Paper Chase

Oct. 1, 2002
Reviewing records for an inspection

Reviewing aircraft records prior to performing an inspection is about as exciting to mechanics as being selected as the keynote speaker at the annual Kaopectate picnic. We know that the record review is important, but we are less than enthusiastic with the paper chase because most mechanics are visually based people. We are more comfortable seeing things in three dimensions and maintenance records are so, well they are so two-dimensional and not that interesting to our discerning eye.

Besides just building up the energy to review the records the next most common complaint I have heard from mechanics is the average aircraft maintenance records look as if they were organized and collated by Larry, Moe, and Curley.

The third biggest problem in the GA world of record keeping is missing records or records that are unreadable because they were damaged by water, sunlight, mildew or something too nasty to mention here. I will tell you how to solve the problem with missing or damaged records in a minute, but let’s start with a quick review of the records we are supposed to cast a jaundice eye at.

First, a question! Who is responsible for the aircraft records? Almost all mechanics know that section 91.417 says the owner/operator is primarily responsible to maintain aircraft records.

Second question. What records should a mechanic review when performing an inspection? Again section 91.417 provides the answer but the answer is in two parts.

Part one or more accurately section 91.417(a)(1)(i)(ii ) says that each registered owner or operator must keep records of maintenance, preventive maintenance and alterations and records of 100-hour, annual, progressive, and other required or approved inspections as appropriate for each aircraft. The records must include a description of, or reference to, the data acceptable to the Administrator of the work performed, the date it was signed off, and the signature and certificate number of the person approving the aircraft for return to service.

Now here is the kicker. The owner or operator only has to keep those records until the work is repeated or superseded by other work, or for one year after the date the work was performed. For example, if more than a year has gone by since the last annual and you can’t find any reference to the minor maintenance that was performed during the last annual you probably figured those records were missing. In reality those records weren’t required to be there in the first place.

Part two or section 91.417(2) says the owner or operator must keep the following records forever or until transferred with the aircraft when it is sold.

1. Total time in service of each airframe, engine, propeller or rotor. While it sounds simple enough sometimes total time is difficult to figure out. Especially when every other entry uses tach time, or hobbs, or daylight savings time. Another problem that comes along and makes your day is when you discover that a tach or hobbs meter is changed in the dim past and there is no notation in the records of previous hours.

2. Current status of life limited parts. This really affects aircraft built under FAR 23 or FAR 25 which assigns life limits for aircraft structures, engines, etc. from day one. While it is true that the vast majority of aircraft built under the older CAR-3 rules did not have life limited parts you cannot take it as a matter of faith that your older aircraft does not have an assigned life limit. Some Supplement Type Certificate (STC) have life limits and they may be installed on your aircraft so to be on the safe side check the aircraft’s Type Certificate and STC list just in case.

3. The times since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time base. You have to check any Airworthiness Directives (AD) that mandate overhaul times, or if the aircraft is being operated under Part 135 you have to review the aircraft’s operating specifications. Turbine engines of modular construction may have four or five different overhaul times that need to be tracked.

4. The current inspection status of the aircraft. This includes the time since the last inspection under which the aircraft and its appliances are maintained. If it is over a year since the last annual, and the owner does want to keep all the records from the last annual that’s fine. However, he still needs to show the inspection status of his aircraft. This can be accomplished by showing the date of the last inspection, total time, the kind of inspection performed, and the name and certificate of the mechanic who performed the inspection in the aircraft records on a separate document or page in the aircraft records.

5. Current status of applicable Airworthiness Directives (AD). This AD checklist as it is usually called takes the form of an extra sheet of paper stapled in the back of the appropriate aircraft logbook. The checklist should give the AD number, the method of compliance, revision date if any, and who signed it off. If the AD is recurring it needs to show the date and time when it is due. Having an AD recorded checklist does not take the place of a section 43.9 entry unless all requirements for a sign off are met.

6. Copies of each Form 337 for each Major Alteration for the airframe, and currently installed, engine, rotors, propellers, and appliances. At first glance it looks as if the framers of the rule forgot to include Major Repairs in the rule. Not so! A Form 337 Major Alteration has to be kept forever because a Major Alteration changes the type design of the aircraft or one of its components parts. So you need a record of that change. A Major Repair on the other hand restores the damaged part or area back to its original Type Design. So a year later and after another inspection has been performed, the owner can file the Major Repair Form 337. Not to worry, the Major Repair Form 337 is still on file in the aircraft’s file in Oklahoma City.

While this is not called out in the rule’s language please don’t forget that each STC applied for after January 1981 and each Field Approval for a major alteration applied for after January 1999 are required to have Instructions for Continued Airworthiness (ICA) for that alteration. The ICA usually details specific inspection and maintenance requirements to be performed and when they are to be performed.

Let’s say you did an annual inspection in accordance with the manufacturer’s checklist but you did not follow any of the aircraft’s ICA inspection requirements. If you signed off the annual, you did in fact sign off a bad inspection. How so? Since the STC or Field Approval changed the Type Design of the aircraft, but you inspected the aircraft according to its original TC and did not inspect the areas that were changed in accordance with ICA, the inspection was incomplete The FAA frowns on such actions.

Missing or damaged records: One memorable moment in my FAA career happened when I was assigned to the local FSDO. Bright and early one Monday morning a Cessna 182 pilot came into the office holding a green trash bag tightly at the neck. I asked if I could help him. He immediately went into a spirited dissertation about himself and his three buddies that hit rough air while flying home from a fly-in breakfast on Sunday. In the middle of a particular severe down draft, he was notified that one of his back seat passengers was turning green. Ever the pilot in command he yelled: "Use the sick sack! It’s in the seat pouch behind me!" Unfortunately the seat pouch also contained the aircraft logbooks in a black leather zipper case. The rest they say is history. The pilot then asked if I wanted to see what was left of the records. I respectfully declined to take a peek but gave him the answer to his unasked question.

First, it will take a lot of patience and time to recreate the aircraft records. You must have the same amount of information required by section 91.417 that we just went over. Determining total time could be a problem if the tach was changed. But that will be a cake walk compared to determining the AD status of the aircraft, engine, propeller, and appliances. In some cases ADs might have to be performed again and signed off.

As far as obtaining copies of STC or major repairs or alterations performed on the aircraft, you can request a copy of the aircraft’s file from Aircraft Registry in OKC, at (405) 954-3116. A CD of the aircraft’s file will cost you $5.00 plus $3.00 if you want it "certified true copy." A paper copy of the aircraft’s file will cost you $2.00 for the search, $.0.25 for the first page and $.05 for every page there after. If you have an old aircraft, an additional $2.00 may be charged if they have to go to the archives to find the records. Certified true copy will also cost $3.00 for a paper copy.

Asking for duplicates of invoices or work orders from repair stations or FBO shops where the aircraft was worked on in the past might save some more time. Additional information on rebuilding records can be found in AC 43.9 Maintenance Records.

When the records are put together the owner must make a notarized statement in the aircraft records or logbooks describing how the records were lost or destroyed. The statement should also say that to the best of his knowledge the records reflect the best estimate of the aircraft’s status and time in service.

To avoid future problems dealing with lost or damaged aircraft records, I have two recommendations. First, tell the owner not to throw away any record, even if the rule says it’s OK to do so. Second, tell the owner to make a duplicate copy of his maintenance records, STC, Form 337, registration, and airworthiness certificates. On the front of the airworthiness certificate write the words in ink: "copied for record keeping purposes only" so you won’t be accused of copying a certificate that says on its front not to copy it. So in closing, just a little time in front of a copier will eliminate the need for the owner or you to participate in the paper chase.

About the Author

Bill O'Brien