Aircraft Maintenance Records Greg Nolting - Aviation Safety Inspector

My Background FAA Inspector since 1995 Graduate of FAA Approved A&P School IA since 1981 Started career at flight school in Minnesota Chief Inspector for 135, 141, and 145. DOM for 135 Taught at A&P 147 School DME

When are aircraft maintenance records required? Whenever any maintenance, preventive maintenance, rebuilding, or alteration is performed. Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts (excludes preventive maintenance). In other words, you must make a record entry for everything, including tire changes.

14 CFR 43.5   Approval for return to service after maintenance, preventive maintenance, rebuilding, or alteration. No person may approve for return to service any aircraft, airframe, aircraft engine, propeller, or appliance, that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless— (a) The maintenance record entry required by §43.9 or §43.11, as appropriate, has been made; (b) The repair or alteration form authorized by or furnished by the Administrator has been executed in a manner prescribed by the Administrator; and (c) If a repair or an alteration results in any change in the aircraft operating limitations or flight data contained in the approved aircraft flight manual, those operating limitations or flight data are appropriately revised and set forth as prescribed in §91.9 of this chapter.

91.405 Maintenance required. Each owner or operator of an aircraft— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter; (b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service; (c) Shall have any inoperative instrument or item of equipment, permitted to be inoperative by §91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required inspection; and (d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a placard has been installed as required by §43.11 of this chapter.

ADVISORY CIRCULAR 43-9B Maintenance records are a shared responsibility between the owner/operator and maintenance personnel, with the ultimate responsibility resting with the owner/operator.

FAR 43.9 “RECORD ENTRIES” Maintenance Records (except for inspections) shall contain the following information:

A description (or reference to data) of work performed. The date of completion of the work. The name of the person performing the work if other than specified below. The signature, certificate number, and kind of certificate held by the person approving the work.

“DESCRIPTION OF WORK PERFORMED” The description should be in sufficient detail to permit a person unfamiliar with the work to understand what was done, and the methods and procedures used in doing it.

INCORPORATION BY REFERENCE You don’t have to write a book. The rule permits reference to technical data in lieu of making a detailed entry. Common references include maintenance manuals, service letters, bulletins, work orders, advisory circulars (AC43.13-1B), and others. Major alterations may reference STC’s.\ Reference documents must be retained.

IN ADDITION “major repairs and alterations shall be entered on a form, and the form disposed of, in a manner prescribed in appendix B, by the person performing the work.” Requirements of appendix B have changed! You will soon be able to file online.

14 CFR 43.11, RECORDS FOR INSPECTIONS The person approving or disapproving for return to service after any inspection performed IAW Part 91, 123, 125, & 135 shall make an entry in the maintenance record the following:

The type of inspection and a brief description of the extent of the inspection. The date of the inspection and the aircraft total time in service. The signature, the certificate number, the kind of certificate held by the person approving or disapproving for return to service.

“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.” Daniel Johnson AP123456789IA

______________________ __________________________ ____________ Sample Logbook Entry N123A Tach/Hobbs: ____________ ACTT: ____________   Enter the type of inspection(s) performed: Enter accomplishment of all A.D.’s including the number, revision date, method of compliance, and if recurring, the next time/date it is due. Enter replacement or inspection of any component part with Airworthiness Limitations (include part, serial number, and total time in service for that component). Enter removal and installation of any serialized component replacement parts (include part, serial number, and total time in service for that component). Enter description of any other general maintenance performed. I certify that this aircraft was inspected in accordance with a (insert type) inspection and was determined to be in an airworthy condition. All work was accomplished in accordance with current Federal Aviation Regulations and manufacturer’s maintenance instructions. Details of work performed can be found on XYZ Company work order _______. ______________________ __________________________ ____________ Signature Certificate # Date

Other Considerations If you find the aircraft to be unairworthy, you need to list the discrepancies. The list must be signed and dated. For progressive inspections, the certification statement is different. For other approved inspection programs, the entry is made according to that program.

FAR 91.417 (a) “MAINTENANCE RECORDS” The owner/operator shall keep the following records: Aircraft Logbook

Records of the maintenance, preventive maintenance, alterations, 100 hour, annual, progressive and other required or approved inspections, as appropriate. Total time in service for the aircraft, each engine, each propeller, and each rotor. Current status of life-limited parts. Time since last required overhauls.

The current status of applicable Airworthiness Directives (A.D.) Copies of FAA Form 337 for any major alterations performed.

14 CFR 91.417 (b)(1) The Owner or Operator shall retain all maintenance records for 1 year after the work is performed or until the work is repeated or superseded by other work.

FAR 91.417 (b)(2) After one year, some maintenance records do not have to be retained. For the most part, this pertains to repairs and replacement of parts that are not life-limited. Altimeter/Transponder checks must be kept for 24 calendar months, or until repeated. All other records must be retained and transferred with the aircraft at the time the aircraft is sold.

Let’s talk about A.D.’s The owner/operator shall keep records containing “the current status of applicable airworthiness directives (AD) including, for each, the method of compliance, the AD number, and revision date. If the AD involves recurring action, the time and date when the next action is required.”

Breaking this down ……. How do you determine the current status? What was the method of compliance? Do you enter the revision date? For recurring AD’s, do you enter the time and date of next recurring action? Where do you make these entries?

Sample from AC 43-9

Maintenance tracking systems Keeping a list of scheduled maintenance. Computer tracking. Commercial record systems.

Making it work for you. If it doesn’t say that you can’t, then you can. Consider what the regulations don’t say. They don’t say that maintenance records have to be kept in a bound logbook.

Time for Questions Thank you for your participation.