CHAPTER 6. MAINTENANCE RECORDKEEPING SYSTEM
600. Why do you have to make and keep maintenance records?
Air carrier maintenance records are made and retained to show that the U.S. Standard Airworthiness Certificate is effective and that the aircraft is airworthy. A U.S. Standard Airworthiness Certificate is effective only as long as the maintenance and alterations are performed according to the requirements of the FAA’s regulations. Incomplete or inaccurate required aircraft maintenance records can have the effect of rendering a Standard Airworthiness Certificate ineffective. Maintenance actions, in almost all cases, become intangible or abstract after the fact. Therefore, in order for an aircraft operator to make a maintenance action tangible, a record of that maintenance action must be made. Additionally, making a record of certain summary information supports the current airworthiness status of an aircraft.
601. Are there penalties for improper air carrier maintenance recordkeeping?
Maintenance records are important because the FAA uses its continuing review of aircraft maintenance records as a direct means of ensuring the airworthiness and safety of air carrier aircraft. Because the review of maintenance records is the only direct means of determining the accomplishment of required maintenance, federal law treats the act of intentionally failing to make and keep, as well as the act of intentionally falsifying, mutilating, or altering air carrier aircraft records as a criminal act, subject to the imposition of substantial fines and/or imprisonment.
602. How must you make and keep required maintenance records?
The FAA’s regulations require you to have and use a recordkeeping system for the preparation, storage, and retention of required aircraft maintenance records. You must document your system in your air carrier manual. The primary objective of these systems is the generation, storage, retention, and retrieval of accurate and complete air carrier aircraft maintenance records. As stated earlier, these records are primarily made to show that the U.S. Standard Airworthiness Certificate of your air carrier aircraft is effective, and therefore the aircraft is airworthy and capable of safe flight.
In addition to the summary records and airworthiness release records, your recordkeeping system should have detailed documentation and source requirements and procedures for administrative handling of aircraft components and parts. You must clearly identify these procedures in your recordkeeping system and manual. These source and documentation requirements for parts and components may include, but are not limited to, documentation of Airworthiness Directives (AD) compliance, life-limited parts current status information, description of maintenance performed, and appropriate certification of new and repaired parts.
603. What are the required air carrier maintenance records?
Over the years, FAA’s air carrier aircraft maintenance record making and retention requirements have evolved from the minimal records of repairs and alterations required in the pre WW2 era, to Par 600 Page 17
the current requirements for two types of records: a list of summary information, and air carrier airworthiness release records.
604. When must these required records be made available to the FAA?
Under FAA’s regulations, you must make these records available to the FAA in a reasonable amount of time. The FAA can make a request to see your records at any time or place.
605. Who must make these required records available to the FAA?
You must designate those persons in your organization who are responsible for providing each required record or report to the FAA on request. You must make a list of these persons and their location. The list must include the records, documents, and/or reports that each person is responsible for. You must keep this list current, and make it available to the FAA at your principal base of operations.
1. Summary information.
Air carriers are required to make and keep a list of certain summary status records. You are required to transfer these records with the aircraft when it is sold. Summary current status recordkeeping requirements are listed and explained as follows:
a. The “total time-in-service of the airframe, each installed engine, and each installed propeller.” Total time-in-service is a record that contains the time-in-service accrued since new or rebuild, expressed in hours and landings or cycles.
b. The “current status of each life-limited part” of each airframe, engine, propeller, and appliance means a record that contains, at least, the following information:
NOTE: For part 135 air carriers, total time-in-service and current status of life-limited parts includes rotors.
(1) Time-in-service since new expressed in the appropriate parameter (hours, cycles, calendar time, etc.).
(2) The time-in-service remaining to the specified life limit expressed in the appropriate parameter (hours, cycles, calendar time, etc.).
(3) The specified life limit expressed in the appropriate parameter (hours, cycles, calendar time, etc.).
(4) A record of any action that alters the part’s life limit or changes the parameter of the life limit.
c. The listing of the “time since last overhaul” means a record that contains, at least, the following information:
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(1) A listing of the item that requires overhaul, and its associated scheduled overhaul interval.
(2) The time-in-service since the last overhaul.
(3) The time-in-service remaining to the next scheduled overhaul.
(4) The time-in-service when the next scheduled overhaul is due.
NOTE: The listing of “time since overhaul” refers to summary current status information and must not be confused with an overhaul record, which is a description of the work performed and the identification of the person who performed and/or issued the approval for return to service.
d. The “current inspection status of the aircraft” means a record that contains, at least, the following information:
(1) A listing identifying each of the scheduled inspection packages and each task and their associated intervals that are required by the maintenance program under which the aircraft is maintained.
(2) The time-in-service accrued since the last accomplishment of each of the scheduled inspection packages and tasks required by the maintenance program under which the aircraft is maintained.
(3) The time-in-service remaining to the next accomplishment of each of the scheduled inspection packages and tasks required by the maintenance program under which the aircraft is maintained.
(4) The time-in-service when the next accomplishment of each of the scheduled inspection packages and tasks required by the maintenance program under which the aircraft is maintained is due.
e. The “current status of an airworthiness directive” means a record that contains, at least, the following information:
(1) Identification of the particular airframe, engine, propeller, appliance, or component to which the AD is applicable.
(2) The AD number (and/or regulatory amendment number).
(3) The date and the time-in-service expressed in the appropriate measuring parameter (hours, cycles, calendar time, etc.) when the required action was accomplished.
(4) If the requirement is recurring, the time-in-service when the next action is due expressed in the appropriate measuring parameter (hours, cycles, calendar time, etc.).
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(5) The method of compliance means: with regard to an AD, a concise description of the action taken to comply with the requirements of the AD. If the AD or its referenced manufacturer’s service bulletin permits the use of more than one method of compliance, the record must include a reference to the specific method of compliance used. If the operator uses an alternate method of compliance (AMOC) to comply with an AD, the method of compliance means a description of this AMOC and a copy of the FAA approval.
NOTE: The listing of “current status of an airworthiness directive” or “method of compliance” refers to summary current status information and must not be confused with an AD record of accomplishment, which is a description of the work performed and the identification of the person who performed and/or issued the approval for return to service.
f. A listing of “the current major alterations of each airframe, engine, propeller, and appliance” means a record that contains, at least, the following information:
(1) A listing identifying each major alteration as well as the associated item to which the major alteration has been installed.
(2) A description, or reference to, the FAA-approved technical data used to make the major alteration.
NOTE: For part 135 air carriers, this listing includes a list of all current major repairs, as well as a requirement for a listing of major repairs and alterations to each rotor.
NOTE: The listing of “all of the current major alterations” refers to summary current status information and must not be confused with a major alteration report, which is a detailed description of the work performed, a description of the FAA-approved technical data used to make the alteration, and the identification of the person who performed and/or issued the approval for return to service. This listing also must not be confused with the requirement to submit a copy of each report of a major alteration to the FAA.
g. “All the records necessary to show that all requirements for the issuance of an airworthiness release have been met.” While the regulatory requirement for these records does not provide a detailed list of these records, this requirement is generally accepted to mean:
(1) Detailed records of all scheduled maintenance that has not been superseded by work of equivalent scope and detail.
(2) Detailed records of the accomplishment of the last overhaul for those items required to be overhauled.
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NOTE: An overhaul record is not required to contain a record of AD accomplishment. The regulations require records of AD current status and accomplishment to be made and preserved as a separate and distinct record.
(3) Detailed records of all unscheduled maintenance that has not been superseded by work of equivalent scope and detail.
(4) Adequate copies of the airworthiness release. “Adequate copies” is generally accepted to mean copies covering the last 60 days of operation.
NOTE: All of these items (a-g) are required, by regulation, to be transferred with the aircraft when it is sold.
2. Air carrier airworthiness release records.
The FAA’s regulations require that each time you perform maintenance or alterations on your aircraft, you must make, or cause to be made, an airworthiness release or log entry before you can operate the aircraft. You are also required to give a copy of the airworthiness release to the pilot-in-command, and to keep a record of the airworthiness release for at least two months. You must keep all of the records necessary to show that all of the requirements for the issuance of an airworthiness release have been met. These records must be retained for at least one year after the work is performed, or until the work is superseded by work of equivalent scope and detail.
However, you must keep detailed records of the accomplishments of the last required overhaul until the work is superseded by work of equivalent scope and detail.
Generally speaking, the airworthiness release is executed each time the aircraft completes a scheduled check. A log entry is executed each time the aircraft is approved for return to service after unscheduled maintenance. You may not operate the aircraft unless you issue an airworthiness release or approve it for return to service.
606. Are there any other required records or reports that you must make and keep?
Besides the records listed above, FAA’s regulations require you to make other reports and records, listed below. You can use these records and reports to review your maintenance operations to determine the adequacy of the maintenance portion of your air carrier manual and the effectiveness of your maintenance program, as well as your CASS. FAA also uses these reports in its continuous oversight of your maintenance program.
1. You must keep an aircraft maintenance log.
Whenever you take action in response to a reported or observed failure or malfunction, you must make a record of that action in the maintenance log of the aircraft. You must ensure that each pilot-in-command enters all mechanical irregularities occurring during flight time, and that these are entered in the maintenance log at the end of that particular flight time.
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2. You must make mechanical reliability reports.
You should use these reports to help you identify deficiencies within your maintenance program.
The FAA uses these reports as a means of gathering information for its Service Difficulty Reporting System.
3. You must make mechanical interruption reports.
Essentially, these reports document the inability of the aircraft to arrive at its scheduled destination due to mechanical difficulties. You should use these reports to help you determine the degree of effectiveness of your maintenance program.
4. If you are a part 121 air carrier, you are required to make a report of each major alteration and each major repair made on your aircraft.
You are required to make and submit a major alteration report to the FAA. You are also required to make a report of each major repair, but you are not required to submit it. You must, however, make it available for inspection by the FAA. In addition, because you are an air carrier, you do not have to use FAA Form 337 to report a major alteration or repair that you accomplished, although you can use it.
5. If you are a part 135 air carrier, you are required to make a report of each major alteration and each major repair made on your aircraft.
You are not required to submit either report, but you must make them available to the FAA when they ask.
NOTE: These alteration and repair reports should not be confused with the current status listing of major alterations required under part 121 as well as the current status listing of major repairs and alterations required under part 135.
607. Are you required to keep historical or source records to support your required maintenance records?
There is no regulatory or statutory requirement for you to prepare, store, or retain historical or source records to support your required aircraft maintenance records or current status records.
Indeed, if you have a good system to prepare, store, and retain your required maintenance records and you monitor that system under your CASS, you should not need historical or source records for support. Unless there is evidence to the contrary, an aircraft maintenance record produced by your maintenance recordkeeping system should be acceptable by itself, without historical or source records. The FAA will not require you to produce or maintain any records not required by statute or regulation. However, you may wish to archive certain source
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documentation records that you used to introduce parts or components into your maintenance system. These records may include documents such as the manufacturer’s invoice for new parts, export certificates of airworthiness, documentation of a major repair or alteration, or other similar information that may be useful in the future.
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CHAPTER 7. ACCOMPLISHMENT AND APPROVAL OF
MAINTENANCE AND ALTERATIONS
You must provide instructions in your manual and program for maintenance and alterations for three major areas: scheduled maintenance, unscheduled maintenance, and specific maintenance requirements for major components of the aircraft.
700. What is scheduled maintenance?
Scheduled maintenance consists of all the individual maintenance tasks performed according to the maintenance time limitations (maintenance schedule). Your scheduled maintenance activities should include procedural instructions for the maintenance tasks and requirements to record the results of the inspections, checks, tests, and other maintenance.
701. What is unscheduled maintenance?
Unscheduled maintenance includes procedures, instructions, and standards for maintenance that occurs on an unscheduled or unforeseen basis. A need for unscheduled maintenance may result from scheduled maintenance tasks, pilot reports, or unforeseen events such as hard or overweight landings, tail strikes, lightning strikes, or engine overtemperature. You should include instructions and standards for the accomplishment of unscheduled maintenance in your technical manuals. You should include detailed procedures for recording all types of unscheduled maintenance in your manual.
702. What should your engine maintenance program contain?
Your engine maintenance program should cover both installed engines and off-wing maintenance for each engine model you operate. If your aircraft has auxiliary power units (APU), you may want to include APU maintenance as part of your engine maintenance program.
Normally, the installed engine or APU requirements will be contained in the maintenance time limitations. In addition to procedural information, the off-wing program described in your manual should provide shop scheduling information or intervals for cleaning, adjusting, inspecting, testing, and lubricating each part of the engine or APU requiring that maintenance.
Include in your maintenance manual the degree of inspection, the applicable wear tolerances, and the work required when the engine or APU is in the shop. Your engine maintenance or APU program should contain at least the following segments:
a. Procedures for installed and off-wing scheduled and unscheduled engine or APU maintenance tasks.
b. The engine or APU overhaul standard, if applicable.
c. The engine or APU build standard.
d. Procedures for managing the maintenance of short-term and long-term leased aircraft engines or APUs.
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e. Procedures for management and maintenance of engines or APUs while they are in a shop maintenance status, whether the engines are leased or not.
f. Procedures for integrating a short-term or long-term leased engine or APU into your maintenance program.
g. Procedures for engine or APU condition and trend monitoring, if used.
703. What should your propeller maintenance program contain?
Your propeller maintenance program should cover each model of both installed propellers and off-wing propellers that you operate. Normally, the installed propeller system requirements will be contained in the maintenance time limitations. In addition to procedural information, the offwing program described in your manual should provide shop scheduling information or intervals for cleaning, inspecting, adjusting, testing, and lubricating each part of the propeller system requiring that maintenance. Include in your maintenance manual the degree of inspection, the applicable wear tolerances, and the work required at these periods. Some modern propellers are constructed of composite materials and therefore may require unique tools, repair procedures, and training for maintenance personnel. Your propeller maintenance program should contain at least the following segments:
a. Procedures for installed and off-wing scheduled and unscheduled propeller system maintenance tasks.
b. The propeller system overhaul standard, if applicable.
c. The propeller system build standard.
d. Procedures for managing the maintenance of short-term and long-term leased propellers.
e. Procedures for management and maintenance of propellers while they are in a shop maintenance status, whether they are leased or not.
f. Procedures for integrating a leased propeller into your maintenance program.
704. What should your parts and appliance maintenance program contain?
For the most part, this component of your maintenance program covers shop operations, which may include both scheduled and unscheduled tasks. You may conduct these shop operations at some location other than where you perform maintenance on your aircraft. Your parts and appliance maintenance program should cover both installed parts and appliances and off-wing maintenance for each part and appliance model you operate. Normally, the installed part and appliance requirements will be contained in the maintenance time limitations. In addition to procedural information, the off-wing program described in your manual should provide shop scheduling information or intervals for cleaning, adjusting, inspecting, testing, and lubricating each component of the part and appliance requiring that maintenance.
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Include in your maintenance manual the degree of inspection, the applicable wear tolerances, and the work required when the part or appliance is in the shop. Your parts and appliance maintenance program should contain at least the following segments:
a. Procedures for installed and off-wing scheduled and unscheduled parts and appliance maintenance tasks.
b. The parts and appliance overhaul standard, if applicable.
c. The parts and appliance build standard.
d. Procedures for managing the maintenance of short-term and long-term leased parts and appliance engines.
e. Procedures for management and maintenance of parts and appliances while they are in a shop maintenance status, whether the parts or appliances are leased or not.
f. Procedures for integrating short-term or long-term leased parts and appliances into your maintenance program.
g. Procedures for parts and appliance condition and trend monitoring, if used.
705. What is the Aging Airplane Program?
The FAA developed the aging aircraft program to address the continued airworthiness of large transport, commuter, and other aircraft that have reached or exceeded their design service life objective. Your Aging Airplane Program normally should cover:
a. Structural modification and inspection;
b. Corrosion prevention and control;
c. Supplemental structural inspection program review and update; and
d. Structural repair assessment requirements.
NOTE: Many FAA ADs associated with the Aging Airplane Program require structural modification, corrosion prevention and control, and supplemental inspection programs. You may integrate these requirements into your overall maintenance program; you do not need to treat it as a separate program, unless the AD requires separation.
706. What are Required Inspection Items?
Under FAA’s regulations, you must designate certain tasks as “required inspection items” (RII).
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with improper parts or materials, could result in a failure, malfunction, or defect which would endanger the continued safe flight and landing of the aircraft. In the case of maintenance tasks performed by other persons, you may delegate the RII function to the other person’s inspection organization provided you document the arrangement and control it through your maintenance manual. Some examples of other terminology used to describe RII are back-check, buy-back, and duplicate inspection.
1. Your maintenance program manual must specifically identify all RII tasks and procedures.
It should also include procedures to identify and authorize RII personnel, both within your organization and in other organizations that perform maintenance for you. You must formally notify persons authorized to accomplish RII items of the authorization and its scope. You should also identify RII on work forms, job cards, engineering orders, and so on, or by any other method consistent with your maintenance program. A primary concept of the RII function is that the person performing the item of work may not perform the required inspection on that item of work. Additionally, you must design your maintenance organization to separate the accomplishment of your required inspection function from the accomplishment of your maintenance, preventive maintenance, and alteration function. You must also have procedures in your manual to ensure that only a supervisor of an inspection unit or the person that has overall responsibility for both the RII function and the other maintenance, preventive maintenance, and alteration functions may countermand the decision of any RII inspector regarding an RII. These requirements apply equally to your organization or to an organization performing your maintenance for you.
2. RIIs differ from other inspection tasks in their critical effect on flight safety.
For example, work on a landing gear position indicating system might be a normal inspection, whereas an elevator rigging check conducted to check adjustment of elevator travel would be designated RII because improper adjustment might result in reduced controllability of the aircraft. You must consider all RIIs with the same emphasis regardless of whether an individual RII is related to a scheduled or an unscheduled task. The fact that an RII requirement arises at an awkward time or inconvenient location cannot have a bearing on the requirement to accomplish these types of inspections properly.
707. What are some examples of RIIs?
In determining the tasks to designate as RIIs, you should consider the following examples. This list does not cover all RIIs.
a. Installation, rigging, and adjustments of flight controls and surfaces.
b. Installation and repair of major airframe or engine structural components.
c. Installation of an aircraft engine, propeller, propeller blade, or rotor.
d. Installation, repair, and calibration of certain avionics and navigational equipment.
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