Are you writing it all down?
In the first of a three-part series, we will discuss specifically the role of the maintenance person or organization regarding the recording or documentation of work accomplished, what rules affect the recording of maintenance, as well as common traps to avoid.
A brief overview of the Federal Aviation Regulations framework and how the rules are organized is a good place to start. The Code of Federal Regulations (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 that Title, are several Chapters and Chapter 1 is titled "Federal Aviation Administration, Department of Transportation," commonly called the Federal Aviation Regulations (FARs). 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, titled "Maintenance, Preventive Maintenance, Rebuilding, and Alteration" is found. This background is given not to bore you, but simply to help you understand how these parts, commonly referred to as "FAR Parts," actually fit into the regulatory framework, and to provide us with minimum standards that, when adhered to, will keep us within the actual law.
Performing and recording
FAA-certified maintenance persons and organizations are authorized to perform maintenance. - Reference 43.3. The term maintenance is specifically defined in the regulations (Ref 14 CFR Part 1), but in the context of this article, maintenance is a general term meaning "inspecting and fixing broken airplanes."
Those who are authorized to perform maintenance also have a responsibility to write down everything that they do. Why? Well, Part 43.9 and 43.11 spell out what needs to be included in maintenance records, "Content Form and Disposition." Part 43.7 spells out who is authorized to approve for return to service, (This 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, the person who is authorized to perform the maintenance performs the maintenance (Part 43.3). Then, the person approving the maintenance inspects the work, often it's the same person, (Part 43.7); and part of that inspection is to make sure the required entries have been made before signing for the approval (Part 43.5).
What is "Return to Service"?
Return to Service is when the aircraft actually leaves the ground for flight. Part 1 defines "Time in Service" as from the time the aircraft leaves the ground to the time the aircraft touches back down for 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. They 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 "Approval for Return to Service" is 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." This is not a description of the major work performed, or a description of the work you get paid for, it just says, "a description of the work performed." There is one acceptable substitution, ". . . or reference to data acceptable to the Administrator." This statement is intended to allow us to refer to a specific manual or instruction that contains the details of the step-by-step procedures used in performing the maintenance rather than writing it all out in detail. 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 "acceptable to the Administrator."
The chain of reference to data acceptable to the Administrator can become hard to follow. For example, let's assume the emergency exit window installed in the previous example had been repaired by a 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.
The most common trap the maintenance people fall into is the get-it-out-the-door trap. As a group, we are very good at getting the maintenance done right; however, it seems we are always finishing the work right when the aircraft is scheduled to leave and the paperwork 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.
• Remember - If you don't write it down, you didn't do the work. This holds true when the FAA or someone else is looking at the record entries you created.
The next article 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.