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Touring Machine Company

Annual with Discrepancy List

We recently had an IA start working on the annual for our plane and then disappear for weeks at a time. After five months of evasions we finally insisted on getting an annual signoff with a discrepancy list. He claimed that wasn’t possible so we pointed him to this information. He finally provided an annual signoff so we could get an A&P to complete the annual.

FAA-G-8082-19 Inspection Authorization Information Guide

6. The owner should be made aware that the annual or progressive inspection does not include correction of discrepancies or unairworthy items and that such maintenance will be additional to the inspection. Maintenance and repairs may be accomplished simultaneously with the inspection by a person authorized to perform maintenance if the owner and the IA holder agree. This method would result in an aircraft that is approved for return to service upon completion of the inspection. A written list of discrepancies and unairworthy items not repaired concurrently with the inspection must be made and given to the owner. Record uncorrected discrepancies and unairworthy items in the maintenance records. The owner must make arrangement for correction or deferral of items on the list of discrepancies and unairworthy items with a person authorized to perform maintenance prior to returning the aircraft to service.

Discrepancy Example

The Busch Legal Interpretation clarifies that “The list of discrepancies required to be provided to the aircraft owner or operator (or lessee) by sections 43.l l(a)(5) and (b) is not a maintenance record that must be entered in the maintenance record of the aircraft.”. The items on the discrepancy list must be addressed by a qualified A&P before return to service. The A&P may decide that some items are not airworthiness items and can be ignored entirely or carefully checked at the next annual/oil change. e.g. spark plug wear. The IA made a determination that the spark plugs needed to be replaced. Our A&P inspected and tested them and determined that they had plenty of life left in them.

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