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808. REQUIRED RECORDS. You are required to make and keep certain summary status records. Summary current status recordkeeping requirements are listed in §§ 121.380 and
135.427 and explained as follows:
a. Total Time in Service. The total time in service of the airframe, each installed engine, and each installed propeller is a record that contains the time in service accrued since new or rebuilt, expressed in hours, landings, or cycles.
NOTE: It is important for you to know that rebuilt does not have the same meaning as overhauled.
b. Current Status of Each Life-Limited Part. 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:
(1) Time in service since new, expressed in the appropriate parameter (hours, cycles, calendar time);
(2) The time in service remaining to the specified life limit expressed in the appropriate parameter (hours, cycles, calendar time);
(3) The specified life limit expressed in the appropriate parameter (hours, cycles, calendar time); and
(4) A record of any action that alters the part’s life limit or changes the parameter of the life limit.
NOTE: If you conduct operations under part 135, total time in service and the current status of life-limited parts also includes rotors.
c. Time Since Last Overhaul. The listing of the time since last overhaul means a record that contains at least the following information:
(1) An identification of the item that requires overhaul and its associated scheduled overhaul interval,
(2) The time in service since the last overhaul was accomplished,
(3) The time in service remaining until the next scheduled overhaul, and
(4) The time in service when the next scheduled overhaul is due.
NOTE: The listing of time since last overhaul refers to summary current status information. You must not confuse it 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.
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d. Current Inspection Status of the Aircraft. 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 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 until the next accomplishment of each of the scheduled inspection packages and tasks required by the maintenance program under which the aircraft is maintained; and
(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. Current Status of Applicable Airworthiness Directives (AD). The current status of applicable ADs 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 when the required action was accomplished and the time in service expressed in the appropriate parameter (hours, cycles, calendar time).
(4) If the requirement is recurring, the date when the next action is due, and the time in service expressed in the appropriate parameter (hours, cycles, calendar time).
(5) With regard to an AD, the method of compliance means 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 AD or method of compliance must not be confused with an AD record of accomplishment, which is a description of the work and who performed it and/or issued the approval for return to service.
f. The current major alterations of each airframe, engine, propeller, and appliance. A listing means a record that contains at least the following information:
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(1) A listing identifying each major alteration, as well as the associated item to which the major alteration has been installed, and
(2) A description of, or reference to, the FAA-approved technical data used to make the major alteration.
NOTE: If you conduct operations under part 135, you must include in this listing, all current major repairs, as well as major alterations, and you must include major repairs and major alterations to each rotor.
NOTE: The listing of the current major alterations refers to summary current status information. You must not confuse this with a major alteration report, which is a description of the work performed, a description of the FAA-approved technical data used to make the major alteration, and the identification of the individual who performed and/or issued the approval for return to service. You must not confuse this listing 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 Form have been met. These records support the use of an Airworthiness Release Form, which is not part of the aircraft maintenance logbook. 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 last overhaul for items that required an overhaul, NOTE: An overhaul record is not required to contain a record of AD accomplishment. The regulations require separate records of AD current status. The regulations also require that the record of AD accomplishment be kept, but for only one year.
(3) Detailed records of all unscheduled maintenance that has not been superseded by work of equivalent scope and detail, and
(4) Copies of the Airworthiness Release Form covering the last 60 days of operation.
809. OTHER REQUIRED RECORDS AND REPORTS. The FAA regulations require you to make other reports and records as discussed in this paragraph. 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 elements of your maintenance program. These records are one of the sources of information for your CASS. The FAA also uses these reports in its continuous oversight of your maintenance program activities.
a. Maintenance Log. Sections 121.701 and 135.65 require any person who takes action in response to a reported or observed failure or malfunction to make a record of that action in the
Page 30 Par 809 maintenance log of the aircraft. These air carrier maintenance log entries correspond to the maintenance recording requirements of § 43.9(b). You also must ensure that each pilot in command (PIC) ensures that all mechanical irregularities occurring during flight time are entered in the maintenance log at the end of that particular flight time, consistent with §§ 121.563 and 135.65.
b. Airworthiness Release Form or Log Entry.
(1) Your Airworthiness Release Form or Log Entry required by § 121.709 or § 135.443 corresponds to the approval for return to service requirements of §§ 43.5, 43.7(e), 121.379(b), and 135.437(b). Furthermore, parts 121 and 135 require you to prepare either an Airworthiness Release Form or Log Entry before you can operate your air carrier aircraft after any maintenance, preventive maintenance, or alterations are performed, whether the aircraft is operated in air transportation or not.
(2) Your approval for return to service certification and documentation required by § 121.709 or § 135.443 is a singular requirement, but you may execute it in one of two ways:
(a) You may complete an Airworthiness Release Form and give it to the PIC. If you use an Airworthiness Release Form, it must be kept separate and distinct from the aircraft log and is not included in the maintenance records. The separate and distinct requirement corresponds to the requirements in §§ 121.380(a)(1) and 121.709(d). In modern day environments, you are most likely to use the Log Entry method to comply with § 121.709 or § 135.443. Other than form or format, there is no legal or technical difference between an Airworthiness Release Form and a Log Entry.
(b) An Aircraft Log Entry. If you make a Log Entry, you do not have to issue an Airworthiness Release Form. To avoid confusion and to be consistent with the regulations, you should not identify this entry in the aircraft log as an airworthiness release. Few air carriers use a separate Airworthiness Release Form.
(3) Consistent with §§ 121.709(d) and 135.443(d), you may include a statement in your manual that the signature in the aircraft log of an authorized, appropriately certificated individual constitutes an approval for return to service under your air carrier maintenance program. Such an authorized signature constitutes the four air carrier approval for return to service certifications without restating each one of the certifications. You must prepare your Airworthiness Release Form or Log Entry in accordance with procedures in your manual and must include the following four certifications consistent with statutory considerations for operations with the highest degree of safety in the public interest.
(a) The work was performed in accordance with the requirements of your manual;
(b) All items required to be inspected were inspected by an authorized person who determined the work was satisfactorily completed;
(c) No known condition exists that would make the aircraft non-airworthy; and
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(d) So far as the work performed is concerned, the aircraft is in condition for safe operation.
(4) The Airworthiness Release Form or Log Entry must be signed by an appropriately certificated individual who is authorized by you to make the Airworthiness Release Form or Log Entry on your behalf.
NOTE: The Airworthiness Release Form or Log Entry must be accomplished by an authorized mechanic or repairman on your behalf under your part 121 or part 135 certificate authorizations. This is consistent with the requirements and authorizations of § 43.7(e), § 121.379(b), or § 135.437(b), and § 121.709(b)(3) or § 135.443(b)(3).
NOTE: Consistent with regulations no individual may issue an Airworthiness Release Form or make a maintenance Log Entry unless they have been authorized by you.
NOTE: Because a part 145 repair station is not an individual, these same regulations preclude accomplishment of your Airworthiness Release Form or Log Entry by a part 145 certificated repair station. With one exception, the Airworthiness Release Form or Log Entry must be executed by an authorized, certificated individual as described in part 121 or part 135, and according to your procedures. The authorized individual may be employed by the repair station, but they are acting on your behalf, not on behalf of the repair station. This is consistent with §§ 119.1(c) and 121.1(b) or 135.1(a)(2).
(5) Your maintenance manual should include detailed procedures for accomplishing the Airworthiness Release Form or Log Entry after any maintenance is accomplished. The procedures should include processes designed to ensure that your aircraft are not operated after any maintenance, preventive maintenance, or alteration is accomplished unless the Airworthiness Release Form or maintenance Log Entry is completed.
(6) Your maintenance manual should include detailed procedures for qualifying and authorizing each individual who is authorized to accomplish your § 121.709 or § 135.443 Airworthiness Release Form or Log Entry. These procedures should include a positive, readily available means of documenting and transmitting the authorization to the individual, including the scope and limitations of their authorization.
c. Service Difficulty Reports. You are required to make service difficulty reports by §§ 121.703 and 135.415. While these reports can identify deficiencies within your maintenance program, these reports are the FAA’s primary means of gathering information for the FAA’s Service Difficulty Reporting Subsystem (SDR).
d. Mechanical Interruption Reports. You are required by §§ 121.705 and 135.417 to make mechanical interruption reports. These reports document the inability of your aircraft to arrive at its scheduled destination because of mechanical difficulties. This is a prime indicator of deficiencies in the effectiveness of your maintenance program. Moreover, analysis of these
Page 32 Par 810 reports is one of the FAA’s most useful means of oversight of the level of effectiveness of your maintenance program.
810. REQUIREMENTS FOR REPORTS OF MAJOR ALTERATIONS AND MAJOR REPAIRS.
a. If you are a part 121 air carrier, § 121.707 requires you to make a report of each major alteration and repair. The alteration report must be submitted to the FAA and the major repair report must be made available for inspection by the FAA. This falls under § 119.59 requirements. In addition, because you are an air carrier, you do not have to use FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance) to report a major alteration or repair that you accomplished.
b. If you are a part 135 air carrier, there is no requirement to submit any reports of major alterations or repairs. However, as with any required record of aircraft maintenance or alteration, you must make them available to the FAA upon request.
NOTE: You should not confuse these alteration and repair reports with the current status listing of major alterations required under part 121 or the current status listing of major repairs and alterations required under part 135.
811. REQUIREMENTS FOR HISTORICAL OR SOURCE RECORDS. You do not have to keep historical or source records to prove that your required records, such as current status records, that you must make, keep and make available to the FAA are, true and accurate.
Inherent with the requirements and objectives of your air carrier maintenance program, you must have a system to prepare, store, and retain your required maintenance records; you must monitor that system under your CASS to ensure that your procedures are being followed and are effective. This ensures your required records are true and accurate. Records such as the inservice history of life-limited parts (traceability back to birth) or the record of accomplishment of an AD do not need to be kept indefinitely. Remember, there are severe criminal penalties for falsifying, or failing to make, or keep air carrier records. Consistent with the FAA regulations, unless there is evidence to the contrary, an aircraft maintenance record produced by your maintenance recordkeeping system should be acceptable by itself, without other historical or source records. The important consideration here is that you have a sound and properly working recordkeeping system. You may wish to archive certain source 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. You may also have business reasons to maintain historical records, but business reasons would not relate to the absence of any FAA regulatory requirements for historical records. The only records that you are legally required to make and retain are those records that are clearly outlined in 14 CFR.
Par 900 Page 33 CHAPTER 9. CONTRACT MAINTENANCE
900. RESPONSIBILITY FOR MAINTENANCE PERFORMED BY OTHERS. Consistent with §§ 121.1(b), 135.1(b)(2) and others, when you use a maintenance provider to accomplish all or part of the maintenance activities on your airplane or its component parts, that maintenance provider becomes, in effect, part of your maintenance organization and under your control.
However, §§ 121.363 and 135.413 make it clear that you remain primarily responsible for all of the maintenance performed by that maintenance provider on your aircraft. You must determine that the maintenance provider has the capability to do your work on your behalf, direct their work, and determine that their work was done satisfactorily according to your manual and your standards. Because all work on your aircraft must be performed in accordance with your maintenance manual and your maintenance program, you must also provide the maintenance provider with appropriate material from your maintenance manual for that work. You must ensure that the maintenance provider follows the procedures in your manual that you have provided. You should accomplish this through work-in-progress audits while the maintenance provider is accomplishing the work. Your manual system should accommodate work performed for you by each maintenance provider. The policy and procedures portion of your maintenance manual should assign clear authority and responsibilities and outline procedures for your personnel to administer, control, and direct all contracted work. The technical material that you provide should be arranged for the use and guidance of the maintenance provider. When possible, you should have a written contract with anyone performing maintenance work for you on a continuing basis. This will help ensure your responsibilities are addressed. In the case of major operations, such as engine, propeller, or airframe overhaul, the contract should include a specification for the work. You should include or reference that specification in your manual system.
901. UNSCHEDULED MAINTENANCE PERFORMED AWAY FROM REGULAR FACILITIES. Sometimes, you will need maintenance performed on your aircraft while it is away from your regular maintenance facilities. You also may need maintenance services on short notice. Your maintenance manual should include procedures for obtaining these services under these unanticipated conditions. You should never use the term “emergency maintenance” to describe short notice unscheduled maintenance, as such terms imply to your workforce that FAA’s regulations and your procedures do not have to be followed. Emergency means that a serious situation has occurred unexpectedly, involves a peril to life or property, and demands immediate action. An out of commission aircraft parked on an airport ramp could hardly constitute a peril to life or property. You should outline the procedural steps you will take to control and direct the unscheduled maintenance that is required. Unscheduled, short-notice requirements for maintenance do not void your responsibility to determine that your maintenance provider has the organization, adequate facilities and equipment, competent personnel, and appropriate portions of your manual for the work that needs to be done. These determinations must be made before any maintenance provider starts to work on your aircraft. These procedures and determinations should be in your manual.
902. AIRWORTHINESS RELEASE FORM OR AIRCRAFT LOG ENTRY.
Sections 121.379(b) and 135.437(b) authorize you to approve your aircraft, airframes, aircraft engines, propellers, or appliances for return to service after you accomplish any maintenance, preventive maintenance, and alterations. These sections only authorize any person other than you
Page 34 Par 902 to approve your aircraft for return to service. §§ 121.709(b) and 135.443(b) outline requirements for those personnel making a Log Entry or issuing an air carrier Airworthiness Release Form under part 121 or part 135. These regulations require a certificated repairman, or certificated airframe and powerplant mechanic that you authorize to make the Log Entry or issue the Airworthiness Release Form for you. These regulations clearly do not authorize a repair station certificated under part 145 or any other entity to make an Airworthiness Release Form or Log Entry on your behalf. The regulations set forth clear personnel qualification requirements for each individual you so authorize. The approval for return to service authority remains solely with you. An individual may not issue an approval for return to service for your aircraft unless you authorize them to do so.
a. You must designate each individual authorized to execute the Log Entry or Airworthiness Release Form for you by name and occupational title. The individual making the Log Entry or Airworthiness Release Form acts as your authorized agent. He or she certifies that the maintenance was accomplished according to your maintenance manual and maintenance program procedures and that no known condition exists that would make the aircraft non-airworthy. This arrangement does not reduce the responsibility of maintenance personnel to accomplish maintenance functions or tasks in accordance with your manual.
b. Consistent with §§ 121.709(b)(1) and 135.443(b)(1), you must include in your maintenance manual the procedures for making an aircraft Airworthiness Release Form or Log Entry. A Log Entry or Airworthiness Release Form is required to be accomplished before you can operate your aircraft for any reason after you have accomplished any maintenance. You are required to make a Log Entry or an Airworthiness Release. Other than form or format, there is no legal or technical difference between an Airworthiness Release Form and a Log Entry.
903. EVALUATING NEW CONTRACT MAINTENANCE PROVIDERS. Before you can use a maintenance provider for the first time, you must determine that the maintenance provider candidate complies with pertinent requirements of part 121, subpart L, or part 135, subpart J. In most cases, you would conduct an onsite audit. You must demonstrate, through this audit or by some other means, that the maintenance provider has an adequate organization, adequate facilities and equipment, competent personnel and is capable of performing the work consistent with the requirements of your program. Your determination of whether to accomplish an on-site audit should be based on risk assessment. The risk assessment should take into account the aircraft part failure or system loss of function, and the consequence of the loss of function related to the work being accomplished.
904. CONTINUING MAINTENANCE PROVIDER OVERSIGHT. Ensuring that each one of your maintenance providers is in continuous compliance is a major function of your CASS.
You should use your risk-based process for establishing a schedule for auditing and inspecting each of your maintenance providers. Inherent with a risk-based process, you may determine that some of your maintenance providers do not require an on-site audit. Consistent with the “performance” wording of § 121.373 or 135.431, the audits that you accomplish should be primarily work-in-progress audits that determine if the maintenance personnel are following your manual. The audits should be accomplished by trained auditors, and the results analyzed by trained analysts. The results of the analysis should permit you to determine each maintenance
Par 904 Page 35 (and 36) provider’s continuing compliance with part 121, subpart L, or part 135, subpart J, as appropriate, and your maintenance program.
905. USING A CERTIFICATED REPAIR STATION AS ONE OF YOUR MAINTENANCE PROVIDERS.
a. If you decide to exercise your authority under §§ 121.379 or 135.437 to make arrangements with other persons to perform maintenance, preventive maintenance, and alterations for you as provided in your manual, you may choose to make these arrangements with an FAA certificated repair station, but you are not required to do so. The scope of your authorization to make arrangements for maintenance is very broad; you can make these arrangements for maintenance with any “person” as that term is defined at 14 CFR § 1.1.
Although the 14 CFR § 1.1 term “person” includes a certificated repair station, it also clearly does not exclude any other “person” who does not hold an FAA certification.
b. The air carrier regulatory and maintenance program requirements that you would use to qualify a maintenance provider that holds a current part 145 repair station certificate are exactly the same as those that you would use for a maintenance provider who does not hold a current part 145 repair station certificate; there is no difference. Consistent with §§ 119.1(c), 121.1(b) or 135(b)(1), each “person,” whether certificated or not, that is employed or used by you for any maintenance, preventative maintenance or alteration of your aircraft is required to comply with the part 121 requirements and your maintenance program requirements, not part 65 or part 145 requirements.
c. Further, your §§ 121.379(b) or 135.437(b) authorization to approve your aircraft for return to service after maintenance extends to the work accomplished under your §§ 121.379(a) or 135.437(a) authorization to make arrangements with other “persons” for maintenance.
Par 1000 Page 37 CHAPTER 10. PERSONNEL TRAINING 1000. MAINTENANCE PROGRAM TRAINING REQUIREMENTS. You can find your specific air carrier maintenance training requirements in certain sections of part 121, subpart L, and part 135, subpart J. Sections 121.375 and 135.433 require you to have a training program that ensures each person (including inspection personnel) who determines the adequacy of work done for you is fully informed about procedures and techniques and new equipment in use and is competent to perform his or her duties. There is an additional implied training requirement in part 121, subpart L, and part 135, subpart J based on your responsibility to provide competent personnel for the proper performance of your maintenance program. A training program is the logical means for ensuring maintenance personnel are competent. FAA regulations allow you to develop a training program fitting your particular needs.
1001. TYPES OF TRAINING. Some of the possible types of training in your training program are initial training, recurrent training, specialized training, competency-based training, and maintenance-provider training. You should select the appropriate training for your personnel, including your maintenance provider personnel, which is based on an assessment of training needs. This assessment is a reflection of the required knowledge, skills, and ability to properly accomplish a given task or function and the current capability of those who would be assigned the task or function.
1002. INITIAL TRAINING. You should provide initial training right after a person is hired, or when your personnel begin to work on new equipment or a new assignment. Your initial training program may include subjects such as employee indoctrination or orientation, maintenance department policies and procedures, maintenance recordkeeping and documentation, aircraft systems or ground equipment, specific skills (for example, avionics, composite repair, aircraft run-up and taxi), skills upgrade, human factors, task-specific training, hazardous materials, or Environmental Protection Agency and Occupational Safety and Health Administration regulations familiarization. Your initial training should also include a competence-based assessment of employees. This evaluates an employee’s previous training and experience and helps identify his or her specific individual training needs. The objective is to provide training that addresses the gap between required competence and the competence an individual already has.
1003. RECURRENT TRAINING. Recurrent training is education occurring on a repetitive basis. You must provide maintenance personnel with the information and skills necessary to maintain your standard of competence. This training also accommodates the introduction of new aircraft, aircraft modifications; new or different ground equipment; new procedures, techniques, and methods; or other new information. Your recurrent training, although occurring on a repetitive basis, may not adhere to a defined schedule. You should not provide repetitive information in recurrent training unless it is needed to maintain the desired degree of competence. Your recurrent training may include:
a. Continuing competency training designed to maintain regulatory and certificate currency requirements.
b. Refresher training on a seldom accomplished task or seldom used skill.
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c. Update training for particular tasks or skills. Update training can include training bulletins, bulletin-board items, self-study tasks, and computer-based instruction.
d. Any other continuing education or training that may not be provided on a defined schedule.
1004. SPECIALIZED TRAINING. Your specialized training should focus on competence in specific tasks or areas of responsibility, such as RII, borescope, non-destructive testing, or flight control rigging. You might provide this training with initial or recurrent training. You do not need to limit it to maintenance subjects, but instead may include management skills training for new supervisors, computer skills, or other training necessary because of a change in an individual’s duties and responsibilities.
1005. MAINTENANCE PROVIDER TRAINING. Your training program must provide appropriate information to each employee of a maintenance provider about your specific program. The training should include function-specific training appropriate to each person’s job assignment or area of responsibility. You do not need to provide training to maintenance provider personnel in areas that do not concern them. For example, training on aircraft log procedures and minimum equipment list procedures would not be required for aircraft interior cleaners, but would be required for maintenance personnel assigned to on-call maintenance for you.
NOTE: If your maintenance provider has specific types of training for its personnel, you do not need to duplicate that training for those individuals.
However, you must ensure your maintenance provider actually has provided the training and that the training meets your own needs and training standards. This could be a CASS work-in-progress audit.
1006. COMPETENCY-BASED TRAINING. Although air carriers historically have provided a specified number of maintenance training hours to ensure employees have the competencies needed for their jobs, studies have shown that it may be better for you to train to a competencybased standard. You do not have to perform this type of training on a defined schedule or for a specific number of hours. Rather, you should test each individual to evaluate what training he or she needs, and then use these evaluations to identify those personnel who retain a high level of subject competence and who may not require a particular block of instruction. Conversely, you also should identify those individuals who require more training. Training to competence permits you to tailor training programs to the specific requirements of your individual maintenance personnel and maintenance providers.
a. Competency-based training can be used to raise an employee’s level of competence to that level required by the individual’s duties and responsibilities. You should have procedures to determine when an individual requires competency-based training. You may determine the need for this type of training through pre- or post-employment testing, or through the analysis and corrective action functions of your CASS. If you use competency-based training, it should specifically address the lack of competence. In some instances, competency-based training may consist of an appropriately knowledgeable person simply reviewing procedures with an employee through on-the-job training. You should design competency-based training to fix an