up? I think we kind of got off on a 61-65 tangent, which we all know those endorsements must be made, but I'm concerned with what should be written in the remarks so as to be totally covered and compliant with the regs.
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Old 01-05-2015, 10:14 PM
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No, I started at the bottom and worked up, sorry I didn't make it clear. For the FR one entry citing 61.56 should cover you. For the 61.31 items as you point out there is a requirement for logging ground instruction so an entry stating there was x.x hours of ground training per 61.31(e),(f),(g),(h) or(i) and another showing flight training should cover it. For PVT, COM or IR students under 61 document each lesson. As Rick points out, now you can just take a picture of each page of the student's logbook for your records.
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Old 01-06-2015, 08:18 PM
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I got this idea from an instructor I flew with when I was still a private pilot, and I did the same thing when I was a CFI.

After the lesson, I wrote down everything that we did in my logbook first. If it was the first time I flew with that student, then somewhere on the line I would write his/her first and last name; on subsequent flights, I'd write the first initial/last name. I would then insist that the students sign the line next to their name in my logbook. Then, and only then, would I put the exact same entry in their logbook.

This protected the student, by making sure everything was logged, and by making sure I couldn't later claim s/he did something I didn't teach if he or she crashed. It protected me by making sure that my log was always kept up to date, and also giving me protection from false claims by the student.

At job interviews later, my record-keeping impressed the hell out of recruiters and interviewers. It did the same when I took checkrides with the FAA and they were looking through my log for experience.

Just food for thought...
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Old 01-09-2015, 06:05 PM
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Twin Wasp - yes i think for the flight review the less the better, citing the reg is a good idea as anywhere, but like i said - AOPA has suggested to simply write "flight review completed satisfactory" which is actually very similar to what DE's write after a checkride, i.e. "private pilot ASEL sat." And yes, with regard to keeping record of endorsements I've fallen back on simply taking pictures with my phone or asking students to do so and send me them if I forgot.

OnCenterline, I actually have followed almost that exact same procedure since I started CFI'ing. Everything except having them sign it, but that is a good idea. Something I will consider in the future.

Thanks for all the answers.
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Old 01-14-2015, 02:21 PM
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I don't think you can go wrong by citing everything in both logbooks exactly as the FARs and AC 61-65 are written, but I personally consider that extremely tedious and unnecessary.

I think you are ultimately at the mercy of the inspector looking at your logbooks. I've had extremely OCD ASIs who want a clear paper trail for their own CYA and I've had much more lax, "spirit of the rules" ASIs who are fine with whatever as long as they can understand how what you wrote corresponds to the appropriate regulations. The same is true for DPEs that I've worked with.

No where in the regulations, ACs, or other guidance has the FAA ever restricted what is considered a "record." It can be toilet paper rolls as long as you write down the appropriate information. 61.51 simply says "Each person must document and record the following time in a manner acceptable to the Administrator [...]" It does not say how many copies must be made, who must hold these copies, or for how long. There are practical or tort-related reasons why you might consider these questions, but they are not explicitly stated by the FAA.

On top of that 61.189 says:

§ 61.189 Flight instructor records.
(a) A flight instructor must sign the logbook of each person to whom that instructor has given flight training or ground training.
(b) A flight instructor must maintain a record in a logbook or a separate document that contains the following:
(1) The name of each person whose logbook or student pilot certificate that instructor has endorsed for solo flight privileges, and the date of the endorsement; and
(2) The name of each person that instructor has endorsed for a knowledge test or practical test, and the record shall also indicate the kind of test, the date, and the results.
(c) Each flight instructor must retain the records required by this section for at least 3 years.
It clearly indicates what records a flight instructor MUST maintain. The language is all-encompassing.

So I would say you do not have to keep records of specific actions performed during any given training flight. Depending on how you feel about lawyers, the courts, and any FAA inspectors that would testify against you or violate you, you may believe it is a good or bad thing to keep those records. The records you keep could incriminate you in the same way they could absolve you of wrong doing. What if you made a mistake or omission in your own records? Now those records become evidence to be used against you. You can claim that you made a mistake, but those records will now have more weight than your own testimony. If the only record of what you did burns up in a crash, you are the sole surviving evidence of what instruction took place. You are not suddenly legally responsible just because the training records were onboard the aircraft.

Of course, much of the risk of what we are talking about can be mitigated by simply instructing your students well and not endorsing them for things that you don't have confidence in them performing without incident.
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