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INTRODUCTION: This course provides a review of aircraft maintenance documentation requirements. It emphasizes the importunateness of proper documentation. It identifies common documentation problems that can lead to maintenance errors. Poor maintenance documentation can be a precursor to aircraft incidents or accidents. It can also lead to FAA enforcement actions.
Maintenance-related accidents and incidents are on a downward trend. However, maintenance-related accidents result in a higher likelihood of injury.
Mechanic violations fall into very consistent categories. Failure to perform maintenance and inspections in accordance with approved methods (43.13, 43.15) and failure to document such actions prior to return to service (43.5, 43.9) accounted for 90% of all maintenance violations
Common findings are improper documentation of maintenance. No documentation. It may be obvious that some maintenance action has been performed. You can not determine what action was done, or by whom, so the work has to be completed again. Inadequate description. You can not tell exactly what was done or if it was done correctly. Using the wrong reference. An example might be using the system description section of the M/M for a component replacement, or citing the wrong ATA chapter.
A company mechanic had performed a 100-hour inspection about 4.3 hours prior to the accident flight. During the inspection, he had loosened the self locking nut on the belt actuator housing assembly and had rotated the down-limit stop screw upward until the screw bottomed out in the actuator housing in the full up position. This maintenance action was not required as part of the 100 hour inspection.
Had this extra maintenance action be documented, it is reasonable to say this accident would have probably been prevented.
This statement was taken from the NTSB Factual Report.
This was a hard lesson in why proper maintenance documentation particularly shift turnover procedures are so important. On Sept. 11, 1999 On that day Continental Express Flight 2574 an EMB 120 aircraft, went down. In flight the left horizontal stabilizer leading edge bent down and then separated from the aircraft. The aircraft become uncontrollable. 14 passengers and the flight crew were killed near Eagle Lake Texas.
This is how the horizontal stabilizer was found. Notice anything missing? The entire leading edge is missing from the left side of the aircraft’s horizontal stabilizer.
This statement was taken from the NTSB Factual Report. “ Departures from approved procedures included failures to solicit and give proper shift / turnover reports, failures to use maintenance work cards as approved, failures to complete required maintenance/inspection shift / turnover forms, and a breach in integrity of the quality control system.” Poor shift turnover policies and procedures were a factor in this accident.
Let’s start by taking a look at some of the regulations. Title 14 of the Code of Federal Regulations to be exact, but let’s just call them by their common names Parts 43, 91 135, 121, 145. Part 43 is where you find the basic rules for Maintenance, Preventive Maintenance, and Alterations. Part 91 is where you find the basic operating rules for aircraft owners/ operators regarding Maintenance, Preventive Maintenance, and Alterations
Part 135 Subpart J. is where we find the rules for Maintenance, Preventive Maintenance, and Alterations that must be followed by 135 operators. Did you know that if an aircraft is listed on the Operations Specifications for a 135 air carrier, the 135 maintenance rules apply no matter who might be operating the aircraft. If the owner uses his turbo prop to take the family on vacation, he must follow the 135 operators maintenance procedures for maintenance documentation. That includes the Minimum Equipment List (MEL). Part 121 Subpart L is where we find the rules for Maintenance, Preventive Maintenance, and Alterations that must be followed by part 121 air carriers.
Part 145. is where we find the rules for Maintenance, Preventive Maintenance, and Alterations that must be followed by 145 repair stations.
Here is what is required by Part 43. Point out the requirements each paragraph of the slide. Description, Date, Signature & Certificate number and kind of certificate held i.e. A & or P IA or Pilot for items allowed under preventive maintenance. That’s in appendix A to Part 43 if you like to look it up.
Part 91 restates the same requirements we saw in Part 43. To put is in the simplest of term. Description, Date, Signature & Certificate information. This is not all that is required by Part 91.417 as far as aircraft records. Since Part 91 is an operating rule it applies to the Owner/Operator rather than maintenance personnel. With that being said all AMTs need to be aware of the requirements.
Sec 91.417 also has other requirements for aircraft records such as the total time in service, current status of life-limited parts and time since last overhaul of item required to be overhauled.
Sec 91.417 also includes t he requirement to document the inspection status of the aircraft, including the time since the last inspection. The current status of applicable airworthiness directives (AD) or service directive including, the method of compliance, the AD directive number and revision date. If the AD involves recurring action, the time and date when the next action is required. Safety Directives? What does that mean? This is new! As of April 2, 2010 Sec 91.417 was amended to include safety directives issued on Special Light Sport Aircraft by the manufactures of the aircraft. The aircraft record must also include copies of the form 337 Sec. 43.9(a) for each major alteration. If a fuel tank is installed within the passenger compartment or a baggage compartment, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner or operator.
The records specified in paragraph (a)(1) must be kept until the work is superseded or for one year. For section (a)(2) it’s for the life of the aircraft. The owner or operator shall make all maintenance records required to be kept by this section available for inspection by the Administrator or any authorized representative of the National Transportation Safety Board (NTSB).or any law enforcement officer.
Part 135 manuals must state the operator’s method to meet the requirements. They must explain in their manual just how maintenance actions are to be handled. What company form must be completed etc?
Part 135.427 states the same basic requirements. Description, Date, Signature & Certificate information.
Part 145.219 states the same basic requirements. Description, Date, Signature & Certificate information. The repair station’s manual will explain the specific requirements
Tell the story so that some one in the future reading your entry know what you did. Then read the slides bullets. A maintenance entry that describes what was done and gives a specific maintenance manual reference leaves little doubt as to what was done, and how it was done.
It is not necessary to add the phrase “and is approved for return to service” your signature says it for you.
Lets take a look at Ads. Each AD issued is an actual amendment to FAR Part 39.
An AD is issued when it is found that an unsafe condition exist in a product The condition is likely to exist or develop in other products of the same design
The Owner/Operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with ADs The Owner/Operator is responsible for ensuring that properly certificated person perform the work.
Maintenance personnel have the responsibility of compliance at the time they are performing inspections to determine all airworthiness requirements are met.
The owner must keep a record showing the current status of applicable ADs. This record must include the following: The current status of ADs applicable to the aircraft, including the AD number and revision date, The method of compliance, and The time‑in‑service, or the cycles, and/or the date when the next action is required for a recurring AD. An acceptable method of compliance should include a reference to either a specific portion of the AD or a manufacturer’s service bulletin, if the bulletin is referenced in the AD. The document that contains the current status of ADs/method of compliance may be the same as the record of AD accomplishment.
Here is a typical AD compliance record that could be used for a general aviation aircraft, or a large transport aircraft. The requirements are the same.
Note: Each line will come in one at time and fade. Talk about each line and type of entry as they appear.
The description should be in sufficient detail to permit a person unfamiliar with the work to understand what was done, and the methods and procedures used. When the aircraft leaves the hangar, your entry must speak for you. When the flight crew reviews the log book your entry is usually all they have to go by. Give them confidence that the maintenance task you performed was done correctly.
Another vital form of maintenance documentation is a shift/ turnover records. Shift turn of is the time to transfer of critical information between work groups or shifts. It needs to be as detailed as necessary, depending on the tasks involved. Sharing of information by the people doing the task. Do you think that aircraft maintenance documentation has never caused an accident?
Why is Shift/Task Turnover Important? Data show that poor shift/task turnover is a common contributing factor to events. Challenges related to shift turnover include: 1. Shift Turn over requires a high level of teamwork and good communication skills. 2. The lack of structured and standardized policies and procedures. 3. Using a location that is conducive for discussion and planning. Such as a high noise area
4. Finishing workers are tired and want to depart facility. 5. Lack of adequate shift overlap to provide time to give one-on-one briefings between the team leaving and the team coming on. 6. Absence of a process to ensure departing personnel have documented all tasks accomplished or started. 7. Minimal training on procedures for shift/task turnover High-quality shift/task turnover procedures enable improvement in practice and improve safety and accountability to all involved in the work. CHECK wording in last paragraph
How do you implement a Shift/Turnover process? Formalize policy and procedures that make the turnover as important as the work. Communicate policy and procedures to all personnel. Consider technology enhancements that improve the transfer of visual information (e.g., photos, graphics, movies).
Provide a time and place for formal shift/task turnover. Dedicate a location for shift turnover meetings that is clean, comfortable, and relatively free of distractions. Access to computers and data sources should be provided, if appropriate. Include a dedicated time for a proper shift turnover within the regular work hours. Carry out the task turnover at the aircraft where the task is being accomplished. Ensure the quality of shift/task turnover Information. Standardize written communications. Ensure consistent level of detail in turnover documentation. Deliver initial and recurrent training on how to conduct a good shift/task turnover. Emphasize the criticality of shift/task turnover and impact on continuing safety. Emphasize use of checklists, shift status reports, and applicable shift/task turnover documents. Define acceptable communication practices. Describe how to conduct and participate in turnover meetings.
To summarize, the basic requirements for aircraft maintenance documentations are the same. Whether it is a Cessna 150 or a Airbus 380 The method of meeting those requirements may be different depending on the type of operation.
It may be a simple airframe, engine, propeller log book, or an air carrier’s maintenance record system. A description of the work performed, date the work was performed and the signature with certificate number and type are always required.
Let’s review. No documentation. The situation may be obvious that maintenance has been performed. You can not determine what maintenance action may have been done, or by whom, so the work has to be redone. Inadequate description. You can not tell what was done or if it was done correctly. Using the wrong reference. Such as using the system description section of the M/M for a component replacement or citing the wrong ATA chapter or maybe using an out of date manual. Shift turnovers should always be done by the people doing the work. Written description of what was accomplished, clear stop and starting points.
Follow the rules. Follow company procedures General Maintenance Manual (GMM). Use the Maintenance Personal Minimums Checklist !
Review the items on the Checklist. Before the Task KEEP THIS IN YOUR TOOLBOX!!
Review the items on the Checklist. After the Task
Contact your FAASTeam Program Manager or FAASTeam Representative for more information. Remember to Be Smart and Follow procedures.
Visit the FAASTeam Maintenance Hangar on our website FAASafety.gov ADD qms feed back link
Aircraft Maintenance Documentation
Federal AviationAdministrationAircraft MaintenanceDocumentation
Federal AviationAdministration2Aircraft Maintenance DocumentationIntroductionThis course provides a review of aircraftmaintenance documentation requirements.It emphasizes the importance of properdocumentation.It identifies common documentation problemsthat can lead to maintenance errors.
Federal AviationAdministration3Aircraft Maintenance DocumentationAccident Data
Federal AviationAdministration4Aircraft Maintenance DocumentationRegulation Cited
Federal AviationAdministration5Aircraft Maintenance DocumentationCommon Findings• No documentation.• Inadequate description of work performed.• Using the wrong reference.
Federal AviationAdministration6Aircraft Maintenance DocumentationMaintenance Related Accident3/24/2005 Prescott, AZ Robinson R22The helicopters main rotor drive belts broke on thebase leg and the helicopter rolled over during thesubsequent autorotation and landing.Upon exiting the helicopter, the instructor observedthat the V-belts were shredded.
Federal AviationAdministration7Aircraft Maintenance DocumentationMaintenance Related AccidentA company mechanic had performed a 100-hourinspection about 4.3 hours prior to the accidentflight.During the inspection, he had loosened the selflocking nut and stop screw on the belt actuatorhousing assembly.
Federal AviationAdministration8Aircraft Maintenance DocumentationMaintenance Related AccidentThe mechanic forgot to reposition the stop screw andtighten the nut. This action resulted in the main rotordrive V-belts becoming excessively loose. The beltsexited their seated position on the lower pulleysheave and were severed.
Federal AviationAdministration9Aircraft Maintenance DocumentationNTSB FindingProbable CauseThe company mechanics impropermaintenance actions, which resulted in thetotal failure of the main rotor drive belt system
Federal AviationAdministration10Aircraft Maintenance DocumentationSept. 11, 1999 near Eagle Lake Texas.Continental Express Flight 2574 an EMB 120In flight the left horizontal stabilizer leading edge bent downand then separated from the aircraft14 passengers and crew killed near Eagle Lake Texas.
Federal AviationAdministration11Aircraft Maintenance Documentation
Federal AviationAdministration12Aircraft Maintenance DocumentationNTSB FindingDepartures from approved procedures included failuresto solicit and give proper shift / turnover reports, failuresto use maintenance work cards as approved, failures tocomplete required maintenance/inspection shift /turnover forms, and a breach in integrity of the qualitycontrol system.
Federal AviationAdministration13Aircraft Maintenance DocumentationThe Regulations (Title 14 CFR)• Part 43 MAINTENANCE, PREVENTIVEMAINTENANCE, REBUILDING, AND ALTERATION• Part 91 GENERAL OPERATING AND FLIGHT RULESSubpart E--Maintenance, Preventive Maintenance, andAlterations
Federal AviationAdministration14Aircraft Maintenance Documentation• Part 135 OPERATING REQUIREMENTS:COMMUTER AND ON-DEMAND OPERATIONSSubpart J--Maintenance, Preventive Maintenance, andAlterations• Part 121 OPERATING REQUIREMENTS: DOMESTIC,FLAG, AND SUPPLEMENTAL OPERATIONS SubpartL--Maintenance, Preventive Maintenance, andAlterationsThe Regulations
Federal AviationAdministration15Aircraft Maintenance Documentation• Part 145 Repair StationsThe Regulations
Federal AviationAdministration16Aircraft Maintenance DocumentationThe RegulationsSec. 43.9(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of thissection, each person who maintains, performs preventive maintenance,rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, orcomponent part shall make an entry in the maintenance record of thatequipment containing the following information:(1) A description (or reference to data acceptable to the Administrator) of the workperformed.(2) The date of completion of the work performed.(3) The name of the person performing the work if other than the personspecified in paragraph (a)(4) of this section.(4) If the work performed on the aircraft, airframe, aircraft engine, propeller,appliance, or component part has been performed satisfactorily, the signature,certificate number, and kind of certificate held by the person approving thework. The signature constitutes the approval for return to service only for thework performed.
Federal AviationAdministration17Aircraft Maintenance DocumentationThe RegulationsSec. 91.417 (a) (1) Maintenance RecordsThe records must include--(i) A description (or reference to data acceptable to theAdministrator) of the work performed; and(ii) The date of completion of the work performed; and(iii) The signature, and certificate number of the personapproving the aircraft for return to service.
Federal AviationAdministration18Aircraft Maintenance DocumentationThe RegulationsSec 91.417 (a) (2) Records containing the following information:(i) The total time in service of the airframe, each engine, eachpropeller, and each rotor.(ii) The current status of life-limited parts of each airframe, engine,propeller, rotor, and appliance.(iii) The time since last overhaul of all items installed on the aircraftwhich are required to be overhauled on a specified time basis.
Federal AviationAdministration19Aircraft Maintenance DocumentationThe Regulations(iv) The current inspection status of the aircraft, including the timesince the last inspection required by the inspection program underwhich the aircraft and its appliances are maintained.(v) The current status of applicable airworthiness directives (AD)and safety directives including, the method of compliance, the ADor safety directive number and revision date. If the AD or safetydirective involves recurring action, the time and date when the nextaction is required.vi) Copies of the forms prescribed by Sec. 43.9(a) for each majoralteration to the airframe ,engines, rotors, propellers, andappliances.
Federal AviationAdministration20Aircraft Maintenance DocumentationRecord retention• The owner or operator shall retain the following records for theperiods prescribed:• The records specified in paragraph (a)(1) of this section shall beretained until the work is repeated or superseded by other work orfor 1 year after the work is performed.• The records specified in paragraph (a)(2) of this section shall beretained and transferred with the aircraft at the time the aircraft issold.
Federal AviationAdministration21Aircraft Maintenance DocumentationThe Regulation• Sec. 135.427 Manual requirements• c) Each certificate holder shall put in its manual asuitable system (which may include a coded system)that provides for the retention of the followinginformation--
Federal AviationAdministration22Aircraft Maintenance Documentation(1) A description (or reference to data acceptable to theAdministrator) of the work performed;(2) The name of the person performing the work if thework is performed by a person outside the organizationof the certificate holder; and(3) The name or other positive identification of theindividual approving the work.•135.427 Manual requirements
Federal AviationAdministration23Aircraft Maintenance DocumentationThe RegulationsSec.145.219 Recordkeeping.(1) A description (or reference to data acceptable to the Administrator) ofwork performed.(2) The date of completion of the work performed.(3) The name of the person performing the work if other than the personspecified in paragraph (a)(4) of this section.(4) If the work performed on the aircraft, airframe, aircraft engine,propeller, appliance, or component part has been performedsatisfactorily, the signature, certificate number, and kind of certificateheld by the person approving the work. The signature constitutes theapproval for return to service only for the work performed.
Federal AviationAdministration24Aircraft Maintenance DocumentationINCORPORATION BY REFERENCE• You don’t have to write a book.• The regulations permit reference to technical data inlieu of making a long step by step detailed entry• Common references include maintenance manuals,service letters, bulletins, work orders, advisory circulars(AC43.13-1B), and others• Major alterations may reference STC’s• Reference documents must be retained
Federal AviationAdministration25Aircraft Maintenance DocumentationIf the work performed on the aircraft, airframe, aircraftengine, propeller, appliance, or component part has beenperformed satisfactorily, the signature, certificate number,and kind of certificate held by the person approving thework.The signature constitutes the approval for return to serviceonly for the work performed.
Federal AviationAdministration26Aircraft Maintenance DocumentationAirworthiness DirectiveFAR Part 39
Federal AviationAdministration27Aircraft Maintenance DocumentationAIRWORTHINESS DIRECTIVESAn unsafe condition exist in a product.The condition is likely to exist or develop in other productsof the same design.
Federal AviationAdministration28Aircraft Maintenance DocumentationRESPONSIBILITYThe Owner/Operator is primarily responsible formaintaining the aircraft in an airworthy condition,including compliance with ADsThe Owner/Operator is responsible for ensuring thatproperly certificated persons perform the work.
Federal AviationAdministration29Aircraft Maintenance DocumentationRESPONSIBILITYMaintenance personnel have the responsibility ofcompliance at the time they are performing inspectionsto determine all airworthiness requirements are met.
Federal AviationAdministration30Aircraft Maintenance DocumentationRECORDSThe owner must keep a record showing the currentstatus of applicable ADs.This record must include the following:The current status of ADs applicable to the aircraft,including the AD number and revision date, themethod of compliance, and the time in service, or the‑ ‑cycles, and/or the date when the next action isrequired for a recurring AD.
Federal AviationAdministration31Aircraft Maintenance Documentation
Federal AviationAdministration32Aircraft Maintenance DocumentationSample Logbook EntryN12345 Tach/Hobbs: ____________ ACTT: ____________Enter the type of inspection(s) performed:Enter accomplishment of all A.D.’s including the number, revision date, method of compliance,and if recurring, the next time/date it is due.Enter replacement or inspection of any component part with Airworthiness Limitations(include part, serial number, and total time in service for that component).Enter removal and installation of any serialized component replacement parts(include part, serial number, and total time in service for that component).Enter description of any other general maintenance performed.I certify that this aircraft was inspected in accordance with a (insert type) inspection and wasdetermined to be in an airworthy condition. All work was accomplished in accordancewith current Federal Aviation Regulations and manufacturer’s maintenance instructions.Details of work performed can be found on XYZ Company work order _______.______________________ __________________________ ____________Signature Certificate # Date
Federal AviationAdministration33Aircraft Maintenance DocumentationDESCRIPTION OF WORK PERFORMEDThe description should be in sufficient detail to permita person unfamiliar with the work, to understand whatwas done, and the methods and procedures used.
Federal AviationAdministration34Aircraft Maintenance DocumentationShift /TurnoverThe transfer of critical information between work groups orshiftsIt needs to be as detailed as necessary, depending on thetasks involvedSharing of information by the people doing the task
Federal AviationAdministration35Aircraft Maintenance DocumentationWhy is Shift/Task Turnover ImportantData show that poor shift/task turnover is a commoncontributing factor to events.Challenges related to shift turnover include:1. A high demand for teamwork and communication skills2. Lack of structured and standardized policies andprocedures3. Using a location that is not conducive for discussion andplanning
Federal AviationAdministration36Aircraft Maintenance DocumentationWhy is Shift/Task Turnover Important4. Finishing workers are tired and want to depart facility.5. Lack of adequate shift overlap to provide time to give one-on-one briefings between the teams6. Absence of a process to ensure departing personnel havedocumented all tasks accomplished or started.7. Minimal training on procedures for shift/task turnoverHigh-quality shift/task turnover procedures enableimprovement in practice and improve safety andaccountability to all involved in the work.
Federal AviationAdministration37Aircraft Maintenance DocumentationHow do you implement a Shift/Task Turnover process?• Formalize policy and procedures that make theturnover as important as the work.• Communicate policy and procedures to all personnel.• Consider technology enhancements that improve thetransfer of visual information (e.g., photos, graphics,movies).
Federal AviationAdministration38Aircraft Maintenance DocumentationHow do you implement the Shift/Task Turnover process?• Provide a time and place for formal shift/task turnover.• Ensure the quality of shift/task turnover Information.• Deliver initial and recurrent training on how to conduct agood shift/task turnover.• Define acceptable communication practices.
Federal AviationAdministration39Aircraft Maintenance DocumentationSummaryThe basic requirements for aircraft maintenancedocumentations are the same.The method of meeting those requirements may bedifferent depending on the type of operation.
Federal AviationAdministration40Aircraft Maintenance DocumentationSummaryIt may be a simple airframe, engine, propeller log book,or an air carrier’s maintenance record system.A description of the work performed, date the work wasperformed and the signature with certificate number andtype are always required.
Federal AviationAdministration41Aircraft Maintenance DocumentationCommon problems• No documentation.• Inadequate description of work performed.• Using the wrong reference.• Poor shift turnovers
Federal AviationAdministration42Aircraft Maintenance DocumentationEasy solutions• Follow the regulations.• Follow company procedures (GMM).• Use the Maintenance Personal Minimums Checklist !
Federal AviationAdministration43Aircraft Maintenance DocumentationBEFORE
Federal AviationAdministration44Aircraft Maintenance DocumentationAFTER
Federal AviationAdministration45Aircraft Maintenance Documentation
Federal AviationAdministration46Aircraft Maintenance DocumentationThank you.