Aviation Business Journal 1st Quarter 2013 - 51

NATA Maintenance Perspective
release entries and part traceability information for replace-

work and another approved the aircraft for return to

ment parts and components. In other words, the maintenance

service, the dates may differ. Two signatures may also

story of the aircraft should be found in its maintenance re-

appear under this circumstance; however, it is not a

cords, at least the story required to be told by the regulations.

requirement.

Well-kept logbooks and maintenance records can also be

These are all pretty straightforward but do require atten-

helpful from a trouble-shooting perspective by providing a

tion to detail by the maintenance provider and the owner. It is

history of maintenance actions, possibly decreasing the time

a good idea for the owner to review the logbooks after main-

a technician may spend chasing a discrepancy. For example,

tenance or an inspection to ensure the work and maintenance

alterations may have set up an unintended consequence that

entries are properly stated; after all, the owner is ultimately

manifests itself later in the operation of the aircraft. If the

responsible.

maintenance technician knows about that alteration, he or she
will more than likely start the search in that area.
The size of your operation, whether you own a Piper Super
Cub in Barrow, Alaska, for private use or you are operating

Section 91.417(a)(2) requirements are more complicated
and can be an area of higher risk for noncompliance by the
owner and the maintainer.
■■

The total time in service of the airframe, each engine,

a large business fleet, will dictate the sophistication of the

each propeller, and rotor. This requires tracking the

recordkeeping system and process. In the first instance, all the

time that has accumulated. The definition of “Time in

records may be in a manila envelope or file folders, whereas a

Service” can be found in 14 CFR Part 1, which states, in

larger complex operation may use electronic systems that are

part, that it is from the moment an aircraft leaves the

automatically updated with every data entry.

surface of the earth until it touches it at the next point of

Regulatory Requirement for Maintenance Records
Title 14 Code of Federal Regulations (CFR) section 91.417

landing.
The total time in service for engines requirement has two
variations. The first variation refers to rebuilt engines; the

describes two types of records that must be kept. The first,

owner or operator may not know the total time in service. The

listed in section 91.417(a)(1), are those that need to be kept

regulations allow a rebuilder of an engine to zero the time and

until the work is repeated or superseded by other work, or for

create a new record. The second variation refers to modular

one year after the work is performed. The other type of re-

engines found in turboprop or turbojets. With those engines,

cords listed in section 91.417(a)(2) must be transferred when

the owner/operator must track total time in service of the

the aircraft is sold.

modules.

First, let’s look at records that are kept until the work is

Tracking the total time in service can really be a chal-

repeated or superseded found in section 91.417(a)(1). They

lenge with older aircraft with incomplete or sketchy mainte-

are also found in section 43.9(a) and pertain to maintenance,

nance histories. Advisory Circular (AC) 43-9C, Maintenance

preventative maintenance, rebuilding, and alterations.

Records, describes a process to derive the total time; however,

A description of the work performed on the aircraft. The

it does state that the procedures contained in the AC do not

description should be in sufficient detail to permit a per-

apply to life-limited parts or airworthiness directive (AD)

son unfamiliar with the work to understand what was

■■

compliance.

done and the methods, techniques and practices used in

■■

The current status of life-limited parts of each air-

performing it.

CFR defines a life-limited part as any part for which a
mandatory replacement limit is specified in the type

vice. The certificate number can be that of an individual

design, the Instructions for Continued Airworthiness,

or an organization; i.e., Part 145 repair station.
■■

frame, engine, propeller, rotor, and appliance. The

The signature, FAA certificate type, and certificate number of the person approving the aircraft for return to ser-

■■

or the maintenance manual. The CFR also defines the

The date the work was completed. This will normally

life status of a part as the accumulated cycles, hours, or

be one date; however, if one person accomplished the
Continued on page 52

Aviation Business Journal | 1st Quarter 2013	

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Aviation Business Journal 1st Quarter 2013

Table of Contents for the Digital Edition of Aviation Business Journal 1st Quarter 2013

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