Maintenance Records: What Constitutes a Complete Set?

Avtrak Inc., Federal Aviation Administration Info: 14 CFR Part 91.417 is the regulation that spells out the required maintenance records for an aircraft. Author Joe Hertzler describes each paragraph to help fully understand the requirements.


In this issue we will outline what aircraft maintenance records are required for an aircraft owner/operator. 14 CFR Part 91.417 is the regulation that spells out the required maintenance records for an aircraft. We will dig deep into the details of each paragraph in 14 CFR Part 91.417 (a) (1) and (2) and in the end fully understand the requirements.

The logbooks — Is That All There Is?

The “logbooks” for an aircraft come in many different packages. One aircraft’s set of logbooks may have one airframe logbook, and a logbook for each engine and each propeller supplemented by a dozen or so maintenance release documents (yellow tags or 8130s), while an identical aircraft with the same amount of time could easily have six 4-inch three-ring binders full of documents, (each including individual signature for the maintenance described on the card) and three other 4-inch binders filled with work orders and maintenance release documents, all in addition to the original airframe, engine, and propeller logbooks provided with the aircraft when it was new.

But regardless of the format or quantity of logbooks and maintenance records for an aircraft, the question at hand is “what content is required by regulation?”

14 CFR Part 91.417 spells out what maintenance records are required and how long those records must be kept by the owner/operator. To simplify the discussion lets divide the maintenance records called out in this rule into two different categories. Category A (permanent records) and Category B (expiring records).

Permanent Records — Category A

“Category A” records are those maintenance records that must be kept and maintained for the aircraft indefinitely. Category A records reflect the current “status” of the aircraft with respect to issues such as inspections, life-limited parts, major changes to type design, and AD compliance. Looking at 14 CFR Part 91.417 (a)(2) we see the list of records that must be “retained and transferred with the aircraft at the time the aircraft is sold” (Ref 14 CFR Part 91.417(b)(2)). As we step through this list of record types let’s discuss each type of record specifically addressed.

Total Time in Service
14 CFR Part 91.417 (a)(2(i)

Having a record of the total time in service of the airframe, each engine, each propeller, and each rotor is simply a matter of keeping track of time accumulation. In order to do that effectively we need to first know the definition of “time in service”.That definition is found in 14 CFR Part 1 and basically defines “Time in Service” as being from the time the tires on the landing gear leave the ground during take off to the time the tires touch back down at the point of landing. In a normal situation this would be very simple. Most aircraft are equipped with an hour meter that is tied to a landing gear squat switch and begins counting time when the aircraft leave the ground and then stops when it touches back down, thus keeping accurate and correct time. When it gets tricky is when the hour meter breaks or is replaced, or when engines, propellers, and rotors are replaced with new or time continued components. In such a case you have to be sure to carry over the correct times prior to the beginning of each flight. With an airframe, two engines, and two propellers it is possible to have five different total times to keep track of and tally up each day or week.

There are some challenges to keeping up with total times. Like in the case of rebuilt engines, propellers with unknown total time, and engines whose time is tracked independently on individual modules. Each of these cases is addressed in FAA Advisory Circular 43-9C “Maintenance Records” (see paragraph 5. (g)(1)(a), (b), and (c); and Paragraph 12).

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