How long does the FAA require part 91 inspection forms to be kept on file ?

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cas4129
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How long does the FAA require part 91 inspection forms to be kept on file ?

How long does the FAA require part 91 inspection forms to be kept on file ?

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wfernandez
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Until the work is repeated or superseded.

bob.pasch
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Respectfully, that's for a repair. There is no requirement to keep an inspection form.

wmermelstein
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As usual this can be very open to interpretation by the administrator. In general, there is no requirement for the retention of the checklist used for an inspection of a Part 91 aircraft, however;

8900.1 Chg 36, Volume 6, paragraph 6-42 discusses the different inspection programs. In some cases the use of a Progressive, AAIP, Manufacturers or CAMP program may require as a portion of that checklist/form the requirement to retain the checklist as a part of "approved inspection program". In the case of a AAIP or progressive inspection, the retention may be required to evidence the portions of inspection complied with at the given interval.

If the checklist used for the inspection has a requirement to be retained this would make the rentention a requirement for sure.

Also, while not clear (and what ever is) FAR Part 43,

[SEE MY COMMENTS IN BRACKETS]

Sec. 43.11

Content, form, and disposition of records for inspections conducted under parts 91 and 125 and Sec. Sec. 135.411(a)(1) and 135.419 of this chapter.

(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, Sec. 135.411(a)(1), or Sec. 135.419 shall make an entry in the maintenance record of that equipment containing the following information:

(1) The type of inspection and a brief description of the extent of the inspection.

[THE "BRIEF DESCRIPTION OF THE EXTENT" ABOVE MAY BE INTERPRETED AS A REQUIREMENT TO RETAIN THE CHECKLIST]

(2) The date of the inspection and aircraft total time in service.

(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.

[IF THE MECHANIC IS USING THE SIGNOFF ON THE CHECKLIST ITSELF AS HIS/HER SIGNOFF THEN THE CHECKLIST IN ITS ENTIRETY WOULD HAVE TO BE RETAINED AS A PART OF THE PERMANENT AIRCRAFT RECORDS]

(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement--"I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition."

(5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement--"I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator."

[IF THE DESCREPANCIES NOTED IS ON THE CHECKLIST FORM THEN IT WOULD HAVE TO BE RETAINED]

(6) For progressive inspections, the following or a similarly worded statement--"I certify that in accordance with a progressive inspection program, a routine inspection of (identify whether aircraft or components) and a detailed inspection of (identify components) were performed and the (aircraft or components) are (approved or disapproved) for return to service." If disapproved, the entry will further state "and a list of discrepancies and unairworthy items dated (date) has been provided to the aircraft owner or operator."

[AGAIN, IF THE FORM CONTAINS THE SIGNOFF THEN IT WOULD HAVE TO BE RETAINED]

(7) If an inspection is conducted under an inspection program provided for in part 91, 125, or Sec. 135.411(a)(1), the entry must identify the inspection program, that part of the inspection program accomplished, and contain a statement that the inspection was performed in accordance with the inspections and procedures for that particular program.

[THE EASIST WAY TO INDICATE THE "PART" AND "PROCEDURES" WOULD BE TO INCLUDE THE CHECKLIST AS A PART OF THE INSPECTION RECORDS/ENTRY]

(b) Listing of discrepancies and placards. If the person performing any inspection required by part 91 or 125 or Sec. 135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicable type certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that persons must give the owner or lessee a signed and dated list of those discrepancies. For those items permitted to be inoperative under Sec. 91.213(d)

(2) of this chapter, that person shall place a placard, that meets the aircraft's airworthiness certification regulations, on each inoperative instrument and the cockpit control of each item of inoperative equipment, marking it "Inoperative," and shall add the items to the signed and dated list of discrepancies given to the owner or lessee.

bob.pasch
bob.pasch's picture

8900.1 is NOT regulatory! So please don't use that to substantiate the mandatory nature of the original question. Your [notes] are duly acknowledged but in no way, shape or form do they translate into a mandatory records-keeping authority for checklists. It's black or white, not gray. There is no REGULATORY authority mandating such an act! If you have knowledge to the contrary, please show me in the Federal Aviation REGULATIONS where it makes such action mandatory. BTW, if it were true, the Feds could collect BILLIONS of $$$ in fines just from my last 30 years in this business...

bob.pasch
bob.pasch's picture

And in the case of your Progressive, AAIP or CAMP Programs they all become a permanent part of the aircraft records. Note, I said "aircraft" records, not the A&P, IA, FBO, shop or scab doing the inspection...

wmermelstein
wmermelstein's picture

Bob, you are correct, 8900.1 is not law. It is however what the FAA inspectors go by. They do not use the regulations. The regs are for the FAA legal do write and interpret.

The PMI/POI will only use ther FSIMS to investigate, approve, sureil, etc. They are instructed to not get into the regs. 8900.1 is what they live by. If a mechanic only considers the regulations then they are very likely to be found in violation. Only the FAA legal system or the courts can discuss the meritis of the reg. The FAA principals will only work from the FSIMS.

It may not be fair, but it is reality. Not understanding and considering 8900.1 is a mistake when considering how the regs are interpreted by the FAA.

bob.pasch
bob.pasch's picture

I hear ya & I've been 'discussing' this very subject with the Feds for years. I've challenged them to take me to task numerous times & I am yet to be cited for a violation of any kind but I acknowledge you point!

P.S.
You make an excellent point in having a thorough knowledge of not only 8900.1 but all applicable FAA Orders, it gives the front line techs a definite advantage!

Eric (not verified)
Anonymous's picture

14 CFR 91.417(b)(1)and (2)

91.417 (a)(1)records ...until repeated or superceded or one year.

91.417 (a)(2)records ...retained and transfered when aircraft is sold.

There is no rule which requires the retention of an inspection checklist.

FSIMS is great reference , but as Bill O Brien would " the rules is the rules"

Respectfully,

Eric

bob.pasch
bob.pasch's picture

Respectfully Eric, nice try! First, Part 91 is General Operating and Flight Rules. That's primarily for owners and operators, NOT for maintenance personnel. Second, your elipse [...] omitted major points against you IF your argument was valid, which it is not. Read the description of the records they're referring to in 91.417(a)(1) and (a)(2). No where will you find the maintenance inspection checklist included in that description. Sorry but that doesn't fly...

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