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#4
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FAR 91.417 (b) (1) says you must keep the record for 1 year or until
the work is repeated. A VOR test is actually an inspection and is considered "work". Where you keep it is up to you. It does not need to be in any particular place or location. It does not need to be in the aircraft either. It is a maintenance record. This is the first time I've heard anyone claim that the VOR check is considered maintenance. Do you have a reference for this interpretation? If a VOR check is considered maintenance, then we're in trouble (except for the pilots who also have an A&P), because VOR check is not on the list of preventive maintenance items given in Part 43, Appendix A. So if it's considered maintenance, but not preventive maintenance, most pilots would not be authorized to perform it. There are several other factors that indicate a VOR check is not maintenance: - FAR 91.171(a)(2) uses the word "checked," not "inspected," for the 30-day checks we're discussing here. - FAR 1 defines maintenance to include "inspections", but not "checks". - FAR 91.171(d) specifies record-keeping requirements that are different from those in 91.417 and 43.9 (no certificate number, for example). If the VOR check is an inspection, then you'd also have to comply with 43.11 and include aircraft total time in service, and the statement "I certify that this aircraft has been inspected ..." It seems clear to me that the VOR check is not maintenance, and thus not subject to the requirements of 91.417. Barry |
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