Logbook entries per PTS or FAR?

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ndakcfi

Well-Known Member
I'm getting a student ready for a private checkride, and just ran into a very strange situation with the local FSDO.

For some reason, the local FSDO has instructed their DPE's that all applicant logbooks have to reflect the exact wording that appears in the PTS (instead of the FAR's), and they're threatening to revoke every certificate held by any DPE who fails to follow the new directive. Since the wording in the PTS and 61.105/107/109 are generally pretty similar, I only need to amend a couple of logbook entries to comply with the change, but I'm still puzzled as to why they decided the PTS was more important than the FAR.

When I did my initial CFI, I was taught to use the FAR's for the wording on logbook entries, and I'd been doing that with no problems until I found out about the FSDO putting this new policy in place.

Has anyone else had a FSDO or DPE insist that logbook entries be based on the PTS?
 
ndakcfi said:
Has anyone else had a FSDO or DPE insist that logbook entries be based on the PTS?
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No. For most of my rides the DPE was pretty explicit that the endorsements and logbook entries should conform to the FARs.

I thought it was just the Orlando FSDOs that made up their own rules.
 
mojo6911 said:
Huh?
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As an example, for a lesson that included hood work, putting "instrument maneuvers" would satisfy 61.107. According to the FSDO, that entry now has to read "strait and level flight, turns, constant airspeed climbs and descents". The only other area where there's much of a difference in the wording is with ground reference maneuvers, since the FAR's just say "ground reference maneuvers", but the FSDO wants specific listing of S-turns, turns around a point and rectangular course in the logbook.

It's not a huge amount of work to get the logbook entries compliant with the PTS, but it's bizarre that the FSDO seems to think the PTS is more important than the FAR's for logbook entries.
 
I have to admit, I don't recall any PTS having any specific wording whatsoever for any endorsements.

Could you please provide an example or two?
 
The only one that I know about is this:

I certify that (First name, MI, Last name) has received the required training in accordance with sections 61.107 and 61.109. I have determined he/she is prepared for the (name the practical test).
/s/ [date] J. J. Jones 987654321CFI Exp. 12-31-05
 
mojo6911 said:
Huh?
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My reaction exactly. The FARs don't contain the specific wording of any endorsements. Neither does the PTS AFAIK.

The FAA does have a set or recommended guarantied-compliant endorsements in AC 61-65E. If a FSDO is claiming that those are not valid, it should be reported to flight standards.
 
My understanding is that they're taking issue with the individual ground and flight entries in the logbook, not the endorsements.

AFAIK, the FSDO is of the opinion that even if an applicant has the proper endorsements in the logbook, if the DPE can't go back and find every PTS item in a ground or flight entry, said applicant is not actually prepared for the checkride.

I've run into issues with an inspector from this FSDO before, when he insisted that one of my students was unprepared for a checkride because one of the items in 61.105 wasn't specifically mentioned in the ground training entries in the logbook, despite the fact that the endorsement mentioned the training from 61.105, 107, and 109.
 
ndakcfi said:
it's bizarre that the FSDO seems to think the PTS is more important than the FAR's for logbook entries.
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The PTS is the FARs,..sort of. The FARs say "ground reference maneuvers", and the PTS is the FAA "interpretation" of that item. By detailing the demonstrated requirement of ground reference maneuvers into three different specific skill tests: rectangular patterns, s-turns, and turns around a point. These three different skill tests should show up in the logbook in training.
How could you expect the applicant to be skilled in the PTS item if he shows no specific training on that testable item?

Logbooks have long been abused by instructors, and we have gotten away with it for all my life, but not any more. The insurance people(lawyers) are here.

Document. Document. Document.
 
ndakcfi said:
My understanding is that they're taking issue with the individual ground and flight entries in the logbook, not the endorsements.

AFAIK, the FSDO is of the opinion that even if an applicant has the proper endorsements in the logbook, if the DPE can't go back and find every PTS item in a ground or flight entry, said applicant is not actually prepared for the checkride.

I've run into issues with an inspector from this FSDO before, when he insisted that one of my students was unprepared for a checkride because one of the items in 61.105 wasn't specifically mentioned in the ground training entries in the logbook, despite the fact that the endorsement mentioned the training from 61.105, 107, and 109.
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Okay, this makes more sense and I agree with the FSDO. There is a case covering CFI endorsements where the CFI was violated for not writing the proper presolo endorsements. Initially in this case I think the CFI was taken to task for not writing the specific training in the students logbook, but the CFI did have other records that supported the training given so the administrator dropped those charges.
In addition if I pick up a student from another CFI and specific training called for in Part 61 is not listed then I must give the applicant that training. I've had this happen several times, in addition to finding student pilots soloing without a record of the required presolo training... anywhere.

http://www.ntsb.gov/alj/O_n_O/docs/Aviation/4634.pdf
 
Blackhawk said:
Okay, this makes more sense and I agree with the FSDO.
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I don't know whether I do or not. Still not enough information for me.

What is required (by both the regs and the analysis in the case you linked to) is that all of the tasks for, say the commercial certificate, that are listed in 61.125 and 61.127, must be logged or recorded, in a way that makes clear that each of them was covered.

If that's what the FSDO is stating, I agree. But if the FSDO is saying that the text of the entries has to use the language that the PTS uses to describe those tasks, I don't.

That said, it is certainly a much better practice to identify which "ground reference maneuver" is covered rather than simply use the generic term, but grounds for failing a checkride?
 
why not just log what you worked on that flight? if it doesn't fit in the remarks section, write somewhere else or use the next line down. That is what I always did just as a CYA and then anyone who needed to see it would be happy because the details of the flight are there.
 
Blip16 said:
why not just log what you worked on that flight? if it doesn't fit in the remarks section, write somewhere else or use the next line down. That is what I always did just as a CYA and then anyone who needed to see it would be happy because the details of the flight are there.
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You are, of course, correct but I don't think that's the issue being raised in this thread. Sounds more like it about whether the way you wrote what you worked on would pass muster with some guy at the FSDO pretending to more authority than he actually has.
 
MidlifeFlyer said:
I don't know whether I do or not. Still not enough information for me.

What is required (by both the regs and the analysis in the case you linked to) is that all of the tasks for, say the commercial certificate, that are listed in 61.125 and 61.127, must be logged or recorded, in a way that makes clear that each of them was covered.

If that's what the FSDO is stating, I agree. But if the FSDO is saying that the text of the entries has to use the language that the PTS uses to describe those tasks, I don't.

That said, it is certainly a much better practice to identify which "ground reference maneuver" is covered rather than simply use the generic term, but grounds for failing a checkride?
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I'm going off this that was written by ndakcfi:

"My understanding is that they're taking issue with the individual ground and flight entries in the logbook, not the endorsements.

AFAIK, the FSDO is of the opinion that even if an applicant has the proper endorsements in the logbook, if the DPE can't go back and find every PTS item in a ground or flight entry, said applicant is not actually prepared for the checkride.

I've run into issues with an inspector from this FSDO before, when he insisted that one of my students was unprepared for a checkride because one of the items in 61.105 wasn't specifically mentioned in the ground training entries in the logbook, despite the fact that the endorsement mentioned the training from 61.105, 107, and 109."
 
Blackhawk said:
I've run into issues with an inspector from this FSDO before, when he insisted that one of my students was unprepared for a checkride because one of the items in 61.105 wasn't specifically mentioned in the ground training entries in the logbook, despite the fact that the endorsement mentioned the training from 61.105, 107, and 109."
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That is the issue. A blanket endorsement is not sufficient to document the training required for that endorsement.
Just saying I have given you all the training required does not document each individual FAR ie. PTS TASk requirement.

It's a simple legal requirement. Not a "FSDO Power Trip". Although it could be. but anyway it is a legal requirement to document training in each required maneuver/procedure required for that certificate/rating.

Insurance Lawyers love our lazy lackadaisical (part 61) "pilot training record" logbook.

Haven't you guys heard the spin logging fiasco?
 
Just a quick update.

I had a student successfully complete a private checkride today, and got a bit more information about what the FSDO is actually doing.

Apparently the requirement that entries pertain to the PTS was the result of a misunderstanding between the FSDO and DPE's, but the FSDO is cracking down on logbooks, especially the individual ground and flight entries.

The only issue the DPE saw with my logbook entries was the fact that one of the items from 61.105 was recorded in a flight, but not in the entries for the ground sessions. Apparently that's something the FSDO is running into a lot (usually on a much larger scale), but if a logbook line has both flight and ground time entered, any items done on that lesson are considered "done" for both ground and flight training.

The DPE wasn't sure if this was a local push or something that all of the FSDO's are going to start doing, so I'd advise the other CFI's out there to double check and compare what's in 61.105,107, and 109 with what's going into student logbooks to make sure that an FSDO inspector with an axe to grind doesn't have anything to use against you.
 
It is interesting to see this posted! I will add my two cents; I recently earned my CFI and I remember discussing this topic with my instructor during the logbook section of training. He told of an experience where a student's logbook was examined during a checkride (I cannot remember if it was a student with a DPE or a CFI applicant through the FSDO) and the examiner looked for the specific wording of each flight task as described in the FARs. The examiner then claimed that some items were missing/not documented and that the student was not prepared for the checkride (Also, I cannot remember if he pink slipped the student or not). My instructor now writes out each maneuver he accomplished in flight and each topic he covered during ground, thereby insuring that each item in the FARs was in the student's logbooks. Many of his logbook entries are 2-4 "lines" deep depending on how thorough the flight was.

I wonder if this will be something the FAA begins cracking down on? I know I've seen MANY entries along the lines of "T/O and L/D, maneuvers".
 
TOGA9 said:
Many of his logbook entries are 2-4 "lines" deep depending on how thorough the flight was.
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On my CSEL & CMEL checkrides, the DPE used up half a logbook page to write "All areas of CASEL PTS tested and found satisactory CASEL Cerificate issued this xx day of xxx 2009" Later did the same thing for the CMEL Add-On. Logbooks aren't expensive and they have plenty of pages so there's no reason not to use all the space you need to document whatever you need to. Half a page for every training flight might be a little excessive though.
 
I wonder if this will be something the FAA begins cracking down on? I know I've seen MANY entries along the lines of "T/O and L/D, maneuvers".
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that is unprofessional as a CFI IMHO. The FAR's require you to log what you did on each lesson (CFI requirement when filling out the logbook) T/O and L/D and maneuvers could be anything.
 
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