November-December 2022 - 39

A R S A INS IG H T
Records: Bane or Boon
Recordkeeping is the bane of business; keep too much and get are overrun,
keep too little and risk not being able to establish compliance. The government
runs on paperwork and in aviation, records go beyond what is required
by the FAA.
Good practices dictate a business establish a solid recordkeeping
policy and stick to it. Unfortunately, it is difficult to decipher
what records need to be kept and for how long. The result: many
companies just keep everything forever, a practice that makes it
almost impossible to find a requested document short of searching
for hours. Without going into all the requirements that may dictate
the type of records that must be kept, let's focus on a business or
individual with a U.S. mechanic or repair station certificate.
Surprisingly, mechanics have no recordkeeping requirements;
they have record making requirements under §§ 43.9 and 43.11 for
the maintenance, alterations and inspections performed. Those
regulations require a record to be made by any person performing
work on a civil aviation aircraft or component. The rules do not
require the mechanic keep a copy, but individuals not keeping track
of what they did, for whom, and when open themselves to accusations
of non-compliance. A mechanic should not be performing
work without recency of experience or having done the work under
supervision. How can that be " shown " without records?
For companies with repair station certificates, there are records
that must be kept and those that should be kept. Maintenance
records, those required by §§ 43.9 and 43.11, must be kept for two
years after the work is completed. That is only to satisfy the FAA,
not customers. Contracts may require retention for longer, possibly
10 or 20 years.
Training records for technicians must be kept for two years after
the training has been given, but many companies keep them for
two years after the individual separates from the company. There
is no requirement to keep old versions of the repair station quality
manual, rosters, or forms, but without them it is hard to show
continued compliance.
So, what is one to do?
Start by making sure you know why you are keeping what data.
Since everyone must answer to the IRS, state, and local tax authorities,
it is essential to work with an accountant or bookkeeper to
identify the financial records expected to be retained. Next, look
at your contracts and obligations to customers, identify the types
of records required, and the retention times. Match those expectations
to the business data that supports the forms created during
the maintenance, alteration, or inspection process; identify those
that are the same. Once the types of records are matched to the
forms and documents created or obtained, identify the " purely "
business documents from the " quality " records, and set the time
parameters of what is kept for which
agency or customer.
Don't forget maintenance manuals
and other instructions relating to
the work performed. Older versions of
those documents should be retained
to establish compliance for past work and to use in the future if a
manufacturer removes a process for its business purposes.
Sarah MacLeod is managing member of Obadal, Filler,
MacLeod & Klein, P.L.C. and a founder and executive director
of the Aeronautical Repair Station Association.
By Sarah MacLeod
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November-December 2022

Table of Contents for the Digital Edition of November-December 2022
