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June 29, 2009

Ask the DAR:Requirements for a builder’s log.

Question: What are the requirements for my builder’s log? Does it have to be extremely detailed? What, as a DAR, are you looking for?

Answer: The requirements for a builder’s log are minimal. The primary purpose of the log is to show the inspector that you did indeed build the aircraft. And, in all honesty, any inspector will know if you built the aircraft after talking with you for just a few minutes. He will ask questions that you could not easily answer if you had not done the work yourself. Here’s a hint: If you are constructing in a “builder’s assistance center” and the inspector asks you a question about a particular part of the construction, you should not turn and look at the building instructor or assistant for guidance at this point.

Electronic logbook entries are acceptable, and may make it easier to tally hours devoted to various parts of the build. However, the DAR usually isn’t interested in a builder-hours breakdown. It’s more important that you know enough about the airplane to be convincing as the true builder.

That’s the subjective end of the argument. Let’s look at the details. FAA Order 8130.2F paragraph 147 addresses the builder’s log requirements. It basically states that the builder should document construction phases using photographs taken at appropriate times prior to covering or finishing. The photographs should clearly show the methods of construction and quality of workmanship, and they should also contain images of you performing the work. Such photographic records should be included with the builder’s log or other construction records. The log needs to be chronological, showing when each process was done. There are no requirements to show how much time was spent, just a reasonable time span.

Your builder’s log should also show at what points your project was inspected by EAA technical counselors, A&P mechanics, experienced builders or other knowledgeable people. The record should show the inspector’s name, what he/she inspected, and any comments and suggestions that were made. If these inspections were made by an EAA tech counselor, you will have been given a copy of the report. These reports should be made a part of your log. (Note: Just because the FAA no longer requires a “pre-cover” inspection, that doesn’t mean you should dismiss outside help. It’s always a good idea to have other experienced eyes on your project.)

The medium used for the builder’s log is up to you. You may use a looseleaf or spiral-bound notebook. Some people mark up their construction plans with dates. Recently more builders are using a computer log, which is fine by me. These should be backed up with a hard copy, as computer files can sometimes “disappear” without reason.

The builder’s log should become a permanent part of your aircraft maintenance records. The FAA may also want to see your builder’s log when you apply for your Repairman Certificate.

A Matter of Tone

I received an email from a reader who said that this comment in the March issue sounded arrogant: “Now if you disagree with the inspector about anything or refuse to correct a problem that was found, the DAR must deny the airworthiness certificate.”

After talking with the individual, I had to agree with his interpretation of my tone. I realize that the statement should have been presented differently. What I should have said is: If you disagree with the inspector and cannot come to an agreement as to the interpretation of the applicable FARs, then he must deny the airworthiness certificate. If you disagree with the inspector, ask him to show you the applicable rule or regulation he is using as a basis for his decision. If he can show you the reg, and he should be able to, then you will be allowed to correct the discrepancy and continue the inspection.

The “must deny” comment was meant to convey that once the DAR accepts an 8130-6 (airworthiness application), he cannot simply walk away. He must either deny the certificate or issue it.

When KITPLANES® asked me to write these articles, I stated that, “I'm not a writer, but I'm willing to learn.” [Mel is being far too modest. He has a clarity of thought and expression many so-called professional writers would do well to emulate.—Ed.] Well, I'm still learning. I have a saying that I often use: “When we stop learning, it's over!” I hope to continue learning for some time. If you disagree with any information presented in my articles, by all means, please let me know. It's much easier to find my mistakes if they are pointed out to me.

Please send your questions for DAR Asberry to with “Ask the DAR” in the subject line.

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