Aviation maintenance technicians who support business aircraft fleets often work under their Part 65 mechanic certificate with powerplant and/or airframe ratings and inspection authorization. This makes them vulnerable to vagaries of aviation safety inspectors who ramp check aircraft and find anomalies or who believe something perfectly acceptable to a local office is noncompliant. There is no protection against a government representative who is “out to get” an individual or business. However, there are protections against blatant misrepresentations of facts or regulations.
Let’s take maintenance records. When a mechanic makes a maintenance entry, she or he must think about what the words will convey to another person as well as ensure they represent the exact extent and nature of the work that was approved for return to service. If the record is so skimpy the next person performing work in the same area or on the same article can’t figure out what was done or the person performing the work can’t remember what was done, it will create issues when placed under scrutiny.
Some may claim the less said the better, under the theory there are fewer words about which to argue. That philosophy ignores the downside of having to redo work that wasn’t clearly recorded. The performance of work is what the rule requires be recorded, it is best to ensure both are represented properly.
The regulation demands “[a] description (or reference to data acceptable to the Administrator) of work performed;” the words used by the mechanic will be what is approved for return to service. The best protection for ensuring compliance is to provide an explanation in enough detail that a person unfamiliar with the work but knowledgeable of the requirements (the regulations) can determine what was done. This may make necessary both a narrative of the work and a reference to the maintenance data used.
In other words, will the person making the record remember what was done when looking at the record a year or two from the time it was made? Will someone who is looking for information on the extent and nature of the work be able to figure out what was inspected, repaired, or replaced, and when something was due or done?
If your maintenance record is clear, questions about what was done can be answered based upon fact and regulation. The protection afforded by a thoughtful maintenance record will not eliminate vagaries of government inspectors, but it will go a long way toward establishing professionalism and trust.
Sarah MacLeod is a managing member at the law firm of Obadal, Filler, MacLeod & Klein, P.L.C. and is engaged in the legal representation of foreign and domestic air carriers, aircraft maintenance and alteration facilities, distributors, pilots, and other individuals and companies in federal court and before federal administrative bodies. She also serves as assistant chair for Air Carrier and General Aviation Maintenance of the FAA’s Aviation Rulemaking Advisory Committee, a post she has held since 1996. A globally recognized expert in aviation regulatory compliance, Ms. MacLeod is a sought-after speaker and has appeared at numerous aviation and MRO events. She is admitted to the bar in Virginia.
Sarah MacLeod is executive director of the Aeronautical Repair Station Association (ARSA), an organization she helped found more than 25 years ago.