To pick up where we left off, we’ll discuss the aircraft maintenance record keeping requirements. While this particular regulation pertains to the average general aviation owner, it also may apply to part 135 on-demand charters operating aircraft excluding a pilots seat, of nine seats or less. Aircraft maintenance records are sometimes referred to as aircraft log books and a host of recordkeeping formats are in use today. The FAA does not approve the format; it’s up to the owner. I once had a discussion with a gentleman who insisted that the FAA approves each and every format. I replied that if he can find that requirement in the regulations then I would eat crow. That was 6 years ago, he still hasn’t produced evidence of his claim. I think these things just arise from folklore fueled by miscommunication or misunderstandings. At the end of the day you need to maintain maintenance records for your aircraft, the format is up to you.
Clarity and Content. As previously discussed, you are responsible for ensuring that maintenance personnel make appropriate entries indicating the aircraft has been approved for return to service. The signature of the maintenance technician constitutes approval only for the work performed. If you cannot read or understand what was recorded in your records then you need to sit down with your tech and discuss the fine art of written communication. There is precedence in regard to maintenance record entries, which were provided to me years ago by FAA Regional Council:
14 C.F.R 43.9 requires mechanics to “include a description of the work performed”. The regulation provides no definition or standard as to what terminology adequately satisfies the ”description” requirement. However, a review of NTSB decisions reveals several cases, which provide some guidance. Reeve’s Aviation involved a logbook entry, which contained only the word “repaired” in the remarks. The NTSB held that the mere use of the adjective “repaired” was inadequate as such lack of detail did “not necessarily tell the reader what was done” concerning the repair given a reasonable construction.
Similarly, in Swanson, the National Transportation Safety Board (NTSB) upheld a finding of § 43.9 violation where the mechanic used a “C/W” notation for “complied with” concerning a repair to a right wing’s trailing edge. Although the “C/W” entry was not in the logbook, but rather made on an Aircraft Condition Notice (FAA Form 8620-1), the NTSB nevertheless assumed for purposes of determining whether “C/W” was adequate, that the “C/W was a logbook entry. Accordingly, it held that the mechanic’s entries failed to specify what type of repair or corrective action he took, and thus, violated § 43.9(a)(1). Further, in Scott, the NTSB upheld a license suspension in which a mechanic had used the notation “all AD’s C/W.” The NTSB held that the notation was “meaningless without some reference to which AD’s were applicable to the aircraft, and the method of compliance.”
What records am I required to keep? The regulation starts off simply enough by indicating which records have to be maintained and for how long. The rule makes an exception for § 91.411 and § 91.413 checks, which are altimeter system altitude reporting equipment and ATC transponder tests and inspections respectively. Those checks are required to be performed each 24 calendar months. Maintain tangible evidence that the checks have been accomplished, if applicable.
Section 1 The following is a list of records that you must maintain:
- Maintenance (Maintenance record entries must meet the requirements of § 43.9, see below for content.)
- Preventive maintenance (Those maintenance items listed in part 43 Appendix A; if you perform any then you are not exempt from making a maintenance record entry per § 43.9. Refer to AC 43-12A Change 1, Preventive Maintenance)
- Alteration (The rule makes no distinction between minor or major alterations. Both require a maintenance record entry meeting the requirements of § 43.9 and in addition to the entry any majors performed must be accomplished in accordance with FAA approved data (think Supplemental Type Certificate (STC) or Field Approval), and recorded on an FAA Form 337, Major Repair and Alteration.
- 100-hour Inspection, as applicable.
- Annual Inspection, as applicable.
- Progressive Inspection, as applicable, or
- Other Required or Approved Inspections.
These records at a minimum must contain a description (or reference to data acceptable to the FAA) of the work performed, the date of completion of the work performed, the signature, and certificate number of the person approving the aircraft for return to service. Keep in mind that the “person” referred to could also be a part 145 Repair Station if you have your maintenance performed at one of the many FAA certificated facilities. Inspection record entries must also contain the aircrafts total time in service. True total time in service as defined by the FAA with respect to maintenance time records, “means the time from the moment an aircraft leave the surface of earth until it touches it at the next point of landing.” If you’re going by tach or hobbs time you may be short changing yourself.
Section 2 Records containing the following information must also be maintained:
- The total time in service of each airframe, engine, propeller and/or rotor.
- The current status of life-limited parts of each airframe, engine, propeller, rotor or appliance. An appliance according to the FAA means “any instrument, mechanism, equipment, part, apparatus, appurtenance, or accessory, including communications equipment, that is used or intended to be used in operating or controlling an aircraft in flight, is installed in or attached to the aircraft, and is not part of an aircraft, engine or propeller. “Got to hand it to the FAA for leaving no stone unturned in that definition, I was beginning to break a sweat reading it”!Life-limited according to the FAA, at least in § 43.10 Disposition of Life-Limited Aircraft Parts, means “any part for which a mandatory replacement limit is specified in the type design, the Instructions for Instructions for Continued Airworthiness (ICAs), or the maintenance manual. Think FAA Approved Airworthiness Limitation section of a manufacturers manual or ICAs. FAA issued Operations Specifications come into play for part 135 on-demand operations.
- The time since last overhaul of all items installed on the aircraft, which are required to be overhauled on a specified time basis.
- 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.
- The current status of applicable Airworthiness Directives (ADs) and safety directives including for each, the method of compliance, 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. Refer to NTSB vs. Scott above.
- Copies of FAA Forms 337 for each major alteration to the airframe, engines, rotors, propellers and appliances.
Retention of the stated records is a follows;
The records discusses in Section 1 must be retained until the work is repeated or superseded by other work or for 1 year after the work was performed. If you live to the letter of the law and decide to only retain these records for a year then you’re going to have a very difficult time selling the aircraft or researching any specific maintenance history. You may also induce a myocardial infarction in your maintenance tech. All though not required as you can see, I would suggest keeping the records from cradle to grave if you’ve got them. There is nothing more unnerving then trying to do research on an aircraft with limited records. While I understand the premise, it doesn’t’ t make good business sense to toss older records.
Years ago I worked in a Repair Station and every once in a while a former customer would show up desperately looking for any records we might have archived. They usually had the same tale about how they were trying to sell their aircraft and couldn’t find takers because many of their older records ended up in that place socks occupy when you loose them in the drying cycle. Does it really make sense to toss any of your records since they can provide trend analysis data and valuable history? Think before you toss and I would even go as far as making scanned copies to keep as a back up; it’s cheap insurance.
The records discussed in Section 2 must be permanently retained and transferred with the aircraft. You are also required to make your records available to the FAA or any authorized representative of the NTSB.
But wait there’s more! If you decide to a have fuel tank installed within the passenger compartment or a baggage compartment (think ferry fuel system), then you are required to keep a copy of the FAA Form 337 Major Repair and Alteration form on board.
This basically sums up § 91.417; there are a couple of more rules which cover the transfer of records and rebuilt engine maintenance records which you can peruse at your leisure. The FAA publishes Advisory Circular 43.9C, which contains an indebt discussion and section-by-section breakdown of the requirements of § 91.417. It also contains a discussion on reconstructing your records if you’ve lost or misplaced them or if your puppy shredded them. In the end, the aircraft is typically only as valuable as the records that accompany it. Clear and concise maintenance records coupled with a well-maintained aircraft can only enhance your investment and keep you in the safety zone.
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