Bob, That is simply incorrect. Let me explain....
§91.417 Maintenance records.
(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
HARD STOP - Now re-read paragraph (a) and pick up at section (2) below....
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods prescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
(c) The owner or operator shall make all maintenance records required to be kept by this section available for inspection by the Administrator or any authorized representative of the National Transportation Safety Board (NTSB). In addition, the owner or operator shall present Form 337 described in paragraph (d) of this section for inspection upon request of any law enforcement officer.
(d) When a fuel tank is installed within the passenger compartment or a baggage compartment pursuant to part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner or operator.
(Approved by the Office of Management and Budget under control number 2120-0005)
[Doc. No. 18334, 54 FR 34311, Aug. 18, 1989, as amended by Amdt. 91-311, 75 FR 5223, Feb. 1, 2010; Amdt. 91-323, 76 FR 39260, July 6, 2011]
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Not sure what Grant is getting at. The FAR indeed has the words "record" and "contain" - but "containing" total time to me means it has to be there. If you have logs back to the manufacture date, and simply haven't added it all up, then maybe your records "contain" total time.
It does not say "Record" as in a verb, It says "Records", as in a noun.
I think you are misreading the regulation. There are two sections under paragraph (a)
Paragraph (a) says an owner must keep these records....
Paragraph (a), Section 1 - Basically says keep a record of these various maintenance/inspection events for this period of time excluding two specific 24 calendar month items.
Paragraph (a), Section 2 - Specifically says also keep any other records "containing" Time in service, among other things, life limited items etc... nowhere does it say the records must contain Time in Service, Just that If you have a record that Includes time in service then it is subject to Paragraph (a) which says to keep it...
And to understand the context, all of this applies to the reason to keep it, and that is for the purpose of transfer of custody of these records which is called out in the regulations following this one.
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Now, If you want to know what is required for a log entry, please refer to part 43 which basically says what I wrote earlier....
Part 43 explains what is required to be in a MAINTENANCE Record(43.9), and separetly, what must be contained in an INSPECTION Record (43.11). The only requirement for TTSN is that INSPECTIONS must contain the TTSN of the AIRCRAFT, Not the engine or prop but the "Thing" as a whole.... There are a few others but those are very specific to Airworthiness Limitations like Life limited parts and/or Airworthiness Directives, etc....