Around The Hangar
Back to the Basics
By Joe Hertzler
I continue to receive questions and concerns from readers about the recording of maintenance and the rules governing the responsibilities shared by the aircraft operators and the maintenance personnel. This article, the first of a three-part series on maintenance records, will discuss the role of the maintenance person or organization in recording or documenting the work accomplished. We will cover the rules that govern the recording of maintenance, as well as common traps to avoid.
To begin with it is good to understand that the Federal Aviation Regulations are a subpart of the Code of Federal Regulations (CFR). The CFR includes a series of sections in a subdivision called Title 14. Title 14 of the CFR is referred to as “Aeronautics and Space.” Within Title 14 we find several Chapters. Title 14 CFR, Chapter 1 is titled “Federal Aviation Administration, Department of Transportation,” commonly referred to as Federal Aviation Regulations (FARs). Title 14 CFR, Chapter 1 is then divided into subchapters A through K. Within each subchapter are several parts pertinent to that subchapter’s topic. For example, Title 14 CFR Chapter 1, Subchapter C, is further divided into Parts and this is where Part 43, “Maintenance, Preventive Maintenance, Rebuilding, and Alteration” is found.
This background is intended to help you understand how our aviation regulations, commonly referred to as “FAR Parts,” actually fit into the regulatory framework. It is this framework that provides our industry with minimum standards that, when adhered to, will keep us within the boundaries of actual aviation law.
Performing and recording maintenance
The FAA certifies both persons and organizations to perform maintenance on U.S. registered aircraft. (Reference 43.3) The term “maintenance” is specifically defined in the regulations (Ref 14 CFR Part 1), but for our purposes, maintenance will simply be a general term meaning “inspecting and repairing aircraft.”
Those who are authorized to perform aircraft maintenance also have a responsibility to write down everything that they do in the maintenance records for that aircraft. Why? Well, without this history it would be impossible to ensure that the aircraft has been maintained to the safety standards required by the regulations. To make it easier, 14 CFR Part 43.9 and 43.11 spell out specifically what needs to be included in maintenance records, “Content Form and Disposition” once maintenance has been completed. The 14 CFR Part 43.7 spells out who is authorized to approve for return to service which is different than who can perform maintenance. And finally, Part 43.5 says that an aircraft cannot be approved for return to service until the maintenance record entries required by 43.9 and 43.11 have been completed.
So, a person who is authorized to perform the maintenance performs the maintenance required for the aircraft (Part 43.3). Then, a person approving the maintenance inspects the work that was performed to make sure that it meets the minimum requirements and standards for that aircraft, (often it’s the same person), (Part 43.7). A part of that inspector’s responsibility is to make sure the required maintenance record entries have been made prior to signing for the approval (Part 43.5).
What is “return to service”?
Specifically speaking, “return to service” is when the aircraft actually leaves the ground for flight. This is clarified by Part 1 with the definition of “time in service” as “the time from the moment an aircraft leaves the surface of the earth until it touches it at the next point of landing.” So logically, if the person who performed the maintenance is not an appropriately rated pilot, he or she cannot return an aircraft to service. Such a person can only approve an aircraft for return to service. Details, you say? Well, it does make sense when you apply it to what we are tasked with as maintenance persons. The actual “approval for return to service” is signified by the authorized signature at the bottom of the list of maintenance tasks accomplished (Reference Part 43.9(a)(4)). As such, “approval for return to service” is only approval for those items accomplished.
How much do I have to say
Part 43.9 (a)(1) says your maintenance record entry must include “a description of the work performed.” It does not say “a description of the major work performed,” or “a description of the work you get paid for,” it simply says, “a description of the work performed.” Looking closely at the rule you will find one acceptable substitution, “. . . or reference to data acceptable to the Administrator.” The intent of this statement is to allow us to refer to a specific manual or instruction (acceptable data) that contains the details of the step-by-step procedures used in performing the maintenance rather than writing out all the details. For example, one might make the statement “Installed new emergency exit window in accordance with Learjet maintenance manual, Chapter 56” in a logbook, thus making reference to a document.
One caution though is that the chain of reference to data acceptable to the Administrator can become hard to follow if it is not properly documented. For example, let’s assume the emergency exit window installed in the previous example had been repaired by a separate vendor window repair shop holding a repair station certificate. We would then need to change our statement to read something like this: “Installed repaired emergency exit window in accordance with Learjet maintenance manual, Chapter 56. See XYZ Window Repair Maintenance Release Tag, dated 1/1/99.”
This statement ties the maintenance release tag to the entry, making the tag a required part of the records. Going a little deeper, it’s likely that the maintenance release tag refers to a work order, which then by reference, also becomes a part of the aircraft’s records. The records need to be detailed enough, properly referenced, and easily accessed. Part 91.417 defines clearly what records must be retained and for how long. Some records must be retained for 12 months or until the work is superseded while other records must be retained and transferred with the aircraft when it is sold. Please refer to the regulation for the specific distinction.
The most common trap we maintenance people fall into is the get-it-out-the-door trap. As a group, we are very good at getting the maintenance done correctly and with the highest quality; however, it seems we are always finishing the work right when the aircraft is scheduled to leave and documentation of the work is the last thing on our minds.
Some suggestions that may help you meet the requirements of the regulations:
- Automation of logbook entries. There are many services and products available to help in making complete and accurate entries.
- On large projects, write down what you do each day in your work order or logbook entry draft to help make your entries complete.
- Understand the chain of “reference to data acceptable to the Administrator.” Losing a link in that chain can be very costly both to you and the aircraft owner.
- Remember – in the eyes of the FAA as well as the next person to purchase the aircraft, if you don’t write it down, you didn’t do the work.
In the July issue we will offer a look from the perspective of the aircraft owner/operator. The management of the maintenance records is a shared responsibility and the owner has as many rules to abide by as those performing the maintenance.
Joe Hertzler is the president of AVTRAK Inc., an Aurora, Colorado-based company.
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