Are Your Maintenance Records Ready for Y2K ?
When I went to college, too many years ago to even consider saying how long ago that was, there was a poster hanging in the aircraft maintenance laboratory that depicted a small child sitting on a toilet. The caption under that picture was "No Job Is Finished Until The Paperwork Is Done. " A cute picture to get the importance of good maintenance records across to a bunch of budding maintenance technicians. This statement is even more true now than it was then. In recent years the FAA has taken an entirely different view of what good maintenance records are over what was accepted in years past.

In order to know what good maintenance records are, we must revert to what is required by the FAR's. The first thing that we must understand is that it is the technicians responsibility to make maintenance entries in the logbooks only if the owner operator gives the logs to him. The primary responsibility for maintenance entries is on the owner-operator. He or she must give their logs to the attending mechanic and ask for them to be filled out. If they do this then the technician must record the work that was done.

The FAR's, particularity FAR Part 91, require a maintenance record for each aircraft, each engine and each propeller. These do not have to be separate individual records but the records required by FAR Part 91 must be kept for each component mentioned. Part 91 also stipulates what is required to be made part of a maintenance record. There are six items that the owner operator must maintain for each of the components that are required to have maintenance records. These are:

  1. Total time in service since new, that is a running account of the time the unit has spent in the air.
  2. The current status of life limited parts, that is the relative status to the retirement time for that life limited part. If an engine is limited to 2000 hours or 12 years the owner operator should be able to produce a record stating when its life ends.
  3. Total time since last overhaul, that is the total time since overhaul of all items on the aircraft that are required to be overhauled on a specific time basis.
  4. Current inspection status, that is when the last inspection was done and when the next one is due.
  5. Current status of applicable Airworthiness Directives, this is to include the AD number, revision number, the method used to comply with it, the date and total time of when it was complied with, the requirements for recurring action and the time frame for that action.
  6. All FAA Forms 337.
In addition to maintaining these six items the owner operator is required to ensure that all maintenance personal make appropriate entries in the maintenance records for all maintenance and inspections that have been performed and that these entries indicate that the item has been approved for return to service.

Maintenance personnel are only required to make entries including the information in item number one when recording a mandatory inspection; i.e., 100 hour, annual or progressive. They are also required to include all of the information in item number five when signing off the compliance of an AD Note. Other than these requirements the six items are the owner operator's responsibility not the charge of the maintenance staff.

When a maintenance technician records maintenance that has been performed, he or she must do so in enough detail so that someone who is unfamiliar with the work would understand what was done. In the case of a very large job this would result in an extremely long and windy log entry. It is permissible for the technician to make reference to technical data acceptable to the FAA in lieu of making a detailed entry. This acceptable technical data includes but is not limited to manufacturer's manuals, service letters and bulletins, FAA Forms 337. If the data, that is used, is not readily available and in common usage the data must also be made part of the maintenance records. When returning a component to service the technician must sign for the work, record the date, the certificate number and type of certificate being used.

When all of these requirements are met, you will be able to satisfy even the most stringent maintenance or FAA personal, to say nothing of the Y2K police.

Send your questions to Mahlon at mahlon@mattituck.com

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© Mahlon Russell 1999