Aug 26 2019

Maintenance Minute - For The Record Posted 5 years 89 days ago ago by Admin

Several times a year, I’ll field a question about aircraft records. Not the Chuck Yeager type, but those binders, stacks, or sometimes just boxes of documents and paper products that record the maintenance performed on an aircraft. 

The specific topic may vary a bit, but one topic that continually repeats itself concerns the FAA required format for these records. While there is FAA guidance on the content and form for each maintenance entry made into these records, there is no mandated format, i.e. physical form, on which that entry should be written.

The closest we get is a small blip in FAA Advisory Circular 43-9C: “Maintenance records may be kept in any format that provides record continuity, includes required contents, lends itself to the addition of new entries, provides for signature entry, and is intelligible.” 

Unfortunately, it’s not the mechanic who determines the record’s format, but the owner or operator per Part 91.417(a). So, if the owner wants the mechanic to make his maintenance entries in a logbook, on an Avery label, or on a Crown Royal bar napkin, the mechanic has no regulatory recourse other than refusing to perform the work.

It’s a little more civilized in Part 135 or Part 121 operations, as there is an FAA requirement to define and describe the maintenance records system as part of the required general maintenance manuals. In this case, it’s doubtful a bar napkin will be accepted. However, in Part 91 operations I’ve seen a rather wide variance in maintenance record formats.

The one positive side to maintenance records in general is that the mechanic is not responsible for them. The owner/operator is. The only portion the mechanic is responsible for is to ensure his entry conforms to the requirements of Part 43.2, Part 43.9, or Part 43.11.

Lately, there’s been a push by certain aircraft owners towards electronic records. That’s fine, but very few computerized aircraft maintenance records systems on the market, especially at the Part 91 level, provide the ability for a mechanic to meet the requirements of Part 43.9 and Part 43.11. The main issue is allowing for a description of the maintenance performed and the mechanic’s signature.

Computerized records systems that do allow for electronic signatures require FAA involvement and are rather expensive. There are some Part 135/121 operators with large fleets that do use them. However, short of these FAA-approved records systems, any maintenance entries made electronically will require that entry to be printed out in a tangible form and hand-signed by the mechanic.   

So the next time an owner goes off tangent and wants your AD sign-off entered in some obscure format, offer to sign it off on his forearm instead. That should make for an interesting conversation if the owner ever needs to comply with Part 91.419. 

About the author: After 32 years maintaining helicopters in various capacities, Scott concluded a full-time career with a major operator in 2014. When not pursuing future writing projects, he can still be seen around the flight line tinkering on aircraft for beer money. He can be contacted at [email protected].