12/7/16

 

8900.1 CHG 499

VOLUME 3  General technical administration

chapter 31  Electronic signatures, electronic recordkeeping systems, and electronic manual systems

Section 5  Safety Assurance System: Evaluate a Part 121/135 (10 or More) Certificate Holder/Applicant Maintenance Recordkeeping System

3-3076    REPORTING SYSTEM(S). This section is related to Safety Assurance System (SAS) Element 4.2.4 (AW), Recordkeeping.

3-3077    OBJECTIVE.

A.    Monitoring Air Carrier Aircraft Maintenance Records. This chapter provides information necessary for evaluating air carrier maintenance recordkeeping systems and other required records/reports on an initial and continuing compliance basis. Pertinent sections of Title 14 of the Code of Federal Regulations (14 CFR) outline the requirement of an air carrier system for the preparation, storage, and retention of certain required records and reports. The primary objective of these systems is the generation, storage, retention, and retrieval of accurate and complete air carrier aircraft maintenance records that show that the standard certificate of airworthiness of a particular aircraft is effective.

B.    Regulatory Scope. Consistent with 14 CFR part 121, 121.1(b) and part 135, 135.1(a)(2), the rules (including those regarding aircraft maintenance records), reports, and other required records that parts 121 and 135 contain govern each person employed or used by an air carrier for any maintenance, preventive maintenance, or alteration of its aircraft. Consistent with the definitions in 14 CFR part 1,  1.1, a “person” includes individuals certificated under 14 CFR part 65, repair stations certificated under 14 CFR part 145, and any other “individual, firm, partnership, corporation, company, association, joint-stock association, or governmental entity” that the Federal Aviation Administration (FAA) has not certificated.

3-3078    GENERAL.

Indicates new/changed information.

A.    Standard Certificate of Airworthiness. The standard certificate of airworthiness issued to a U.S.‑registered aircraft is effective as long as regular maintenance, preventive maintenance, and alterations are performed according to the regulatory requirements. In view of this significant requirement, aircraft maintenance records become especially important, since incomplete or inaccurate required aircraft maintenance records can render a standard certificate of airworthiness ineffective. Aircraft maintenance actions, in almost all cases, become intangible or abstract after the fact. Therefore, to make a maintenance action tangible, the aircraft operator makes a record of it. Also, making a record of certain summary information supports the current airworthiness status of an aircraft. These maintenance records are important to the FAA, as the FAA uses its continuing review of aircraft maintenance records as a direct means of determining properly done regular maintenance, preventive maintenance, and alterations, thereby fulfilling, in part, its oversight mandate for the airworthiness and safety of aircraft. Additional information concerning airworthiness can be found in Volume 14, Chapter 3, Section 4.

B.    Criminal Violations. Furthermore, because the review of maintenance records is the only direct means of determining properly done required maintenance, preventive maintenance, and alterations, the U.S. Congress has made it a crime to intentionally fail to make and keep, falsify, mutilate, conceal or induce reliance on a false statement, or alter air carrier aircraft records. Such actions are subject to substantial fines, imprisonment, or both.

1)    Failure to adhere to air carrier maintenance recordkeeping and other required reporting regulations is the only 14 CFR noncompliance established, by statute, as a criminal activity. Moreover, an air carrier’s failure to make available any required record, document, or report is grounds for suspending all or any part of its air carrier’s operating certificate and operations specifications (OpSpecs).
Indicates new/changed information
2)    Since the statutory requirement for regulations reflects an air carrier’s responsibility to operate with the highest possible degree of safety in the public interest, the FAA expects the air carrier to accurately produce, as well as make complete and correct, its records. Keep in mind that deviations by certificate holders often arise from factors such as flawed procedures, simple mistakes, lack of understanding, or diminished skills. The FAA believes that deviations of this nature can most effectively be corrected through Root Cause Analysis (RCA) and appropriate corrective actions by the airmen/entities involved, which are documented and verified by Flight Standards Service (AFS) to ensure effectiveness.
3)    For further information, see the training resources listed in Volume 14, Chapter 1, Section 1, subparagraph 14-1-1-13D. Consider Volume 14, Chapter 3, Section 3 which contains guidance for conducting investigations and enforcement of 14 CFR part 3, which discusses false and misleading statements regarding aircraft products, parts, appliances, and materials. Use Volume 14, Chapter 1, Section 2 to analyze all alleged, suspected, or identified instances of noncompliance based on the specific facts and circumstances involved. When appropriate, use the policy and procedures for handling criminal violations relating to air carrier records and reports contained in the current edition of FAA Order 2150.3, FAA Compliance and Enforcement Program, Chapter 4, Investigation of Violations, paragraph 18.

3-3079    REQUIRED AIR CARRIER AIRCRAFT MAINTENANCE RECORDS.

Indicates new/changed information

A.    Required Records. Regulations require air carriers to make and keep a list of certain summary status records and records related to the issuance of an airworthiness release form, and to transfer that information with the aircraft when it is sold. These specific records are listed in 121.380 and 135.439.

B.    Retention Requirements. Air carrier aircraft maintenance record making and retention requirements have evolved from the minimal records of repairs and alterations required in the pre-World War II era. The current requirements consist of a list of summary status information and maintenance records. Currently, the regulations require each air carrier to keep certain maintenance records using the system specified in 121.369 and 135.427 for the time periods specified in 121.380(c) and 135.439(b).

Indicates new/changed information

NOTE:  In this section the term “rotor” only applies to part 135 certificate holders.

Indicates new/changed information
1)    As referenced in 121.380(c)(1) and 135.439(b)(1), except for the records of the last complete overhaul of each airframe, engine, propeller, appliance, or rotor, all the records necessary to show that all requirements for the issuance of an airworthiness release under 121.709 or 135.443 have been met “shall be retained until the work is repeated or superseded by other work or for one year after the work is performed.”
a)    While the regulatory requirement (for all the records necessary to show that all requirements for the issuance of an airworthiness release have been met) does not provide a detailed list of records that the air carrier must retain, this requirement generally means:

1.    Records of all scheduled maintenance that work of equivalent scope and detail has not superseded.

2.    For those items requiring overhaul, detailed records of the accomplishment of the last overhaul.

3.    Records of all unscheduled maintenance that work of equivalent scope and detail has not superseded.

4.    Adequate copies of the maintenance log, covering the last 60 days of operation, required under 121.563, 121.701, and 135.65 and consistent with 121.709(d).

Indicates new/changed information

NOTE:  Some of the air carrier’s maintenance records that may have been necessary to show that all requirements for the issuance of an airworthiness release, may also belong in a different category for records retention requirements. In this case, the records must be retained to the longer requirement.

2)    As referenced in 121.380(c)(2) and 135.439(b)(2), “the records of the last complete overhaul of each airframe, engine, propeller, rotor, and appliance shall be retained until the work is superseded by work of equivalent scope and detail.”

NOTE:  Regulations do not require an overhaul record to contain a record of Airworthiness Directive (AD) accomplishment. The regulations require the air carrier to make and preserve records of AD current status and accomplishment as a separate and distinct record.

3)    As referenced in 121.380(c)(3) and 135.439(b)(3), the records containing the following information “shall be retained and transferred with the aircraft at the time the aircraft is sold”:
a)    For part 121 certificate holders, the total time in service of the airframe. For part 135 certificate holders, the total time in service of the airframe, engine, propeller, and rotor. (Refer to  121.380(a)(2)(i) and 135.439(a)(2)(i).)
b)    For 121 certificate holders, except as provided in 121.380(b), the total time in service of each engine and propeller. Section 121.380(b) states, “a certificate holder need not record the total time in service of an engine or propeller on a transport category cargo airplane, a transport category airplane that has a passenger seat configuration of more than 30 seats, or a nontransport category airplane type certificated before January 1, 1958, until the following, whichever occurs first: March 20, 1997; or the date of the first overhaul of the engine or propeller, as applicable, after January 19, 1996.” (Refer to 121.380(a)(2)(ii) and 121.380(b).)

NOTE:  Section 1.1 defines “time in service.” Total time in service includes the time in service accrued since new or since rebuilt, expressed in hours and landings or cycles.

Indicates new/changed information
c)    As referenced in 121.380(a)(2)(iii) and 135.439(a)(2)(ii), “the current status of life‑limited parts of each airframe, engine, propeller, rotor, or appliance.”

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.

Indicates new/changed information
d)    As referenced in 121.380(a)(2)(iv) and 135.439(a)(2)(iii), “the time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.”

1.    A listing of the item requiring 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 (TSO) refers to current summary status information and must not be confused with an overhaul record. An overhaul record is a description of the work performed and the identification of the person who performed the work and/or issued the approval for return to service.

Indicates new/changed information
e)    The identification of the current inspection status of the aircraft, including the times since the last inspections required by the inspection program under which the aircraft and its appliances are maintained. (Refer to 121.380(a)(2)(v) and 135.439(a)(2)(iv).)

1.    A listing identifying each of the scheduled inspection packages or groups, or individual tasks, and their associated intervals required by the maintenance program that maintains the aircraft.

2.    The time in service since the last inspections required by the inspection program under which the aircraft and its appliances are maintained.

3.    The time in service remaining to the next completion of each of the scheduled inspection packages or groups, or individual tasks, required by the maintenance program that maintains the aircraft.

4.    The time in service when the next accomplishment of each of the scheduled inspection packages or groups, or individual tasks, required by the maintenance program that maintains the aircraft, is due.

Indicates new/changed information
f)    As referenced in 121.380(a)(2)(vi) and 135.439(a)(2)(v), “the current status of applicable airworthiness directives, including the date and methods of compliance, and, if the airworthiness directive involves recurring action, the time and date when the next action is required.”

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 time in service, expressed in the appropriate measuring parameter (hours, cycles, calendar time, etc.), when the air carrier accomplished the required action.

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.).

5.    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 (SB) 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 alternative 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. The AMOC and a copy of the FAA approval are permanent parts of the method of compliance record. If the air carrier identifies its method of compliance as an internal procedure or document (such as an Engineering Change Order (EO), change order, engineering authorization, or similar document) to accomplish and document the AD accomplishment, the FAA considers a copy of that internal document a permanent part of the method of compliance record.

NOTE:  The record of current status of an AD 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 the work and/or issued the approval for return to service.

Indicates new/changed information
g)    For part 121 certificate holders, per 121.380(a)(2)(vii), “a list of current major alterations to each airframe, engine, propeller, and appliance.” For part 135 certificate holders, per 135.439(a)(2)(vi), “a list of current major alterations and repairs to each airframe, engine, propeller, appliance and rotor.”

1.    For part 121 records, a listing identifying each major alteration, including the item associated with the major alteration.

Indicates new/changed information

2.    For part 135 records, this listing includes all current major repairs in addition to all major alterations, as well as a listing of all major repairs and alterations to each rotor.

3.    A description or reference to the FAA-approved technical data used to make the major alteration.

NOTE:  The listing of all of the current major alterations refers to current summary status information and must not be confused with a major alteration record. A major alteration record 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 major alteration report, which must be submitted in accordance with 121.707.

Indicates new/changed information

3-3080    OTHER REQUIRED RECORDS AND REPORTS. Part 121 subpart V, as well as 135.415 and 135.417, outline the reports and records required for air carriers to keep. The FAA also uses these reports in its continuous review of air carrier maintenance operations as a direct means of assessing the design, performance, and effectiveness of all elements of the air carrier maintenance program, as well as the Continuing Analysis and Surveillance System (CASS).

A.    Air Carrier Airworthiness Release. Consistent with 14 CFR part 43, 43.5 and 43.7(e), and  121.709 and 135.443, it is clear that an air carrier may not operate its aircraft after the accomplishment of any maintenance, preventive maintenance, or alterations unless it has approved the aircraft for return to service.

Indicates new/changed information.
1)    An air carrier airworthiness release or a log entry is the air carrier’s version of an approval for return to service. An air carrier may accomplish an approval for return to service with a log entry instead of an airworthiness release. Other than form or format, there is no legal or technical difference between an air carrier airworthiness release and a log entry. This is consistent with the requirements of 43.5, 43.7(e), 43.9(b), 121.709, and 135.443.
2)    The regulatory requirement for an airworthiness release traces back to the requirement for a maintenance release that 14 CFR parts 40, 41, 42, and 46 introduced around 1955. The requirements of these four regulations differed slightly. An accompanying, interpretive regulation described the purpose of the maintenance release or appropriate log entry (that is made after the accomplishment of any air carrier maintenance) as a certification that the aircraft is airworthy. In other words, the work was done according to the Civil Air Regulations (CARs) and the air carrier’s instruction, and no known condition exists that would make the aircraft unairworthy. The interpretive regulation also stated that the form of the maintenance release was optional as long as it fulfilled the purpose of the rule.
Indicates new/changed information.
3)    In early 1964, the FAA amended the original 1955 regulations as part of the Continuous Airworthiness Program (CAP), introduced by Amendments 40-46, 41-11, 42-10, and 46-9. These amendments changed the term “maintenance release” to “airworthiness release” and retained the original term “appropriate entry in the aircraft log.” The amendments also standardized the four regulations with amended procedural and documentation requirements. In late 1964, the FAA consolidated and recodified the separate, regulatory parts, parts 40, 41, and 42, in the new parts 121 and 135. At the same time, the FAA recodified part 46 in a now rescinded 14 CFR part 127. The new 121.709 and 135.443 relating to the procedural and documentation certifications, pursuant to an airworthiness release or log entry have remained essentially unchanged since then.
4)    The four certifications are as follows:

    The work was performed in accordance with the requirements of the certificate holder’s manual;

    An authorized person inspected all items requiring inspection and determined that the work was satisfactorily completed;

    No known condition exists that would make the airplane unairworthy; and

    Concerning the work performed, the aircraft is in condition for safe operation.

5)    These four certifications are also consistent with statutory requirements for regulations that reflect operations with the highest possible degree of safety in the public interest. There is only one approval for return to service certification and documentation required by 121.709 or 135.443. However, the air carrier may accomplish its execution in one of two manners: an aircraft log entry or an airworthiness release form. If the air carrier uses an airworthiness release form, it is separate and distinct from the aircraft log. Also, the air carrier does not include it in the maintenance records. If a separate airworthiness release form is used, the regulations require that a copy of the airworthiness release is given to the pilot in command (PIC) and that a record of the airworthiness release is kept for at least 2 months.
6)    A review of standard practice shows that most air carriers do not use an airworthiness release form that is separate and distinct from the aircraft log. Most air carriers use a log entry labeled as an airworthiness release.
Indicates new/changed information.
7)    Consistent with the requirements of 43.5, 43.7(e), 121.701, 121.709, 135.65, and 135.443, any air carrier aircraft log entry documenting maintenance, preventive maintenance, or alterations accomplished under part 121 or 135.411(a)(2) always includes the four regulatory required certifications outlined above. Other than form or format, there is no legal or technical difference between an air carrier airworthiness release and a log entry.
8)    However, in a practical sense, instead of restating the four certifications each time a log entry or airworthiness release is made, most air carriers state in their manual that the signature in the aircraft log of an authorized, appropriately certificated individual authorizes an approval for return to service and constitutes the four regulatory certifications without restating the four certifications each time.
9)    Sections 121.709 and 135.443 clearly show that each time any maintenance, preventive maintenance, or alterations are accomplished on an air carrier aircraft, the air carrier must make four airworthiness release or log entry certifications before it can operate the aircraft. This is consistent with the approval for return to service provisions of 43.5, 43.7(e), 121.709, and 135.443.
Indicates new/changed information
10)    For the purposes of contract maintenance, it is important to note that 121.709(b)(3) and 135.443(b)(3) outline specific requirements for the persons authorized to sign an airworthiness release or log entry. As defined in 1.1, a person is an individual, firm, partnership, corporation, company, association, joint‑stock association, or government entity. Thus, a repair station, as a company, qualifies as a “person” defined in 1.1 and can prepare, or cause to be prepared, an airworthiness release or an appropriate entry in the aircraft log.
Indicates new/changed information. Indicates new/changed information
a)    Such a release or aircraft log entry is limited to the work the repair station is rated to perform, and actually performs, on an aircraft for certificate holders operating under parts 121 and 135. However, in preparing the airworthiness release or log entry, the person (or in this instance, the certificated part 145 repair station) must comply with the procedures set forth in the part 121 or 135 certificate holder’s manual for preparing the airworthiness release or log entry.
b)    Since there is no reference to “person” in 121.709(b) or 135.443(b), the “certificate holder” refers not to the repair station, but the part 121 or 135 certificate holder for whom the repair station is performing maintenance. This provision corresponds to the part 121 and 135 certificate holder’s duty under  121.367 and 135.425 to ensure that not only are competent personnel performing maintenance on their fleets, but that each aircraft released to service is airworthy.
11)    Finally, as a qualification requirement, each authorized individual must hold a Mechanic Certificate with Airframe and Powerplant (A&P) ratings or an appropriate Repairman Certificate. There is an exception for individuals employed by a certificated repair station (CRS) located outside the United States.

B.    Maintenance Log. Sections 121.563, 121.701, and 135.65 require an aircraft maintenance log. These sections 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 maintenance log of the aircraft. In addition, 121.563 and 135.65 require the PIC to ensure that it has entered all mechanical irregularities occurring during flight time in the maintenance log at the end of that particular flight time.

C.    Service Difficulty Reports (SDR). SDRs are required by 121.703 and 135.415, and part 145,  145.221. While the air carrier should use these reports to identify deficiencies within its air carrier maintenance program, they are also the primary means of gathering information for the FAA’s Service Difficulty Reporting System (SDRS).

D.    Mechanical Interruption Summary (MIS). These reports address the inability of the aircraft to arrive at its scheduled destination due to mechanical difficulties. Sections 121.705 and 135.417 require these documents. Analysis of the events in these reports is one of the air carrier’s most effective means of determining the effectiveness of the Continuous Airworthiness Maintenance Programs (CAMP).

E.    Alteration and Repair Reports. Regulations require a part 121 air carrier to prepare a report of each major alteration and each major repair made on its aircraft promptly on their completion, as outlined in  121.707. While the regulations require an air carrier to submit a report of a major alteration to the FAA principal maintenance inspector (PMI) assigned to the part 121 air carrier, they do not require the air carrier to submit a report of a major repair. But the air carrier must make it available for PMI inspection. This is one of the required reports listed under 14 CFR part 119, 119.59. In addition, 43.9(b) permits an air carrier to use a form other than FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance), for reporting a major alteration or repair it accomplished. The report, required by 121.707, should contain at least the identification of the altered airframe, aircraft engine, propeller, or appliance. The report should provide a means of positively identifying each altered item and its technical data approval basis.

NOTE:  These alteration and repair reports should not be confused with the current status listing of major alterations required under part 121 and major repairs and alterations required under part 135. Part 135 does not include a reporting requirement similar to 121.707.

3-3081    HISTORICAL AIRCRAFT MAINTENANCE RECORDS.

A.    FAA Monitoring. Through extensive and thorough research, the FAA has determined that a regulatory or statutory requirement for the preparation, storage, and retention of historical or source records to authenticate or support required air carrier aircraft maintenance records (particularly current air carrier status records) does not exist. However, under the Federal statutes, the FAA is responsible for the public trust, involving the safety of operations in air transportation and other air commerce. Aircraft maintenance records and current summary status information are the primary and most direct means the FAA and the operator have of determining the airworthiness status of aircraft. The act of willful falsification or alteration of these air carrier maintenance records is a criminal offense. The importance of accurate air carrier aircraft maintenance records cannot be overstated. In view of the severe penalties involved with falsification or alteration of required aircraft records, the FAA expects these current status information records to be complete as well as accurate.

B.    Recordkeeping. The FAA’s level of confidence in current status records produced by an air carrier’s maintenance recordkeeping system and monitored by that air carrier’s CASS is clearly higher than it would be for those records produced by no system or by a system that the FAA does not monitor. Unless there is evidence to the contrary, an aircraft maintenance record, particularly a current status record, produced by an air carrier’s maintenance recordkeeping system should be acceptable by itself (i.e., without historical or source records). The FAA cannot require or force an aircraft operator to produce or keep records that a regulation or statute does not require. For its aircraft maintenance recordkeeping system, the air carrier must develop and use detailed documentation and source requirements and procedures for administrative handling of aircraft components and parts. The air carrier must clearly identify these requirements and procedures in its manual. These source and documentation requirements may include, but are not limited to, documentation of AD compliance, life-limited part current status information, description of maintenance performed, and appropriate certification of new and repaired parts.

C.    Essential Information. To ensure that the air carrier satisfies these requirements, it should enter the following essential information into its recordkeeping system:

1)    Documentation and source information required for air carriers to retain as necessary to support the CASS.
2)    Documentation that may be necessary to integrate the part into the air carrier’s CAMP.
3)    Documentation required to support future maintenance on the affected parts, such as detailed shop records or FAA-approved technical data.

D.    Additional Records. An air carrier may wish to archive certain source documentation records, which the air carrier used to introduce parts into their system. These may be such records as the manufacturer’s invoice for new parts, export certificates of airworthiness, documentation of a major repair or alteration, or other similar information that the air carrier may consider useful in the future.

3-3082    REFERENCES, FORMS, AND JOB AIDS.

A.    References (current editions):

    Title 14 CFR Parts 43, 119 ( 119.59), 121 (Subparts G, L, and V), and 135 (Subparts B and J).

    FAA Order 2150.3, FAA Compliance and Enforcement Program.

    Advisory Circular (AC) 120-16, Air Carrier Maintenance Programs.

    AC 20-109, Service Difficulty Program (General Aviation).

    Title 18 of the United States Code (18 U.S.C.) 1001, Statements or Entries Generally.

    Title 18 U.S.C. 3571, Sentence of Fine.

    Title 49 of the United States Code (49 U.S.C.) 46310, Reporting and Recordkeeping Violations.

    Service Difficulty Reporting Site (http://av-info.faa.gov/sdrx/).

B.    Forms. None.

C.    Job Aids. None.

3-3083    PROCEDURES.

A.    Overview. During initial certification, regulations require an air carrier to establish an aircraft maintenance recordkeeping system. The air carrier should base its system on system safety principles. It must also develop a section in its manual that provides a description of the system as well as detailed instructions for the use of that recordkeeping system. The recordkeeping system may be electronic. The PMI should ensure that the air carrier’s manual contains a description or overview of the recordkeeping system. In addition, the air carrier’s initial compliance statement should clearly identify the detailed procedures contained in the air carrier manual to use for the generation, storage, retention, and retrieval of aircraft maintenance records. The air carrier manual maintenance recordkeeping procedures should be written in a consistent format and describe clear, concise, and accurate procedures. Ambiguities are not acceptable. After certification, the assigned FAA personnel will conduct surveillance of the air carrier’s aircraft maintenance recordkeeping system on a routine basis to ensure that it is producing and maintaining accurate records, and that they are retrievable in accordance with the system.

B.    Record Location and Responsible Persons. Consistent with 119.59, verify that the air carrier has procedures in its manual for making required records available to the Administrator at its principal base of operations. The certificate holder is required under 49 U.S.C. to keep a current listing that includes the location of the records and those persons who are responsible for each record, document, and report. Each employee of, or person used by, the air carrier who is responsible for maintaining the air carrier’s maintenance records must make those records available to the Administrator.

C.    System Evaluation. Consistent with the system safety principles, evaluate the aircraft maintenance reporting and recordkeeping system described in the air carrier’s manual. The reporting and recordkeeping system must include the procedures, information, and instructions necessary to allow the personnel concerned to perform their duties and responsibilities with a high degree of safety. The manual should identify the individual with overall authority and responsibility for the recordkeeping system as well as the individual who has direct responsibility for each system function. The general regulatory requirements for an air carrier maintenance recordkeeping system are that the system must be suitable, and that the system must provide for the preservation and retrieval of information in a manner acceptable to the Administrator. Additionally, with regard to maintenance work performed, the system must include procedures that ensure that maintenance work records at least include the following:

1)    A description (or reference to data acceptable to the Administrator) of the work performed.
2)    The name of the person performing the work if the person is from outside the organization of the air carrier.
3)    The name or other positive identification of the individual approving the work. The system should address both types of aircraft maintenance records (i.e., records to show that all requirements for the issuance of an airworthiness release have been met and the record of current summary status information). The current summary status information should contain, at least, that information described in paragraph 3-3079.

D.    Procedures Review. While reviewing the air carrier’s manual, keep in mind that although each air carrier’s maintenance recordkeeping system must meet the same requirements, the system and procedures developed and used by each individual air carrier to meet those requirements may be quite different from one another. The system may be electronic.

1)    Also, keep in mind that the recordkeeping procedures must address the generation, storage, retention, and retrieval of records of all maintenance and alterations, whether air carrier personnel or authorized persons outside of the air carrier’s organization accomplish the maintenance or alteration.
2)    Consistent with 43.9(b), 121.1(b), and 135.1(a)(2), records of maintenance, preventive maintenance, or alterations accomplished on an air carrier aircraft by a maintenance provider are air carrier records. They are not maintenance provider records, even if a CRS accomplished the work. The procedures must clearly identify the particular individual(s), by job title or description, who has the authority and responsibility for each particular function of the recordkeeping system.
3)    In addition, the air carrier’s maintenance recordkeeping procedures must not be contrary to the regulations, nor should the manual contain procedures that allow activity that results in de facto exemptions from sections of the CFR.
4)    An air carrier maintenance recordkeeping system must include, at least, methods and detailed procedures for the generation, storage, retention, and retrieval of:
a)    Records of scheduled, unscheduled, and shop maintenance.
b)    Records of engine and/or propeller or rotor shop maintenance.
c)    Records of the maintenance log entry or airworthiness release described in 121.709 and 135.443.
d)    If the air carrier uses an airworthiness release form, all records necessary to show that all requirements for the issuance of the airworthiness release form described in 121.709 and 135.443 have been met.
e)    The SDRs.
f)    The MIS reports.
g)    The report of each major alteration and repair of each airframe, aircraft engine, propeller, or appliance of an aircraft operated by the air carrier.
h)    The current summary status information, describing;

1.    The total time in service of the airframe, each engine, each propeller, and for part 135 air carrier, each rotor.

2.    The current status of each life-limited part of each airframe, engine, propeller, appliance, and for part 135 air carrier, each rotor.

3.    The TSO of each item requiring overhaul.

4.    The current inspection status of the aircraft.

5.    The current status of each applicable AD.

6.    A list of the current major alterations to each airframe, aircraft engine, propeller, or appliance.

7.    For part 135 air carriers, a list of the current major alterations and major repairs to each airframe, engine, propeller, rotor, or appliance.

E.    Analyze the Findings.

1)    Follow SAS guidance for Module 5.
Indicates new/changed information
2)    Follow Volume 14, Chapter 1, Section 2 to address all alleged, suspected, or identified instances of noncompliance.

3-3084    TASK OUTCOMES. Follow SAS guidance for Modules 4 and 5.

3-3085    FUTURE ACTIVITIES. Follow SAS guidance.

RESERVED. Paragraphs 3-3086 through 3-3100.