Relying On Photos of Maintenance Entries

If your mechanic sends you a photograph of the latest entry in your aircraft’s maintenance records, can you rely upon the photograph to ensure that the aircraft has been approved for return to service, or do you need to see the records in person? 

FAR 91.405 “Maintenance required” states that each owner or operator of an aircraft “shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service.”

In a recent interpretation of this FAR, the FAA’s Office of Chief Counsel states that viewing a photograph of the entry sent by fax, email, or text would allow the owner or operator to meet the regulation’s requirement, as this “would provide the same level of assurance as if the operator viewed the entry in person.”  However, there is a common-sense caveat.

The FAA cautions that owners or operators must use their judgment in relying upon pictures to ensure that the mechanic made the entry.  More specifically, the photograph must have “sufficient indicia of accuracy or reliability that the entry is, in fact, in the aircraft's maintenance records” and that “[s]ome of this judgment may include the owner's or operator's degree of confidence in the integrity of the mechanic.”

In light of modern technology, this FAA interpretation is quite practical.

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Jared Allen
Mr. Allen is AOPA’s Legal Services Plan (LSP) senior staff attorney and is an instrument-rated private pilot. He provides initial consultations to pilots through the LSP when the FAA has contacted them about potential FAR violations. Jared has helped numerous pilots successfully navigate through compliance actions.
Topics: Aircraft Maintenance

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