CHAPTER 3. ELECTRONIC RECORDKEEPING
3-1. ELECTRONIC RECORDS. An electronic record must provide equivalent or better data integrity, accuracy, and accessibility to what would otherwise be provided by a paper record. In general, a record preserves the evidence of an event. It should contain enough information to clearly depict the event that took place. It is the certificate holder’s responsibility to address all 14 CFR requirements for their recordkeeping system(s) applicable to their operation(s).
3-2. FAA STANDARDS FOR ELECTRONIC RECORDS. To be considered complete and valid, an electronic record should contain at least the following information:
• The type of event that took place (e.g., training, maintenance performed, signing of a release, conduct of a flight, etc.);
• For a training event, information that shows compliance with regulatory requirements, such as the name of the course module or subject, the number of hours of instruction, whether the student passed or failed, etc.;
• When the event took place (e.g., the date and time (where appropriate));
• Where the event took place (e.g., the station, training facility, maintenance
facility, etc.);
• Who was involved in the event (e.g., crewmember, dispatcher, instructor, mechanic, etc.);
• Aircraft type and registration number for pilot logbook records (when required by regulation);
• Certification, verification, or authentication of the event, such as a signature, where required by regulation; and
• Applicable aircraft, airframe, engine, propeller, appliance, component, or part make and model (M/M) for maintenance records, such as life-limited parts and time-in-service records.
3-3. ELECTRONIC RECORDKEEPING SYSTEM. Electronic recordkeeping system(s) should include the following elements:
a. Security.
(1) The system should protect confidential information.
(2) The system must ensure that the information in an electronic record is not altered in an unauthorized way.
(3) The system must provide for secure access and contain safeguards against unauthorized access.
b. Procedures. Electronic recordkeeping system procedures must be incorporated into the certificate holder’s manual system. For those certificate holders who are not required to have manuals (e.g., 14 CFR part 135 single pilot and 14 CFR part 141), a standalone electronic recordkeeping system procedures document is an acceptable alternative, provided it is an official document maintained by the certificate holder. Procedures should include at least the following:
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(1) Procedures for Making Required Records Available to FAA and National Transportation Safety Board (NTSB) Personnel. A certificate holder must provide its records in a format and manner that is acceptable to the requesting agency. FAA personnel assigned to a certificate holder with an electronic recordkeeping system may request a certificate holder to provide direct access to the electronic system for the purpose of inspecting regulatory records.
Providing this direct access to the FAA is voluntary. The FAA will not request direct electronic access to records beyond those that are required by regulation and authorized in Operations Specification (OpSpec) A025, Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manual Systems. It is important to distinguish a certificate holder’s voluntary provision of direct access to its electronic recordkeeping system to the FAA from the certificate holder’s responsibility to make regulatory records available to the FAA in accordance with 14 CFR part 119, § 119.59(c). In accordance with this regulation, each employee of, or person used by, the certificate holder who is responsible for maintaining the certificate holder’s regulatory records (those required under Title 49 of the United States Code (49 U.S.C.)
applicable to the operation of the certificate holder) must make those records available to the Administrator.
(2) Quality Control (QC). The system should have procedures for auditing the computer system periodically to ensure the quality, integrity, and accuracy of the system. If workstations are server-based and contain no inherent attributes that enable or disable access, there is no need for each workstation to be audited. (A record of the audit should be completed and retained on file as part of the certificate holder’s record retention requirements. This audit may be a computer program that automatically audits itself.)
(3) Maintenance Support and Backup Measures. The system should include procedures for maintenance and support that include provisions for electronic system (computer hardware, software, application network, etc.) outages and protect against the loss of record data.
The system should also include backup measures to maintain and provide access to records in the event of a system failure. The backup system may be a separate electronic system, a backup server, or backup drive. Backup can also include media such as print or CD-ROM, external drive, or other media acceptable to the FAA.
(4) Record Transfer. Procedures should ensure that records transferred with an aircraft (either electronic or on paper) meet regulatory requirements (i.e., 14 CFR part 43, § 43.10;
part 91, § 91.419; part 121, § 121.380a; and part 135, § 135.441).
(5) Persons with Authorized Access. The system procedures should contain guidelines for authorized representatives of the certificate holder to use electronic recordkeeping and to have access to the appropriate records (each representative with authorization to make entries shall be issued a unique individual access code and password in order to validate the entry). In particular, procedures should specifically address instructor, evaluator, and supervisor access to the system.
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(6) Electronic Authentication, Signature, Validation, or Endorsement. Most records required by 14 CFR require some kind of validation, such as a signature, certification, endorsement, or authentication. This validation must be a permanent part of any electronic record. Any electronic form of validation must meet the legal requirements of electronic signing as outlined in this AC. The certificate holder must also have authorization to use an electronic signature in OpSpec A025.
(7) Training and User Instructions. Each electronic recordkeeping system should contain training and user instructions for the persons responsible for entering, maintaining, and retrieving data from the system. Training should include security awareness and system integrity, as well as procedures that are necessary to authorize access to the electronic recordkeeping system. User instructions should include those for FAA personnel who are provided direct access to the system.
(8) Transferring Data. Technological advances may make it desirable or necessary for a certificate holder to update its electronic recordkeeping system or transfer data to a new system. The certificate holder must have policies and procedures that ensure the continued integrity of record data when a certificate holder moves records from one system to another. This could entail running redundant systems for a brief period of time.
(9) Continuity of Data Between Legacy and Electronic Systems. The system should have a method of ensuring continuity of data during transition from a legacy (hardcopy) system to an electronic system.
(10) Continuity of Records for Maintenance Providers. Procedures should ensure continuity with maintenance providers. Certificate holders must ensure there is continuity between their program(s) and their maintenance provider’s programs. This is necessary to ensure the quality and integrity of each record that is maintained via the electronic recordkeeping system.
c. Responsible Personnel. Policies and procedures should identify the certificate holder’s personnel who have the authority and overall responsibility for the integrity and security of the electronic recordkeeping system and who are responsible for controlling access to the system.
Policies and procedures should also identify the persons with the authority and responsibility for modifying the electronic recordkeeping system, as well as those who are responsible for entering data into the system.
d. Description of Electronic Recordkeeping System(s). There may be more than one system required to maintain various kinds of records. Each electronic recordkeeping system used by the certificate holder must be described in its manual. The manual containing the description will be included in the OpSpec A025 authorization for parts 91K, 121, 125, and 135. For those certificate holders who are not required to have a manual, a standalone electronic recordkeeping system procedures document is an acceptable alternative, provided it is an official document maintained by the certificate holder. Each electronic recordkeeping system description should address the information and elements contained in paragraphs 3-1, 3-2, and 3-3 of this AC, as well as the following:
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(1) Description of electronic recordkeeping system(s) to include system facilities, hardware, and software.
(2) Identification of records that will be maintained in the electronic system(s).
(3) Identification of which electronic records on which the certificate holder will use an authorized electronic signature process.
e. Changes to the Electronic Recordkeeping System. A certificate holder’s policies and procedures should include details of when revisions to the electronic recordkeeping system will be submitted for approval or acceptance (depending on the regulatory requirement) prior to implementation. This includes new versions of system software. Software version numbers will be included in the OpSpec A025 authorization for parts 91K, 121, 125, and 135. For all operations to which this AC applies, changes to the electronic recordkeeping system must be included in the manual or official document containing the electronic recordkeeping system description.
f. Audit Procedures. The certificate holder must have auditing procedures that ensure the quality and integrity of each record maintained in the system and that all of the requirements of the electronic recordkeeping system continue to be met. Procedures should include unauthorized event recognition, which includes actions to be taken by the certificate holder upon discovery of an attempt by an unauthorized individual to access and/or make entries into the electronic recordkeeping system.
3-4. ELECTRONIC RECORDKEEPING AUTHORIZATION.
a. Application. Certificate holders should submit their application for an electronic recordkeeping process to their certificate-holding district office (CHDO). The application medium (paper or electronic file) must be acceptable to both the applicant and the FAA. The FAA will review the application package according to the General Process for Approval or Acceptance of Air Operator Applications contained in FAA Order 8900.1, Flight Standards Information Management System (FSIMS), Volume 3, Chapter 1, The General Process for Approval or Acceptance of Air Operator Applications. The FAA will review the application package for accuracy and completeness and discuss any deficiencies with the certificate holder.
The FAA may also notify the certificate holder in writing of any application deficiencies. Before the CHDO accepts the application package, the certificate holder will be required to correct all of the deficiencies A certificate holder’s application package for authorization to use an electronic record keeping system must include the following:
(1) Letter of Intent. The application must contain the certificate holder’s letter of intent to use an electronic recordkeeping system.
(a) The Name of the Electronic System(s). The letter must include the kinds of records along with the name of the electronic system to be used to maintain the records. There may be more than one system required to maintain various kinds of records.
(b) Estimated Date of Implementation. The letter must include the estimated date on which the certificate holder would like to implement the electronic recordkeeping system.
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(c) Primary Point of Contact (POC). The letter must include the certificate holder’s primary POC for the electronic recordkeeping system application process.
(2) A Description of the Proposed Electronic Recordkeeping System(s). The electronic recordkeeping system description must address all of the requirements contained in paragraphs 3-1, 3-2, and 3-3 of the AC, and include a description of the system facilities, hardware, and software. Software version numbers must be included.
(3) The Records That Will be Maintained in the System. The certificate holder must state specifically which records the certificate holder intends to maintain and access via the electronic recordkeeping system. The application should include a sample of each record type.
(4) The Data Backup. The application must describe the details of the certificate holder’s data backup system.
(5) Access and Security Procedures. The application must include information regarding access and security procedures.
(6) Electronic Signature Processes. The application must include a description of any electronic signature process associated with each electronic record category.
b. Demonstration of the System. The FAA will require a certificate holder to demonstrate the electronic record keeping system. The items requiring demonstration will typically include at least the following:
(1) User Access. The certificate holder should demonstrate how to securely access the system.
(2) Security Protocols and Prevention of Unauthorized Access and Record Modification. The certificate holder should demonstrate how the system prevents unauthorized access or modifications to the records maintained on the system.
(3) Record Entry. The certificate holder should demonstrate how a record is entered into the system.
(4) QC Procedures. The certificate holder should demonstrate the procedures for ensuring the quality and integrity of each record maintained on the system.
c. Successful Completion of Application Process for Approval or Acceptance and Authorization. When the certificate holder successfully completes the application and demonstration process, the FAA will accept or approve (depending on the regulatory requirement) the electronic recordkeeping system and authorize its use by signing and issuing OpSpec A025.
d. Unsuccessful Application. If the certificate holder fails to submit an acceptable application or fails to successfully demonstrate the electronic recordkeeping process, the CHDO will reject the application and provide an explanation to the certificate holder in writing.
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CHAPTER 4. ELECTRONIC MANUAL SYSTEMS
4-1. ELECTRONIC MANUALS. Like printed manuals, electronic manuals must provide instructions and information necessary to allow personnel concerned to perform their duties and responsibilities with a high degree of safety. An electronic manual must provide equivalent or better data integrity, accuracy, and accessibility to what would otherwise be provided by a printed manual. The content of each electronic manual must be clearly identifiable and viewable by the user and must correlate and be comparable to what would be available in a printed version of the manual. An electronic manual should contain elements that generally comprise a printed manual. These elements typically include:
• The manual title;
• Revision control pages or sections from which the user can readily determine whether the manual is current;
• List of effective pages;
• Indication of FAA approval (e.g., signature or stamp) for those manuals or manual sections that require FAA approval;
• Chapter numbers;
• Chapter headings;
• Section numbers;
• Topic headings;
• Page numbers;
• Applicable aircraft, airframe, engine, propeller, appliance, component, or part make and model (M/M) (when applicable for minimum equipment list (MEL) and maintenance purposes); and
• The person with the authority and responsibility for manual content.
4-2. ELECTRONIC MANUAL SYSTEM. An electronic system for delivering manual content must comply with regulatory requirements for currency, availability, and distribution to the appropriate personnel. A certificate holder’s electronic manual system must address any 14 CFR part requirements for “must” or “should” that apply to their operation(s) into their electronic manual system. An electronic manual system should describe/address:
a. Currency. Each certificate holder’s electronic manual system method of keeping each manual current.
b. Access, Availability, and Distribution. Each electronic manual system should provide distribution and/or access to manual(s) by the appropriate personnel, in a form and method acceptable to the Administrator.
c. MEL Direct Access Requirement. As required by part 91, § 91.1115(a)(2); part 121, § 121.628(a)(2); part 125, § 125.201(a)(2); and part 135, § 135.179(a)(2) certificate holders who conduct operations under part 91K, 121, 125, or 135 must provide flightcrews with direct access to the MEL through printed or other means approved by the Administrator. An Electronic Flight Bag (EFB) is an example of other means that may be approved by the FAA.
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d. FAA/National Transportation Safety Board (NTSB) Access. The FAA encourages certificate holders to provide access to the electronic manual system to the appropriate FAA representatives assigned to the certificate holder. When providing such access, a certificate holder should provide the FAA’s representatives with instructions on how to access the system.
Certificate holders must provide any requested information to the NTSB in the event of an accident or incident. When a certificate holder is required to provide manuals or manual information to the FAA or NTSB, it should be provided in the desired format of the requesting agency whenever possible.
e. Responsible Personnel. The system description should include the certificate holder’s personnel who have the authority and responsibility for maintaining the system, implementing, modifying, revising, and monitoring the electronic manual software and ensuring the overall integrity of the content of manuals that are part of the system.
f. Prevention of Unauthorized Access and Data Corruption. Manual system computer hardware and software must prevent unauthorized access and/or modification to electronic manual content.
g. Storage and Retrieval. The computer hardware and software system must store and retrieve the manual’s content under conditions of normal operation and use. The system must not permit unauthorized modification of the data it contains.
h. Functionality. Users should be able to easily access, navigate, and retrieve manual content via computer or comparable device. Manual users should be able to print any information contained in an electronic manual.
i. Revision Control. A certificate holder’s electronic manuals should be easy to revise.
The electronic manual system should include revision control procedures for making revisions (incremental, temporary, and scheduled) in a timely manner. Procedures should include the accomplishment of revisions by personnel to whom manuals are issued. The revision control procedures should address at least the following:
(1) Communication of Revision Information. Procedures should include the method of communicating revision information, similar to what would be provided for a paper manual revision. Revision information should provide the revision content, effective date, and any instructions required for ensuring the revision is uploaded or incorporated into the electronic manual. Revision information should allow the user the ability to compare the current revision to the previous version, or it should explain the effect of the change. The revision system should make changes under the current revision readily apparent. An example of this would be change bars. An electronic manual should contain a revision control page or section from which the user can readily determine whether the manual is current.
(2) Revision Status of Each Manual Page. Each page of a manual should contain the date of the latest revision for that particular page. For part 121 operations, this is required by § 121.135(a)(3). If an electronic manual is distributed via a device that displays the manual in a continuous flow format, as opposed to page-by-page, then each section or block of information displayed on the device must contain the date of the latest revision.
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(3) Date and Time Stamp of Printed Information. When information from an electronic manual is printed, there should be a means to identify the date and time of printing.
This ensures the currency of information by allowing the manual user to compare the date of the printed information with the date of the information contained in the electronic manual system.
Printed information that has the same date, but differs from the information contained in the electronic manual, would indicate that the manual content was printed before the manual was updated later that day.
(4) User Responsibility for Current Information. Users of electronic manuals who need or elect to print material (data information, instructions, procedures, etc.) from the electronic manual must ensure the printed information is the most current available prior to use.
Users should discard printed manual information after using it to ensure printed information does not become outdated.
(5) Distribution and Submission of Electronic Revisions to the FAA.
(a) Revision control procedures should include the certificate holder’s method of distributing electronic revisions to the FAA.
(b) When a particular manual requires FAA approval or acceptance, the certificate holder’s procedures should explain how the certificate holder will submit an electronic revision to the FAA for approval or acceptance of the revision content.
j. Special Considerations in Displaying Information. Information retrieved from an electronic manual could be displayed in a format that differs from what would appear on paper.
The display format could even vary by user. For example, the display of manual content could be different for pilots on the flight deck of an aircraft versus what is displayed to ground personnel at a computer workstation. This could occur for reasons such as screen resolution, software application, or authorized display device. Information displayed on any authorized device on the flight deck must correlate to information displayed at an authorized computer workstation or authorized portable device. Additionally, any information displayed should be easily traceable and comparable to the source document. The most important point is that the electronic manual content must remain the same, regardless of the display format or device. Any displayed manual information must be identical in content for all users.
k. Data Archiving. An electronic manual system should have a method of archiving technical and procedural data superseded by revision. A certificate holder should archive earlier versions of manuals to provide for future needs to duplicate, regenerate, or reconstruct instructions.
(1) The Importance of Historical Data. Archived historical data is particularly important for the following reasons:
(a) To trace aircraft repair information or reconstructing maintenance instructions.
(b) To evaluate normal and abnormal flight deck (cockpit) checklist procedures.
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(c) For training purposes.
(d) For investigation purposes in the event of an accident, incident, or occurrence.
(2) Preservation of Archived Data. An electronic manual system must have procedures to ensure the integrity of the archived technical and procedural data. These procedures should include at least:
(a) A method of ensuring that no unauthorized changes can be made.
(b) A method or medium that minimizes the deterioration of data.
(c) A method to protect the archived data against hazards and natural disasters.
l. Transferring Data to Another System. Technological hardware or software advances may make it desirable and/or necessary for a certificate holder to update its electronic manual system. When transferring manual data from one electronic system or application to another, certificate holders should ensure that data integrity is maintained during transfer. This includes ensuring that archived information remains intact. This could entail running redundant systems for a brief period of time.
m. Backup Method. A certificate holder that uses an electronic manual system must have a backup method of maintaining, distributing, or otherwise providing access to manuals, in case of system hardware or software failure. The backup method may be a separate electronic system;
a backup server to the authorized system; the use of backup media such as print or CD-ROM; or other method acceptable to the FAA.
n. System Maintenance and Support. Each certificate holder’s electronic manual system should include maintenance and support function that identifies hardware and software failures within the system. System maintenance and support should include provisions for system outages and for switching over to the backup method described in subparagraph 4-2m above.
o. Master Manual for Parts 91K, 121, 125, and 135. An electronic manual system used in operations under parts 91K, 121, 125, and 135 must include a master manual that describes the electronic manual system and lists each manual maintained and distributed via the system.
(A part 135 certificate holder authorized by OpSpec A040 as a Single Pilot Operator, who elects to have a manual and maintain/distribute it electronically, may list that manual as being the master manual for the purposes of A025.) The master manual is what the principal inspector (PI) will reference when accepting the electronic manual system and authorizing its use in Operations Specification (OpSpec) A025, Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manual Systems. The master manual must include at least the following:
(1) Description of the Electronic Manual System. The electronic manual system description should include the methods for distribution and/or access to manual(s) (including manual revisions and replacements) by the appropriate personnel.
(2) Delivery Media. An electronic manual system description must include an explanation of the media by which the manuals will be distributed to required personnel.
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(3) Personnel with Authority and Responsibility. The master manual must list the certificate holder’s personnel who have the overall authority and responsibility for maintaining the electronic manual system.
(4) Listing of Manuals—Certificate Holders with Large and Complex Manual Systems. For a certificate holder with a large and complex manual system that contains numerous manuals, it is acceptable to list the kids of manuals, instead of listing each manual, provided all of the particular kinds of manuals are maintained and distributed via the electronic manual system. For example, list “All Ground Operations Manuals,” “All Maintenance Manuals,” or “All Training Program Manuals.”
p. Description of the Electronic Manual—Parts 133 and 145. For electronic manuals used in parts 133 and 145, a description of how each electronic manual is displayed, maintained, revised, and distributed should be included in the certificate holder’s manual system. The description must also include an explanation of the media by which manuals will be distributed to required personnel.
q. Electronic Manual System Changes. Policy and procedures should address how the certificate holder will submit changes to the electronic manual system to the FAA for acceptance. For parts 91K, 121, 125, and 135, changes to the electronic manual system must be documented through revision to the master manual containing the electronic manual system description. The master manual revision number and date will be included in the OpSpec A025 authorization.
r. User Instructions and Training. Each certificate holder must provide instructions and training to users of the electronic manual system. The scope and complexity of the training may vary depending on an individual’s duties and responsibilities. Training should include security awareness and computer system (hardware, software, application, network, etc.) integrity.
4-3. ELECTRONIC MANUAL AUTHORIZATION.
a. Application. Certificate holders should submit their application for an electronic manual system to their certificate-holding district office (CHDO). The application medium (paper or electronic file) must be acceptable to both the applicant and the FAA. The FAA will review the application package according to the General Process for Approval or Acceptance of Air Operator Applications contained in FAA Order 8900.1, Flight Standards Information Management System (FSIMS), Volume 3, Chapter 1. The FAA will review the application package for accuracy and completeness and discuss any deficiencies with the certificate holder.
The FAA may also notify the certificate holder in writing of any application deficiencies. Before the CHDO accepts the application package, the certificate holder will be required to correct all of the deficiencies. A certificate holder’s application package for authorization to use an electronic manual or manual system must include the following:
(1) Letter of Intent. The application must contain the certificate holder’s letter of intent to use an electronic manual system.
(a) Estimated Date of Implementation. The letter must include the estimated date on which the certificate holder would like to implement the electronic manual system.
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(b) Primary Point of Contact (POC). The letter must include the certificate holder’s primary POC for the electronic manual system application process.
(2) Master Manual for Parts 91K, 121, 125, and 135. An application to use an electronic manual system for part 91K, 121, 125, or 135 must include a copy of the proposed master manual as described in subparagraph 4-2o of this AC.
(3) A Description of the Proposed Electronic Manual—Part 133 and 145. An application to use an electronic manual for parts 133 and 145 must include a description of the electronic manual as described in paragraph 4-2p of this AC.
(4) Manuals Included in the System. The application must state specifically which manuals the certificate holder intends to maintain and distribute electronically:
• Flight Operations Manuals (FOM) by title;
• Ground operations manuals by title;
• Maintenance manuals by title;
• Training program manuals by title;
• Electronic MELs;
• General policy manuals by title; and
• User manuals (e.g., flight planning system and other hardware/software applications) by title.
(5) Distribution to the FAA. The certificate holder must provide a copy of the electronic manuals to the CHDO and provide an explanation of how revisions and future electronic manuals will be distributed to the FAA.
(6) Electronic Access to an MEL. Parts 91K, 121, 125, and 135 require a certificate holder or program manager to have FAA approval and OpSpec authority to provide access to an MEL via electronic means. Certificate holders desiring to provide electronic access to an MEL must specify that in the application and include details on how electronic access will be provided.
b. Demonstration of the System. The FAA will require a certificate holder to demonstrate the electronic manual system. The items requiring demonstration will typically include at least the following:
(1) Hardware and Software Capabilities. The certificate holder should demonstrate how to use the hardware and software by performing simple tasks within the system.
(2) Distribution and Availability. The certificate holder should demonstrate how the manuals will be distributed or made available (depending upon the regulatory requirement) to required personnel electronically.
(3) Information Access Capabilities. The certificate holder should demonstrate how to access manual content via the electronic system.
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