Maintenance Records

Maintenance Records Are they all there or do we need more? By Joe Hertzler February 2001 This is the second of a three-part series discussing maintenance records and the regulations that require we record the maintenance we perform...

Time since overhaul-14 CFR Part 91.417 (a)(2)(iii)
Overhaul times are generally called out in maintenance manuals and service information. The maintenance manual usually lists the items that the manufacturer requires be overhauled. The rule requires that we be able to show the time since last overhaul for those items.
Incidentally, this rule does not mandate the overhaul of such items, just the recording of the time since last overhaul. For operations conducted under 14 CFR Part 91, overhaul is not a mandatory requirement as long as the item continues to pass required inspection criteria, although it is usually very desirable to perform overhauls at the recommended intervals.

Inspection Status-14 CFR Part 91.417 (a)(2)(iv)
14 CFR Part 91 discusses inspection requirements. The requirements can vary greatly depending on aircraft classification. They can range from annual inspections on G.A. aircraft to phase inspections on the larger more complex ones. Special inspections that are tracked by landings or cycles may also need to be recorded.
In order to be able to provide the current inspection status of an aircraft required by the rule, the following should be answered:
1. What inspection program has been selected for the aircraft?
2. What are the required look phase inspections and special inspection for my airframe, engines, propellers, rotors, appliances, survival equipment, and emergency equipment installed on my aircraft?
3. When was the last time that each of the required inspections was accomplished?
4. When is the next time each items is required to be accomplished again?

Airworthiness Directives-14 CFR Part 91.417 (a)(2)(v)
Accurate and complete maintenance records will include proper documentation of AD compliance throughout the records as each AD is complied with. It is only practical however, to create a list of all applicable AD’s and identify in that list, the information required by this rule:
• The AD Number
• The Topic of the AD (optional)
• The revision or effective date of the AD (not the amendment number)
• The method of compliance for the AD
• If the AD requires recurring action, the time and/or cycles and date it will next be due

Major Alterations (FAA Form 337)14 CFR Part 91.417(a)(2)(vi)
This rule requires that only FAA Form 337’s that document Major Alterations need to be retained permanently and transferred with the aircraft. However, the value of the aircraft can be greatly impacted without all FAA Form 337’s. It is usually a good idea to keep all 337’s including those for Major Repairs - even if they are kept in a separate binder. This practice can also assist maintenance personnel who may need to refer to a 337 in order to answer maintenance questions.

Expiring Records-14 CFR Part 91.417 (a)(1)
Now, let’s talk about items we will call expiring records.
14 CFR Part 91.417 (a)(1) reads as follows:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include:
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service.
Maintenance records that fall into this category are required to be kept until the work is accomplished again or for a period of 12 months (Ref 14 CFR Part 91.417 (b)(1)). This indicates that these records, if not superceded by new identical records within the first 12 months following approval for return to service, may be discarded. (CAUTION: DON’T DISCARD THOSE RECORDS). Expiring records include, maintenance performed (including Major Repairs), preventive maintenance performed, minor alteration records, and records of inspections. Although inspection records (100-hr, annual, and progressive) do not need to be retained when they have been superceded within the required 12 months, this does not alleviate the requirement to keep the current status of inspections.
Next issue we will wrap up our Maintenance Records Topic in a discussion about the impact of accurate maintenance records on the value of the aircraft and the re-generation of lost or stolen maintenance records.

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