FAA Aircraft Maintenance Records & Airworthiness Directives
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FAA Aircraft Maintenance Records & Airworthiness Directives
- 1. Federal Aviation AdministrationAircraft Maintenance Records & Airworthiness Directives Mark Laughridge – FAASTeam Program Manager March 9, 2013
- 2. Federal Aviation Administration 2 Aircraft Maintenance Records Introduction This course provides a review of aircraft maintenance documentation requirements, emphasizing the importance of accurate and complete documentation. It identifies common documentation problems that can lead to maintenance errors.
- 3. Federal Aviation Administration 3 Aircraft Maintenance Records Aircraft Maintenance Records The basic requirements for Aircraft Maintenance Records are the same. The method of meeting those requirements may be different depending on the type of operation.
- 4. Federal Aviation Administration 4 Aircraft Maintenance Records Common problems • No documentation. • Inadequate description of work performed. • Using the wrong references. • Poor shift turnovers
- 5. Federal Aviation Administration 5 Aircraft Maintenance Records Regulation Cited
- 6. Federal Aviation Administration 6 Aircraft Maintenance Records Sept. 11, 1999 near Eagle Lake Texas. Continental Express Flight 2574 an EMB 120 In flight the left horizontal stabilizer leading edge bent down and then separated from the aircraft. Attaching hardware had been left out of the upper left horizontal stabilizer leading edge. 14 passengers and crew killed near Eagle Lake Texas.
- 8. Federal Aviation Administration 8 Aircraft Maintenance Records NTSB Finding Departures from approved procedures included failures to give proper shift / turnover reports, failures to use maintenance work cards as approved, failures to complete required maintenance/inspection shift / turnover forms, and a breach in integrity of the quality control system.
- 9. Federal Aviation Administration 9 Aircraft Maintenance Records Shift /Turnover The transfer of critical information between work groups or shifts It needs to be as detailed as necessary, depending on the tasks involved Sharing of information by the people doing the task
- 10. Federal Aviation Administration 10 Aircraft Maintenance Records Why is Shift/Task Turnover Important Data shows that poor shift/task turnover is a contributing factor to accidents/incidents. Challenges related to shift turnover include: 1. A high demand for teamwork and communication skills 2. Lack of structured and standardized policies and procedures 3. Using a location that is not conducive for discussion and planning
- 11. Federal Aviation Administration 11 Aircraft Maintenance Records Why is Shift/Task Turnover Important 4. Finishing workers are tired and want to depart the facility. 5. Lack of adequate shift overlap to provide time to give one- on-one briefings between the teams. 6. Absence of a process to ensure departing personnel have documented all tasks accomplished or started. 7. Minimal training on procedures for shift/task turnover. High-quality shift/task turnover procedures enable improvement in safety and accountability to all involved in the work.
- 12. Federal Aviation Administration 12 Aircraft Maintenance Records Implement a Shift/Task Turnover process • Formalize policy and procedures that make the turnover as important as the work. • Communicate policy and procedures to all personnel. • Deliver initial and recurrent training on how to conduct a good shift/task turnover. • Provide a time and place for formal shift/task turnover. • Consider technology enhancements that improve the transfer of visual information (e.g., photos, graphics).
- 13. Federal Aviation Administration 13 Aircraft Maintenance Records Part 43.3 Persons Authorized to Perform Maintenance The holder of a Mechanic Certificate… The holder of a Repairman Certificate… The holder of a Repair Station Certificate… The holder of a Air Carrier Operating Certificate… The holder of a Pilot Certificate…
- 14. Federal Aviation Administration 14 Aircraft Maintenance Records Part 43.5 Approval for Return to Service After Maintenance, Preventive Maintenance… No person may approve for return to service any aircraft… that has undergone maintenance…unless, (a) The maintenance record entry required by 43.9 or 43.11 has been made…
- 15. Federal Aviation Administration 15 Aircraft Maintenance Records Part 43.7 Persons Authorized to Approve Aircraft, Aircraft engines…for return to service after maintenance… The holder of a mechanic certificate or an inspection authorization… The holder of a repair station certificate… The manufacturer… The holder of a air carrier operation certificate… The holder of a private pilot certificate…
- 16. Federal Aviation Administration 16 Aircraft Maintenance Records Part 43.9 Content, Form, and Disposition of Maintenance Records (a)…each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, engine, propeller, appliance, or component part, shall make an entry in the maintenance record of that equipment (1) A description of work performed. (2) Date of completion of the work performed. (3) The name of the person performing the work (4) The signature, certificate number, and kind of certificate held by the person approving the work.
- 17. Federal Aviation Administration 17 Aircraft Maintenance Records “Note” “The signature constitutes the approval for return to service only for the work performed.”
- 18. Federal Aviation Administration 18 Aircraft Maintenance Records Part 43.11 Content, Form, and Disposition of Records for Inspections (a) The person approving an aircraft for return to service …shall make an entry in the maintenance record of that equipment containing the following information:
- 19. Federal Aviation Administration 19 Aircraft Maintenance Records Part 43.11 Content, Form, and Disposition of Records for Inspections (1) The type of inspection and a brief description. (2) The date of the inspection and aircraft total time in service. (3) The signature, the certificate number, and kind of certificate held by the person approving the aircraft for return to service. (4) Certifying statement
- 20. Federal Aviation Administration 20 Aircraft Maintenance Records 43.13 PERFORMANCE RULES (GENERAL)43.13 PERFORMANCE RULES (GENERAL) (a) Each person performing maintenance, alteration, or(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, orpreventive maintenance on an aircraft, engine, propeller, or applianceappliance shall use the methods, techniques, and practicesshall use the methods, techniques, and practices prescribed in the current manufacturer’s maintenanceprescribed in the current manufacturer’s maintenance manual or Instructions for Continued Airworthiness preparedmanual or Instructions for Continued Airworthiness prepared by its manufacturerby its manufacturer, or other methods, techniques, and, or other methods, techniques, and practices acceptable to the Administrator, except as noted inpractices acceptable to the Administrator, except as noted in 43.16. He43.16. He shall useshall use the tools, equipment, and test apparatusthe tools, equipment, and test apparatus necessary to assure completion of the work in accordancenecessary to assure completion of the work in accordance with accepted industry practices.with accepted industry practices. If special equipment orIf special equipment or test apparatus is recommended by the manufacturertest apparatus is recommended by the manufacturer involved, he must use that equipment or apparatusinvolved, he must use that equipment or apparatus oror itsits equivalent acceptable to the Administrator.equivalent acceptable to the Administrator.
- 21. Federal Aviation Administration 21 Aircraft Maintenance Records I’ve always done it this way! This is an example of what happens when we do not pay attention to detail, and do not follow instructions and checklists! A KC-135 Aircraft was being pressurized at ground level. The outflow valves which are used to regulate the pressure of the aircraft were capped off during a 5 year overhaul and never opened back up. The post-investigation revealed: that a civilian depot technician who, "had always done it that way," was using a homemade gauge, and no procedure. The technician's gauge didn't even have a max "peg" for the needle and so it was no surprise he missed it when the needle went around the gauge the first time. As the technician continued to pressurize the aircraft, and as the needle was on its second trip around the gauge the aircraft went "boom" - the rear hatch was blown over 70 yards away, behind a blast fence! An incident like this is never funny and is further regrettable when we consider that this mistake is one that we (the taxpayers) will end up paying for. Fortunately, no one was reported as being injured. This was a good "Lessons Learned" for making sure we have trained people, who have the right tools, and who are following detailed procedures. And it should serve as a reminder that just because you’ve always done it that way, it does not make it the “right” way!
- 25. Federal Aviation Administration 25 Aircraft Maintenance Records (c) ((c) (CContinuousontinuous AAirworthinessirworthiness MMaintenanceaintenance PProgramsrograms approved under FAR Part 121, 127, 135, and 129 constitute anapproved under FAR Part 121, 127, 135, and 129 constitute an acceptable means of compliance with this section).acceptable means of compliance with this section). (b) Each person maintaining or altering or performing(b) Each person maintaining or altering or performing preventive maintenance,preventive maintenance, shall do that work in such a mannershall do that work in such a manner and use material of such a quality, that the condition of theand use material of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or applianceaircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properlyworked on will be at least equal to its original or properly altered conditionaltered condition (with regard to aerodynamic(with regard to aerodynamic function, structural strength, vibration and deteriorationfunction, structural strength, vibration and deterioration resistance, and other qualities affecting airworthiness).resistance, and other qualities affecting airworthiness). 43.13 PERFORMANCE RULES (GENERAL) (cont.)43.13 PERFORMANCE RULES (GENERAL) (cont.)
- 26. Federal Aviation Administration 26 Aircraft Maintenance Records 91.417 Maintenance Records Records of maintenance…must include-- A description (or reference to data acceptable to the Administrator) of the work performed; and The date of completion of the work performed; and The signature, and certificate number of the person approving the aircraft for return to service.
- 27. Federal Aviation Administration 27 Aircraft Maintenance Records 91.417 Maintenance Records The total time in service of the airframe, each engine, each propeller, and each rotor. The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and appliances are maintained.
- 28. Federal Aviation Administration 28 Aircraft Maintenance Records 91.417 Maintenance Records The current status of applicable airworthiness directives (AD) and safety directives including, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. Copies of the forms prescribed by Sec. 43.9(a) for each major alteration to the airframe, and currently installed engines, rotors, propellers, and appliances.
- 29. Federal Aviation Administration 29 Aircraft Maintenance Records Record retention • The owner or operator shall retain the following records for the periods prescribed: • The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. • The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.
- 30. Federal Aviation Administration 30 Aircraft Maintenance Records INCORPORATION BY REFERENCE • You don’t have to write a book. • The regulations permit reference to technical data in lieu of making a long step by step detailed entry. • Common references include maintenance manuals, service letters, bulletins, work orders, advisory circulars (AC43.13-1B), and others. • Major alterations may reference STC’s. • Reference documents must be retained.
- 31. Federal Aviation Administration 31Aircraft Maintenance Records What Must Be In The Maintenance Records? • Description of the work performed • Date the work was completed • Signature and certificate number of the person approving the work Ι χερτιφψ τηατ τηισ αιρχραφτ ηασ β εεν ινσπεχτεδ ιν αχχορδανχε ωιτη α ν αννυαλ ινσπεχτιον ανδ ωασ δετερ µινεδ το βε ιν αν αιρωορτηψ χονδιτι ον SIGNATURE ΙΑ 4456782435
- 33. Federal Aviation Administration 33 Aircraft Maintenance Records AIRWORTHINESS DIRECTIVES An unsafe condition exist in a product. The condition is likely to exist or develop in other products of the same design.
- 34. Federal Aviation Administration 34 Aircraft Maintenance Records RESPONSIBILITY The Owner/Operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with ADs The Owner/Operator is responsible for ensuring that properly certificated persons perform the work.
- 35. Federal Aviation Administration 35 Aircraft Maintenance Records RESPONSIBILITY Maintenance personnel are responsible when they are performing inspections to determine that all airworthiness requirements are met. Part 43.15
- 36. Federal Aviation Administration 36 Aircraft Maintenance Records RECORDS The owner must keep a record showing the current status of all applicable ADs. This record must include the following: The current status of ADs applicable to the aircraft, including the AD number and revision date, the method of compliance, and the time in service‑ ‑ , or the cycles, and the date and/or time when the next action is required for a recurring AD.
- 37. Federal Aviation Administration 37 Aircraft Maintenance Records Steps to performing a successful AD research • Un-cowl and completely open the aircraft for the inspection. • Clean the aircraft. • Starting with the aircraft serial number, write down each and every part number and serial number of all installed equipment, to include the engine and its components, and the prop. • There are a number of good forms available for this on the internet.
- 38. Federal Aviation Administration 38 Aircraft Maintenance Records • Climbing under the panel with a flashlight and mirror to collect the model and serial numbers from all the instruments is difficult. BUT….. • Murphy’s Law says that the instrument you miss will be the one with the AD note that is overdue. Steps to performing a successful AD research
- 39. Federal Aviation Administration 39 Aircraft Maintenance Records AD sign offs in the records. • Some common yet incorrect entries found in some records are: – “PCW” with no other information or – “N/A” with no other information or – an entry without enough information or – “All ADs complied with”
- 40. Federal Aviation Administration 40 Aircraft Maintenance Records •No reference to next due date and time. “All other AD notes checked for compliance” is an incorrect signoff. Problem maintenance record entry?
- 42. Federal Aviation Administration 42 Aircraft Maintenance Records Sample Logbook EntryN12345 Tach/Hobbs: ____________ ACTT: ____________ Enter the type of inspection(s) performed: Enter accomplishment of all A.D.’s including the number, revision date, method of compliance, and if recurring, the next time/date it is due. Enter replacement or inspection of any component part with Airworthiness Limitations (include part, serial number, and total time in service for that component). Enter removal and installation of any serialized components (include part, serial number, and total time in service for that component). Enter description of any other general maintenance performed. I certify that this aircraft was inspected in accordance with a (insert type) inspection and was determined to be in an airworthy condition. All work was accomplished in accordance with current Federal Aviation Regulations and manufacturer’s maintenance instructions. Signature_______________ Certificate #_______________ Date__________
- 43. Federal Aviation Administration 43 Aircraft Maintenance Records DESCRIPTION OF WORK PERFORMED The description should be in sufficient detail to permit a person unfamiliar with the work, to understand what was done, and the methods and procedures used. “Show the same pride in your record entries as you do in your work”.
- 44. Federal Aviation Administration 44 Aircraft Maintenance Records Summary It may be a simple airframe, engine, propeller log book, or an air carrier’s maintenance record system. A description of the work performed, date the work was performed and the signature with certificate number and type are always required.
- 45. Federal Aviation Administration 45 Aircraft Maintenance Records Common problems • No documentation. • Inadequate description of work performed. • Using the wrong reference. • Poor shift turnovers
- 46. Federal Aviation Administration 46 Aircraft Maintenance Records Easy solutions • Follow the regulations. • Follow company procedures (GMM). • Use the Maintenance Personal Minimums Checklist !
- 47. Federal Aviation Administration 47 Aircraft Maintenance Records Before the task
- 48. Federal Aviation Administration 48 Aircraft Maintenance Records AFTER
- 50. Federal Aviation Administration 50Aircraft Maintenance Records The Southern Region FAASTeam is dedicated to quality customer service and we would appreciate your feedback on the critique sheet provided. Thank You
Editor's Notes
- Title Slide
- INTRODUCTION: This course provides a review of Aircraft Maintenance Records requirements. It emphasizes the importunateness of proper documentation. It identifies common documentation problems that can lead to maintenance errors. Poor maintenance documentation can be a precursor to aircraft incidents or accidents. It can also lead to FAA enforcement actions.
- To summarize, the basic requirements for Aircraft Maintenance Recordss are the same. Whether it is a Cessna 150 or a Airbus 380 The method of meeting those requirements may be different depending on the type of operation.
- Let’s review. No documentation. The situation may be obvious that maintenance has been performed. You can not determine what maintenance action may have done, or by whom, so the work has to be redone. Inadequate description. You can not tell what was done or if it was done correctly. Using the wrong reference. Such as using the system description section of the M/M for a component replacement or citing the wrong ATA chapter or maybe using an out of date manual. Shift turnovers should always be done by the people doing the work. Written description of what was accomplished, clear stop and starting points.
- Mechanic violations fall into very consistent categories. Failure to perform maintenance and inspections in accordance with approved methods (43.13, 43.15) and failure to document such actions prior to return to service (43.5, 43.9) accounted for 90% of all maintenance violations
- This was a hard lesson in why proper maintenance documentation particularly shift turnover procedures are so important. On Sept. 11, 1999 On that day Continental Express Flight 2574 an EMB 120 aircraft, went down. In flight the left horizontal stabilizer leading edge bent down and then separated from the aircraft. The aircraft become uncontrollable. 14 passengers and the flight crew were killed near Eagle Lake Texas.
- This is how the horizontal stabilizer was found. Notice anything missing? The entire leading edge is missing from the left side of the aircraft’s horizontal stabilizer.
- This statement was taken from the NTSB Factual Report. “ Departures from approved procedures included failures to solicit and give proper shift / turnover reports, failures to use maintenance work cards as approved, failures to complete required maintenance/inspection shift / turnover forms, and a breach in integrity of the quality control system.” Poor shift turnover policies and procedures were a factor in this accident.
- Another vital form of maintenance documentation is a shift/ turnover records. Shift turn of is the time to transfer of critical information between work groups or shifts. It needs to be as detailed as necessary, depending on the tasks involved. Sharing of information by the people doing the task. Do you think that Aircraft Maintenance Records has never caused an accident?
- Why is Shift/Task Turnover Important? Data show that poor shift/task turnover is a common contributing factor to events. Challenges related to shift turnover include: 1. Shift Turn over requires a high level of teamwork and good communication skills. 2. The lack of structured and standardized policies and procedures. 3. Using a location that is not conducive for discussion and planning. Such as a high noise area
- 4. Finishing workers are tired and want to depart facility. 5. Lack of adequate shift overlap to provide time to give one-on-one briefings between the team leaving and the team coming on. 6. Absence of a process to ensure departing personnel have documented all tasks accomplished or started. 7. Minimal training on procedures for shift/task turnover High-quality shift/task turnover procedures enable improvement in practice and improve safety and accountability to all involved in the work. CHECK wording in last paragraph
- How do you implement a Shift/Turnover process? Formalize policy and procedures that make the turnover as important as the work. Communicate policy and procedures to all personnel. Consider technology enhancements that improve the transfer of visual information (e.g., photos, graphics, movies).
- Part 91 restates the same requirements we saw in Part 43. To put is in the simplest of term. Description, Date, Signature & Certificate information. This is not all that is required by Part 91.417 as far as aircraft records. Since Part 91 is an operating rule it applies to the Owner/Operator rather than maintenance personnel. With that being said all AMTs need to be aware of the requirements.
- Sec 91.417 also has other requirements for aircraft records such as the total time in service, current status of life-limited parts and time since last overhaul of item required to be overhauled.
- Sec 91.417 also includes t he requirement to document the inspection status of the aircraft, including the time since the last inspection. The current status of applicable airworthiness directives (AD) or service directive including, the method of compliance, the AD directive number and revision date. If the AD involves recurring action, the time and date when the next action is required. Safety Directives? What does that mean? This is new! As of April 2, 2010 Sec 91.417 was amended to include safety directives issued on Special Light Sport Aircraft by the manufactures of the aircraft. The aircraft record must also include copies of the form 337 Sec. 43.9(a) for each major alteration. If a fuel tank is installed within the passenger compartment or a baggage compartment, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner or operator.
- The records specified in paragraph (a)(1) must be kept until the work is superseded or for one year. For section (a)(2) it’s for the life of the aircraft. The owner or operator shall make all maintenance records required to be kept by this section available for inspection by the Administrator or any authorized representative of the National Transportation Safety Board (NTSB).or any law enforcement officer.
- Tell the story so that some one in the future reading your entry know what you did. Then read the slides bullets. A maintenance entry that describes what was done and gives a specific maintenance manual reference leaves little doubt as to what was done, and how it was done.
- § 91.417 is our source for guidance on the information we should find in the aircraft maintenance records. When we review the records to verify airworthiness, we’re basically looking for What, When, and Who. If the entry we are looking at appears to be Greek, it might be a good time to seek clarification. As the pilot in command, if I’m expected to make the final decision regarding the airworthiness of the aircraft, I need to be able to understand what I’m reading. Further, the last time I checked, A&P mechanics are required to be able to read, write and understand the English language. §43.9 also contains wording that specifically requires the name of any person working on the aircraft and the certificate type of the approving person. If I’m working with an A&P who is allowing me to do some of the work on my aircraft, my name needs to be entered into the maintenance record, along with the name and certificate number of the A&P who is approving my work.
- This is a maintenance record entry that the next mechanic does not want to see. Whoever made this entry just made the next persons job that much harder. The entry does not conform to regulation in that it does not provide a complete enough description of the work performed.
- An AD is issued when it is found that an unsafe condition exist in a product The condition is likely to exist or develop in other products of the same design
- The Owner/Operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with ADs The Owner/Operator is responsible for ensuring that properly certificated person perform the work.
- Maintenance personnel have the responsibility of compliance at the time they are performing inspections to determine all airworthiness requirements are met.
- The owner must keep a record showing the current status of applicable ADs. This record must include the following: The current status of ADs applicable to the aircraft, including the AD number and revision date, The method of compliance, and The time‑in‑service, or the cycles, and/or the date when the next action is required for a recurring AD. An acceptable method of compliance should include a reference to either a specific portion of the AD or a manufacturer’s service bulletin, if the bulletin is referenced in the AD. The document that contains the current status of ADs/method of compliance may be the same as the record of AD accomplishment.
- The following slides provide a discussion on the methods to accomplish an AD search. Completely opening the aircraft and cleaning it is essential. You can’t see the model and serial numbers of the components if they are covered up with dirt. The identification of all the components and a very good understanding of what is installed on the aircraft is important. As you are looking through the AD note index, you may spot a reference to an AD note for a component that is installed on the aircraft. An example of this is the ELT, several ELT types have AD notes issued for them.
- There are AD notes against a whole lot of different components that are installed under the instrument panel on GA aircraft. Some turn coordinators have AD notes, there are switches and circuit breakers that have AD notes.
- Maintenance records are the responsibility of the person performing the work. If it’s not done correctly, it will make the job just that much harder for the person who follows you working on the aircraft again. PCW is not a good acronym to use and neither is NA with not supporting info.
- This is a maintenance record entry that the next mechanic does not want to see. Whoever made this entry just made the next persons job that much harder. The entry does not conform to regulation in that it does not provide a complete enough description of the work performed.
- Here is a typical AD compliance record that could be used for a general aviation aircraft, or a large transport aircraft. The requirements are the same.
- Note: Each line will come in one at time and fade. Talk about each line and type of entry as they appear.
- The description should be in sufficient detail to permit a person unfamiliar with the work to understand what was done, and the methods and procedures used. When the aircraft leaves the hangar, your entry must speak for you. When the flight crew reviews the log book your entry is usually all they have to go by. Give them confidence that the maintenance task you performed was done correctly.
- It may be a simple airframe, engine, propeller log book, or an air carrier’s maintenance record system. A description of the work performed, date the work was performed and the signature with certificate number and type are always required.
- Let’s review. No documentation. The situation may be obvious that maintenance has been performed. You can not determine what maintenance action may have done, or by whom, so the work has to be redone. Inadequate description. You can not tell what was done or if it was done correctly. Using the wrong reference. Such as using the system description section of the M/M for a component replacement or citing the wrong ATA chapter or maybe using an out of date manual. Shift turnovers should always be done by the people doing the work. Written description of what was accomplished, clear stop and starting points.
- Follow the rules. Follow company procedures General Maintenance Manual (GMM). Use the Maintenance Personal Minimums Checklist !
- Review the items on the Checklist. Before the Task KEEP THIS IN YOUR TOOLBOX!!
- Review the items on the Checklist. After the Task
- Contact your FAASTeam Program Manager or FAASTeam Representative for more information. Remember to Be Smart and Follow procedures.
- The Southern Region FAA Safety Team is dedicated to quality customer service and we like your feedback. Please provide us feedback on the critique sheet provided. Thank you.