Aircraft Record Keeping

Poor records, either the way they are produced or in the way that they are stored, will lead to huge financial losses when aircraft, engines or parts are sold or leased. Planes that are worth millions of dollars may only be worth scrap value if the records are not managed properly. Or they may require a major maintenance check, costing hundreds of thousands to make the aircraft compliant and attractive to new owners or lessors. Accurate data, accessibility, and safe storage of records are vital if you own or operate an aircraft.

Who is responsible for record keeping? Under part 91.7 the owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition. Part 91, sect;91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration. (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless— (1) It has been approved for return to service by a person authorized under sect;43.7 of this chapter; and (2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made.

These terms and conditions are further restated, in block 6, on the front of FAA Form 8100-2, Standard Airworthiness Certificate. Qualified persons, who perform the maintenance, preventive maintenance and alterations, shall make a record entry of this accomplishment, thus maintaining the validity of the certificate of airworthiness.

Adequate aircraft records provide tangible evidence that the aircraft complies with the appropriate airworthiness requirements. In accordance with the terms and conditions listed in block 6 of the Standard Airworthiness Certificate, insufficient or non-existent aircraft records may render that standard airworthiness certificate invalid. An FAA mechanic with and Airframe and Powerplant rating we become charge to make a proper record entry in accordance with Part 43 Section 43.9 that includes: 1) Description of maintenance performed reference to the data used or a big story explaining what we did. 2) Date of completion of the work performed. 3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section. 4) Work was performed satisfactory, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

For many of us mechanics we may not of read section 43.9 recently or did not realize that if someone help us perform maintenance their name must be in the record entry. In addition, we have to state the work was performed satisfactory on the item we performed maintenance on.

When making record entries it is import what we write in record entries as well as what we don't write. It is those things we don't write in records that seem to get the attention of the FAA when the perform record inspections on maintenance or inspections mechanic perform.

Something that most mechanics may not realize is the owner or operator is charged to make sure mechanics make the proper record entry, kind of our Quality Control, if you will. Part 91, sect;91.405(b) Maintenance required. (b)Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service.

There is a growing trend toward computerized maintenance records. Many of these systems are offered to owners/operators on a commercial basis. While these are excellent scheduling systems, alone they normally do not meet the requirements of sections 43.9 or 91.417.

The owner/operator who uses such a system is required to ensure that it provides the information required by Part 91 section 91.417, including signatures. If not, modification to make them complete is the owner/operators responsibility and that responsibility may not be delegated.

If you are using digital record keeping you may what to check and see it the program and software meets the requirements of Part 43 Section 43.9 and 91.417 the signature requirement. You may have to keep a paper record to meet the signature requirement. Occasionally, the records for an aircraft are lost or destroyed and having a digital record as a backup is one way to reconstruct records that were lost or destroyed. In order to re-construct them, it is necessary to establish the total time-in-service of the airframe. This can be done by reference to other records that reflect the time-in-service; research of records maintained by repair facilities; and reference to records maintained by individual mechanics, etc. When these things have been done and the record is still incomplete, the owner/operator may make a notarized statement in the new record describing the loss and establishing the time-in-service based on the research and the best estimate of time-in-service.

Keep in mind establishing total time is the owners or operators responsibility, NOT the mechanic that is reviewing the records. Only the owner or operator can make a notarized statement in the new the record establishing the time-in-service. If an owner does lose, the records have them order the aircraft records on CD from the FAA aircraft records branch in Oklahoma City. These records will provide a base line to start your record search and reconstruction. For all maintenance record entries section 43.9 must be followed. For all inspections sections 43.11 and section 91.417 must be followed. All inspection required total time in accordance with section 91.417 and maintenance record entries for the most part do not. However, it is a good idea to include tack time or total time with maintenance records for tracking purposes.

A good reference for all mechanics for aircraft maintenance records is AC 43.9C Maintenance Records available for download on the FAA web site under AC's.

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Nice paragraph... whew

As we move from a paper to digital world we have increased capabilities for recordkeeping including the ability to record maintenance against individual components. In the paper days if you changed the brushes on a starter you made a record in the maintenance logbook. The records were in the airframe, engine or prop logbook.

In a digital world we now have the ability to track/record component maintenance to the individual components. There has even been done work on using RFID tags to attach component information including history to the individual components. This allows thousands of “mini logbooks” that can roll up to provide a view of the complete aircraft records making the aircraft or engine logbook a dynamic logbook.

So, what happens to this dynamic logbook as components are changed out? The paper logbooks provided a view into historical maintenance that was performed on components that are no longer installed. Dynamic logbooks will show the history of the aircraft in its’ current configuration. Using the starter brush change example once the starter is removed so are its’ records from the aircraft logbooks.

All changes present positive and negative features. I would be interested in members’ thoughts on digital recordkeeping and dynamic logbooks.