Maintenance Records

March 1, 2001

Maintenance Records

Is there any value other than basic compliance?

By Joe Hertzler March 2001 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 cycle of events known as the maintenance cycle, which is made up of four basic components or segments: flight, inspection, corrective action, and modification.

Flight Cycle – Once the aircraft is delivered to the owner for use (either new from the factory or fresh out of maintenance), the flight segment of the maintenance cycle begins. The length of the flight segment can be limited by two factors: scheduled maintenance and/or component failure. It is important to note, however, that the scheduled inspection program for an aircraft is purposely designed to eliminate component failure. As the aircraft is operating in this flight segment, it is accumulating hours cycles and calendar time.

Inspection Cycle – The next segment of the maintenance cycle is the inspection segment. Recurring inspections performed on a scheduled basis are supposed to identify unsafe conditions that, when corrected, ensure safe operation for the intended inspection schedule. The inspection segment is the physical action taken by qualified individuals trained to find 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 adequate schedule.
The other very common part of the inspection phase is the logbook evaluation or audit. The purpose of the audit is to determine the current status of the aircraft (see AMT Feb. 2001 Issue) and identify any deficiencies in the aircraft’s maintenance records. During the inspection phase all discrepancies found are recorded and it must then be determined what discrepancies are to be corrected.

Corrective Action Cycle – The next segment in the maintenance cycle is the corrective action segment. The corrective action segment is the performance of hands on maintenance (to be performed in accordance with appropriate instructions (see AMT Nov. 2000 issue) to correct the physical defects found and the records deficiencies identified. It is the proper correction of the discrepancies found that determines the airworthiness of the aircraft. If all "airworthiness" issues have been corrected, the aircraft is then approved for return to service. When defects and deficiencies that impact the airworthiness of the aircraft are left undone, the inspection performed is still signed off. However, "a list of uncorrected discrepancies" must be provided to the owner-operator and the aircraft should not be operated until those items are corrected.

Modification Cycle – 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 as previously discussed. The reason 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 FAA methods of approving 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.

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 companies inability to act quickly (one of the reasons they bought the aircraft in the first place) and you can see how unnecessary and 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. Try to accomplish everything that will come due before the next scheduled inspection whenever possible and plan to modify the aircraft in conjunction with and inspection. With the maintenance shops bulging at the seams with work, scheduling for the inspection well ahead of time is essential.

Duplication of Work
Duplication of work is likely the second largest unnecessary expense for aircraft owners/operators. If the scheduled inspection or maintenance item that has been accomplished is not properly recorded in the maintenance records of the aircraft, the maintenance will either be duplicated or time will be spent chasing down a revised maintenance record, proving once again that, "No job is finished until the paperwork is finished." The rules clearly require that the owner/operator examine the maintenance records prior to returning the aircraft to service. This is not only to ensure that the aircraft has been approved for return to service, but just as important, to ensure that all required maintenance entries have been made. Paperwork is never as much fun as fixing the aircraft.
As maintenance providers, we should encourage the owner/ operator to look over the entries (second set of eyes); and as owner/ operators, we should understand the importance of making sure entries are complete and accurate and take the time look them over.
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. As logbook auditors, we commonly find omissions, inaccurate times/cycles, wrong dates, etc.

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, and for our purposes we will assume that the damage was unavoidable — accidents just happen.

For the Record
Records are things we can control, however, incomplete or missing records are things that will greatly impact the value and ability to sell the aircraft.
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? Well think about this: If your particular aircraft is one of several (30 or 40) 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.We can now see the impact that maintenance record keeping has on the cost of maintenance and the overall value of an aircraft.
We sincerely hope that these past three issues on maintenance record keeping have provided some insight and answered a few questions.