VOLUME 6 SURVEILLANCE
Chapter 2 PARTS
91 SUBPART K INSPECTIONS
Section 35 Safety Assurance System: Inspect Section
135.411(a)(1) (Nine or Less) Certificate Holder’s Maintenance Records
6-951 REPORTING SYSTEM(S). Use Safety Assurance System (SAS) automation and the associated Data Collection Tools (DCT).
6-952 OBJECTIVE. This section provides guidance for inspecting a certificate holder’s aircraft maintenance records under Title 14 of the Code of Federal Regulations (14 CFR) part
The term “certificate holder” within this section applies to part
carriers or operators only.
NOTE: If the certificate holder chooses to maintain its aircraft under §
Volume 6, Chapter 2, Section 36,
Safety Assurance System: Inspect Parts
(10 or More) Operator’s Maintenance Records.
6-953 GENERAL. Aircraft maintenance records include any record documenting the performance of work on an aircraft. Principal inspectors (PI) and aviation
safety inspectors (ASI) must inspect a certificate holder’s aircraft maintenance records to ensure that the records meet the requirements of 14 CFR.
6-954 PREREQUISITES AND COORDINATION REQUIREMENTS.
• Knowledge of the regulatory requirements of 14 CFR parts
• Successful completion of appropriate Airworthiness Indoctrination course(s); and
• Familiarity with the type of operation being inspected.
1) This task requires coordination between the PIs, and coordination may be required with the Aviation Data Systems Branch.
2) If a geographic inspector is performing this inspection, coordination with the certificate-holding district office (CHDO) must be maintained.
6-955 REFERENCES, FORMS, AND JOB AIDS.
A. References. Title 14 CFR Parts
B. Forms. None.
C. Job Aids. JTA: 2.3.108.
A. Schedule Inspection. Follow Volume 10 SAS guidance to schedule the inspection, based on risk.
B. Review Office File.
6-957 SURVEILLANCE CRITERIA. During surveillance of a certificate holder’s aircraft maintenance records, the
PIs and ASIs must determine that all of the work was based on instructions, procedures, or information that has been approved previously or found acceptable to the Administrator. Such data could be in the form of:
• Manufacturer’s manuals,
• Service Bulletins (SB),
• Service Letters (SL),
• Service Instructions (SI),
• Data included in the certificate holder’s approved inspection and/or maintenance programs,
• Approved Engineering Orders (EO) or Engineering Change Authorizations (EA),
• Airworthiness Directives (AD), and
• Other accepted documents.
6-958 INSPECTION OF CERTIFICATE HOLDER’S RECORDKEEPING SYSTEM. Ensure that the certificate
holder’s recordkeeping system is adaptable to making timely corrections to address
recordkeeping system discrepancies. Recordkeeping discrepancies could indicate:
• Maintenance performance not in accordance with part
• Undocumented maintenance,
• A deficient inspection program, and
• Systemic certificate holder deficiencies.
6-959 IDENTIFYING PERSONNEL. Certificate holders operating under an inspection program per part
§ 91.409 or §
use their air carrier/operating certificate number for return
to service. Therefore, the name and certificate numbers of the person performing the work and the person approving the work must be provided as required by part
6-960 RECORDS OF MAINTENANCE, PREVENTIVE MAINTENANCE, ALTERATIONS, AND
INSPECTIONS. Ensure that the certificate holder maintains records of maintenance,
preventive maintenance, and alterations; and records of the 100-hour, annual,
progressive, and other required or approved inspections, as appropriate, for
each aircraft (including the airframe) and each engine, propeller, rotor, and
appliance of an aircraft. The records must include:
• A description (or reference to data acceptable to the Administrator) of the work performed;
• The date of completion of the work performed; and
• The signature and certificate number of the person approving the aircraft for return to service.
NOTE: The records must be retained until the work is repeated or superseded by other work, or for 1 year after the work is performed.
6-961 TOTAL TIME-IN-SERVICE RECORDS (§
Ensure that the certificate holder maintains records
for total time in service for the airframe, engine(s), propeller(s), and rotor(s),
as applicable. Total time in service continues for the life of the airframe,
propeller, and rotor. However, total time for the engine is variable. If an
engine is overhauled, time since overhaul (TSO) can be tracked separately, but
the total time of the engine continues and must still be tracked. If an engine
is rebuilt and certified to Zero Time, the total time in service of the engine
will return to zero. Certifying to Zero Time is only possible by the engine
manufacturer or by an agency approved by the manufacturer per §
6-962 LIFE-LIMITED PARTS (§
Ensure that the certificate holder maintains records
of the current status of life-limited parts for each airframe, engine, propeller,
rotor, and appliance. This record indicates the present accumulated time in
service of each life-limited part. The certificate holder must be able to verify
the accumulated time in service of all life-limited items. This is done by providing
records for the item showing each segment of its operation in service since
its manufacture. This may be accomplished by one of the following:
• A record audit trail providing a record of the time in service of the item, or
• A time audit trail providing a record of continuous time in service.
6-963 RECORDS OF OVERHAUL (§
A certificate holder must maintain overhaul records
of any item required to be overhauled by the certificate holder’s inspection
or maintenance program. Ensure that the records include the time since last
overhaul (hours, cycles, or calendar date). These records must be retained and
transferred with the aircraft at the time the aircraft is sold.
6-964 INSPECTION STATUS (§
Inspection status defines the work that has been and is scheduled to be performed in accordance with the inspection or maintenance
program. Ensure that the certificate holder’s inspection status records show the
current inspection status of the aircraft, including the time (hours, cycles,
or calendar time) since the last inspection required by the inspection program
under which the aircraft and its appliances are maintained.
6-965 AD STATUS (§
The certificate holder must maintain the current status
of all applicable ADs. Ensure the certificate holder documents, the method of
compliance, the AD number, and revision date for each AD. If the AD involves
recurring action, ensure that the certificate holder documents the time and
date when the next action is required. Some acceptable sources of procedures for compliance with ADs are:
• Specific instructions provided in the AD,
• Approved EO or EA, and
• Alternative methods of compliance (AMOC).
6-966 MAJOR ALTERATIONS (§
Ensure that the certificate holder retains copies of the forms prescribed by §
each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
6-967 REPAIR STATION RECORDS OF WORK PERFORMED ON CERTIFICATE HOLDER’S AIRCRAFT (Part
Repair stations are required to retain records of work for
at least 2 years from the date the article was approved for return to service.
Some certificate holders have reported that maintenance records are not always
available from repair stations beyond the 2-year retention period. To avoid
this situation, certificate holders should be advised to require a copy of the
work documentation from the repair station at the time that the work is performed. The certificate holder is always responsible for obtaining and
retaining these records required by the Administrator.
6-968 INSPECT RECORD SYSTEM. Ensure that the certificate holder’s records are being maintained in accordance
with a recordkeeping system. Ensure that the certificate holder’s recordkeeping
system is adequate and can make timely corrections to systemic recordkeeping
errors. In addition, review the certificate holder’s recordkeeping practices
for potential factors that may indicate improper recordkeeping practices, such
as long periods between maintenance record entries and maintenance discrepancies not documented per the certificate holder’s
6-969 TASK OUTCOMES.
A. Complete the Task. Follow Volume 10 SAS guidance for Module 4 (Chapter 5) for Data Collection and Data Reporting.
B. Conduct Debriefing. Brief the certificate holder on the inspection
results. Discuss all deficiencies, certificate holder corrective actions, and
Federal Aviation Administration (FAA) actions, if required. The ASI can find
instructions for conducting briefings in
Volume 1, Chapter 3, Section 1.
6-970 FUTURE ACTIVITIES. Follow Volume 10 guidance to plan future risk-based surveillance in SAS.
RESERVED. Paragraphs 6-971 through 6-985.