Related considerations concerning Continuing Airworthiness Records
Part 39 Continued Airworthiness Requirements – Subpart D – Aircraft Records
The following references are applicable to CAW records
39.73 Maintenance and continued airworthiness records
39.75 Retention of records
CAW records retention for maintenance records
(2) for all detailed maintenance records in respect of the aircraft and any service life-limited component fitted thereto, not less than 24 months after the aircraft been released to service in respect of that maintenance or until the information contained therein is superseded by new information equivalent in scope and detail, whichever is the longer time.
Concerning the transfer of records
39.77 Transfer of maintenance records
(a) Each holder of a Territory Certificate of Registration for an aircraft transferring registration to another person under OTAR Part 47 shall, at the time of transfer of registration, transfer to that person all relevant maintenance records and records of continued airworthiness.
(b) In the event of a temporary change of operator, the relevant maintenance records and records of continued airworthiness shall be made available to the new operator.
Background Concerning Retention Criteria
117.1 Objective for Record Keeping – Properly executed and retained records provide owners, operators and maintenance personnel with information essential in controlling unscheduled and scheduled maintenance, and troubleshooting to eliminate the need for re-inspection and rework to establish airworthiness.
As a minimum, records necessary to prove all requirements have been met for issuance of the certificate of release to service including sub-contractors release documents should be retained.
The prime objective is to have secure and easily retrievable records with comprehensive and legible contents.
The aircraft record should contain basic details of all serialised aircraft components and all other significant aircraft components installed, to ensure traceability to such installed aircraft component documentation and associated maintenance data.
Store Media and Data Backup
117.2 Media requirements
(a) The maintenance record can be held on either a paper or computer system or any combination of both. In all cases, the record should remain legible throughout the required retention period.
(b) Computer systems may be used to control maintenance and/or record details of maintenance work carried out.
Computer systems used for maintenance should have at least one backup system that should be updated within a maximum of 24 hours of any maintenance. Each terminal is required to contain programme safeguards against the ability of unauthorised personnel to alter the database.
117.3 Storage
The records should be stored in a safe way with regard to fire, flood and theft. Computer backup discs, tapes etc. should be stored in a different location from that containing the working discs, tapes etc in an environment that ensures they remain in good condition.
117.4 Modular Engine Records
Some gas turbine engines are assembled from modules and true total time in service for a total engine is not kept.
When owners and operators wish to take advantage of the modular design, total time in service and maintenance records for each module is to be maintained.
The maintenance records as specified are to be kept with the module and should show compliance with any mandatory requirements pertaining to that module
117.5 Restoration of Lost or Destroyed Records
Reconstruction of lost or destroyed records can be done by reference to other records which reflect the time in service, research of records maintained by repair facilities and reference to records maintained by individual mechanics etc.
When these things have been done and the record is still incomplete, the owner/operator may make a statement in the new record describing the loss and establishing the time in service based on the research and the best estimate of time in service.
Note – The reconstructed records should be submitted to the Governor for acceptance. (approved by the authority – however, the possibility of moving an aircraft with re-constituted records would be extremely problematic)
117.6 Transfer of Records
Where an approved organisation terminates its operation, all retained maintenance records covering the last two years should be distributed to the last owner/customer of the respective aircraft or component.
If it is impossible to trace the owner/customer, the maintenance records should be stored as required by the Governor.
Note – EASA requires the last 3 years so again potentially a problem
Next Steps
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