Avionics News October 2014 - 17

the	 ASI	 clearly	 explaining	 the	 causes(s)	 for	 concern.	 As	
part	of	this	written	notification,	the	ASI	should	request	an	
explanation	of	corrective	actions	in	writing	from	the	certificated	mechanic	along	with	a	copy	of	any	reference	entries	
entered	in	the	aircraft	permanent	records.
Volume 6 Surveillance: Chapter 2 Part 121, 135 and
91 Subpart K inspections
Section 37 - Improper Maintenance and Alterations
This	 section	 provides	 aviation	 safety	 inspectors	 (maintenance	and	avionics)	guidance	in	determining	appropriate	
action	when	investigating	cases	of	improper	maintenance/
alteration.
In	 July	 2007,	 the	 FAA	 issued	 Notice	 N	 8900.12,	
Processing	Reports	of	Suspected	Unapproved	Parts,	thereby	canceling	FAA	Order	8120.10A,	Suspected	Unapproved	
Parts	 Program.	The	 notice	 was	 subsequently	 incorporated	
into	FAA	Order	8120.16,	Processing	Reports	of	Suspected	
Unapproved	Parts,	and	became	effective	in	July	2008.	The	
notice	realigned	the	Suspected	Unapproved	Parts	Program	
Office's	responsibilities	within	the	Flight	Standards	Service	
and	Aircraft	Certification	Service.	During	the	realignment	
and	review	of	the	SUP	policy	contained	in	Order	8120.10A,	
the	FAA	realized	we	defined	and	categorized	"improperly	
maintained"	 or	 "altered	 parts"	 as	 unapproved	 parts.	 The	
definition	of	"improperly	maintained"	as	established	in	N	
8900.85,	 Improper	 Maintenance	 and	Alterations,	 on	Aug.	
6,	2009,	is	listed	below	for	clarification.
Improperly Maintained or Altered.	 A	 part	 or	 component	 that	 has	 been	 returned	 to	 service	 by	 a	 certificated	
person	 without	 the	 work	 being	 completed	 in	 accordance	
with	 14	 CFR	 Part	 43	 or	 an	 approved	 process/procedure	
acceptable	to	the	administrator.
6-1012 Guidance.	When	ASIs	conduct	investigations	of	
allegations	of	improper	maintenance/alteration,	the	following	 guidance	 applies.	 Approved	 parts	 are	 parts	 produced	
under	 an	 approval	 according	 to	 the	 procedural	 requirements	 of	 14	 CFR	 Part	 21.	 Parts	 eligible	 for	 installation	
on	type-certificated	aircraft,	but	excepted	from	the	FAA's	
approval	 requirements,	 are	 also	 considered	 "approved	
parts."	FAA	approval	requirements	are	detailed	in	Part	21,	
§§	 21.8	 and	 21.9.	 Improper	 maintenance/alteration	 of	 an	
approved	 part	 does	 not	 render	 the	 part	 unapproved,	 but	
can	 render	 the	 part	 ineligible	 for	 installation	 because	 the	
part	was	not	maintained	or	altered	in	accordance	with	the	
provisions	of	Part	43.	Under	this	circumstance,	an	installer	
can	 no	 longer	 verify	 that	 installation	 of	 the	 improperly	
maintained/altered	 part	 in	 a	 TC'd	 product	 would	 return	
that	product	to	a	condition	at	least	equal	to	its	original	or	
properly	altered	condition.	Such	a	verification	is	a	necessary	condition	in	determining	installation	eligibility	under	
Part	43,	§	43.13(b).

FREQUENTLY ASKED
QUESTIONS
United States
Birth records for articles
The following information is from the Federal Aviation
Regulations (14 CFR Parts 43 and 91).

QUESTION:

My	customer	is	requesting	"birth	records"	for	an	article	
recently	overhauled	by	us.	What	is	required?

ANSWER:

There	 are	 two	 requirements	 for	 maintenance	 records:	
one	for	the	maintainer	(§	43.9)	and	one	for	the	operator	
(§	 91.417).	 Neither	 requires	 birth	 records	 for	 articles.	
However,	it	is	important	to	understand	that	many	international	regulatory	bodies	do	require	"back	to	birth	records."
For	 the	 maintainer,	 Section	 43.9	 (a)	 requires	 that	 following	 maintenance,	 preventive	 maintenance,	 rebuild	 or	
alteration:
1.	 A	 description	 (or	 reference	 to	 data	 acceptable	 to	
the	administrator)	of	work	performed.
2.	 The	date	of	completion	of	the	work	performed.
3.	 The	 name	 of	 the	 person	 performing	 the	 work	 if	
other	than	the	person	specified	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	the	work.	The	signature	
constitutes	the	approval	for	return	to	service	only	
for	the	work	performed.
There	are	exceptions	for	air	carrier	maintenance	(43.9	
(b))	and	inspections	(43.9	(c)),	and	specific	requirements	
for	major	alterations	and	repairs	(43.9	(d)).
The	 operators	 requirements	 are	 contained	 within	 §	
91.417	Maintenance	records.	Records	retention	are	contained	in	§	91.417	(b).	The	owner	or	operator	shall	retain	
the	following	records	for	the	periods	prescribed:
1.	The	 records	 specified	 in	 paragraph	 (a)(1)	 of	 this	
section	 shall	 be	 retained	 until	 the	 work	 is	 repeated	
or	superseded	by	other	work	or	for	one	year	after	the	
work	is	performed.
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Avionics News October 2014

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