8900.1 CHG 596



Indicates new/changed information.

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 135, § 135.411(a)(1). The term “certificate holder” within this section applies to part 135 air carriers or operators only.

NOTE:  If the certificate holder chooses to maintain its aircraft under § 135.411(a)(2), follow Volume 6, Chapter 2, Section 36, Safety Assurance System: Inspect Parts 91K and 121/135 (10 or More) Operator’s Maintenance Records.

Indicates new/changed information.

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.

Indicates new/changed information.


A.    Prerequisites.

Indicates new/changed information.

    Knowledge of the regulatory requirements of 14 CFR parts 43, 91, and 135;

    Successful completion of appropriate Airworthiness Indoctrination course(s); and

    Familiarity with the type of operation being inspected.

B.    Coordination.

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.
Indicates new/changed information.


A.    References. Title 14 CFR Parts 39, 43, 65, 91, 135, and 145.

B.    Forms. None.

C.    Job Aids. JTA: 2.3.108.

Indicates new/changed information.

6-956    PROCEDURES.

A.    Schedule Inspection. Follow Volume 10 SAS guidance to schedule the inspection, based on risk.

B.    Review Office File.

Indicates new/changed information. Indicates new/changed information.

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),

Indicates new/changed information.

    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.

Indicates new/changed information.

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 43,

    Undocumented maintenance,

Indicates new/changed information.

    A deficient inspection program, and

    Systemic certificate holder deficiencies.

Indicates new/changed information.

6-959    IDENTIFYING PERSONNEL. Certificate holders operating under an inspection program per part 91, § 91.409 or § 135.419 cannot 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 43, § 43.11.

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:

Indicates new/changed information.

    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 (§ 91.417(a)(2)(i)). 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 § 91.421.

6-962    LIFE-LIMITED PARTS (§ 91.417(a)(2)(ii)). 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.

Indicates new/changed information.

6-963    RECORDS OF OVERHAUL (§ 91.417(a)(2)(iii)). 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.

Indicates new/changed information.

6-964    INSPECTION STATUS (§ 91.417(a)(2)(iv)). 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 (§ 91.417(a)(2)(v)). 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).

Indicates new/changed information.

6-966    MAJOR ALTERATIONS (§ 91.417(a)(2)(vi)). Ensure that the certificate holder retains copies of the forms prescribed by § 43.9(d) for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

Indicates new/changed information.

6-967    REPAIR STATION RECORDS OF WORK PERFORMED ON CERTIFICATE HOLDER’S AIRCRAFT (Part 145, § 145.219). 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.

Indicates new/changed information. Indicates new/changed information.

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 recordkeeping system.

Indicates new/changed information.


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.