Around The Hangar
Maintenance Records, Part 3
Smart management = complete records
By Joe Hertzler
This is the third of a three-part series discussing maintenance records. The first part focused on the role of maintenance personnel and organizations in the recording of work accomplished, and the second part discussed what records are required for an aircraft owner/operator as described in 14 CFR Part 91.417(a)(1)&(2). In this part, we will discuss the value of complete and accurate record keeping.
The maintenance cycle
Aircraft go through a repeatable and predictable series of events I like to refer to as the maintenance cycle. The maintenance cycle is made up of four basic components or segments: flight, inspection, corrective action, and modification. Let's look at each segment from a practical point of view.
Flight segment ' Once the aircraft is delivered to the owner for use (either new from the factory or fresh out of maintenance or modification), the flight segment of the maintenance cycle begins. The length of the flight segment is limited by two factors: 1) scheduled maintenance and/or 2) component failure. It is interesting and important to keep in mind that the scheduled inspection program (which is made up of several scheduled maintenance events) for an aircraft is purposely designed to eliminate component failure as well as minimize downtime. As the aircraft is operating in this flight segment, it is accumulating hours, cycles, and calendar time and as such is constantly moving closer to its next scheduled maintenance event.
Inspection segment ' The next segment of the maintenance cycle is the inspection segment. Recurring inspections performed on a scheduled basis will identify potentially unsafe conditions that, when corrected, ensure safe operation for the remainder of the intended inspection schedule. The inspection segment describes the physical action taken by qualified individuals trained to isolate defects that have developed as a result of the flight segment(s). An aircraft inspection is required to be performed using a checklist. The obvious purpose of the checklist is to avoid forgetting any portion of the inspection and allow an inspection program to be divided up into a logical and efficient schedule. During this segment inspection is not just limited to the physical aircraft. A critical part of the inspection phase is a maintenance records (logbook) evaluation or audit. The purpose of a logbook audit is to determine the current status of the aircraft and identify any deficiencies in the aircraft's maintenance records. During the inspection phase any discrepancies found are recorded and for the most part must be corrected prior to returning the aircraft to service.
Corrective action segment ' The next segment in the maintenance cycle is the corrective action segment. The corrective action segment is obviously the performance of hands-on maintenance in order to correct any physical defects found as well as any records deficiencies identified through the records evaluation. The proper correction of the discrepancies found will determine the airworthiness of the aircraft. Once each item has been corrected, another inspection is conducted to verify adequate and complete correction of the discrepancy. If all discrepancies that affect 'airworthiness' have been corrected, the aircraft is then eligible to be approved for return to service. The approval for return to service is a written certification (by a properly certificated person or agency) that indicates that the aircraft meets all regulatory airworthiness requirements. When defects and deficiencies that impact the airworthiness of the aircraft are left undone, the inspection performed may still be signed off, however in this case, 'a list of uncorrected discrepancies' must be provided to the aircraft owner-operator and the aircraft may not be operated until those items are corrected. This is to allow for the correction of discrepancies by someone other than the person or agency that found them.
Modification segment ' The fourth and final segment in our definition of a maintenance cycle is the modification segment. Often, an aircraft owner will decide that the aircraft would better fit their needs if it was modified. Modifications are either major or minor in nature. One reason I choose to include the modification segment in the maintenance cycle is the possible significance that modification can have on the inspection segment. According to FAA policy, all major modifications should come with Instructions for Continued Airworthiness or ICA's. These instructions may include new inspection and/or maintenance requirements that must be meshed into the current inspection program for the aircraft. The two basic methods the FAA uses for approving aircraft modifications are STCs (Supplemental Type Certificates) and FAA Field Approvals, the latter of which is getting to be less and less common.
So, we then return to the flight segment and continue the maintenance cycle for the life of the aircraft. Having complete and accurate maintenance records can simply make the maintenance cycle more predictable and much less expensive. Following are some ways that having accurate and complete maintenance records can make a difference for the cost of the operation of your aircraft.
What it costs
One of the most costly, though somewhat intangible, expenses incurred by an aircraft owner-operator is downtime. Because the aircraft is an asset to the company, it usually has an ongoing interest cost regardless of its availability for use. Add to that, the cost of alternative transportation, and the possibility of lost business from the company's inability to act quickly (one of the reasons it bought the aircraft in the first place) and you can see how unplanned downtime must be avoided. The only way to manage downtime is to get your arms around the maintenance requirements and the utilization of the aircraft and effectively plan the maintenance to be accomplished. It is a good idea to try to accomplish everything that will come due before the next scheduled inspection whenever possible and plan aircraft modification in conjunction with a scheduled maintenance event. With the maintenance shops bulging at the seams with work, scheduling for the inspection well ahead of time is essential to be sure when the aircraft will be out of service.
Duplication of work
Duplication of work is likely the second largest expense for aircraft owners/operators and is not only unnecessary but will cause wear and tear on the aircraft. If the scheduled inspection or maintenance item that has been accomplished is not properly recorded in the aircraft maintenance records, the maintenance will either be duplicated or time will be spent chasing down a revised maintenance record, reinforcing the old saying that, 'No job is finished until the paperwork is finished.' The rules clearly require the owner/operator to examine the maintenance records prior to returning the aircraft to service. This is not only to ensure the aircraft has been approved for return to service properly, but just as important, to ensure that all required maintenance entries have been made. Paperwork is never as much fun as fixing the aircraft and is therefore many times completed in a rush and with half the effort.
As maintenance providers, we need to encourage the owner-operator to look over the entries (second set of eyes), understand the importance of making sure entries are complete and accurate, and take the time to look them over in detail.
Most maintenance providers would much rather make needed corrections up front than get a call in six months asking for a new entry. And, we are all susceptible to making mistakes. Our logbook auditors commonly find omissions, inaccurate times/cycles, wrong dates, etc., all of which cost more to correct after the fact.
When it is time to sell
Not only does the accurate and complete recording of maintenance have a significant impact on the ongoing operational cost of an aircraft, the overall value of the aircraft is impacted as well.
Arguably, the most revealing pre-buy inspection is a good audit of the aircraft records. A complete audit will identify the current status of the aircraft as required by 14 CFR 91.417, uncover time frames of no maintenance, identify inaccurate engine cycle tracking as well as aircraft time tracking and reveal aircraft damage history. Once an aircraft has been damaged, it is difficult to establish a value that is as high as the identical aircraft with no damage.
For the record
Incomplete or missing records will greatly impact the value and ability to sell the aircraft. The completeness and accuracy of an aircraft's maintenance records is something we can control with very little effort.
We have seen missing blocks of time or missing logbooks impact the value of a used aircraft as much as 25 percent. For a $2.5 million aircraft that figure is $625,000. Hard to believe isn't it? Well think about this: If your particular aircraft is one of several available at the time you are ready to sell and you are missing a large block of maintenance records for some reason, the aircraft with complete and accurate records will sell first, no doubt. And, when you are faced with a must-sell situation, you will be forced to reduce the price significantly in order to move the aircraft.
So, we can see how important complete and accurate aircraft records are. The regulations set up the framework for maintenance recording. They dictate what must be recorded, by who, and when, in addition to what records must be transferred with the aircraft.
I hope that as a result of reading this article you have a new appreciation for the impact that maintenance record keeping has on the cost of maintenance and the overall value of an aircraft.
Joe Hertzler is the president of AVTRAK Inc., an Aurora, Colorado-based company. He is an A&P mechanic with Inspection Authorization and also a private pilot.