The following items and issues serve as a summary and overview regarding observed issues during records reviews:
a) Deferred Defects not referencing the original date of the defect
b) Identifying MEL defects as “non-operational” leading to exceedances and overruns
c) Cabin Log containing airworthiness items which are not transferred to the Aircraft Technical Logbook
d) Robbery of OTAR registered aircraft components incorrectly certified using EASA Form 1 (Not in accordance with AMC 145.A.50)
e) Parts manufactured under the FAA Parts Manufacturing Approval (PMA) are typically acceptable to Overseas Territories (OT) when accompanied by an 8130-3 form (Must be eligible for fitment on the aircraft type) However PMA has been found fitted ref ATA 106 (Not an acceptable release document)
Note – ATA 106 forms are statements, not certifications, unfortunately, many resemble the 8130-3 or EASA Form One format.
f) Flight Manual Status Management and Amendment – AD’s missing or out of date – FM Supplements missing
g) Status of Corrosion Control (Corrosion Prevention and Control Programs)
h) Supplemental Structural Inspection Document (SSID) Status
i) Major Repairs Status – All
j) Major Modifications Status – All
k) Technical Records Documentation – Life Limited Parts (LLP) Back to Birth records availability shortfall (even when in exactly the same condition as an initial receipt)
l) Lack of Technical Record History – OTARs and EASA requirements mandate that detailed records be kept in some cases back to birth. Supplied Aircraft records go back to the last “D” check (not acceptable)
Note 1– Back to Birth (BTB) traceability requires hard time EASA Form 1’s plus full shop visit reports (SVR)
Note 2– The leasing company is far more attentive during Lease returns – Typically the lease agreement will carry a disclaimer and place the full burden on the operator during acceptance to “accept” the aircraft in regard to all aspects and elements.
m) Lack of full availability of Shop Visit Reports (SVR) – Note Shop visit reports for Landing Gear (LDG) and engines contain essential records which are required when returning an aircraft at the end of lease
n) Lack of sufficient hard copy files of Continuing Airworthiness Data – Airworthiness Directives Files with Dirty Fingerprints (DFP), Major Modifications (STCs) All the information supporting an STC should be in the records (STC, ICAW, DGRs, FM Supplement, Airworthiness Limitations, CMRs etc)
o) Missing BTB records for all LLPs as well as the last overhaul certification for Service Life Limited Parts
p) Incomplete Aircraft Dent and Buckle Mapping – with all appropriate references to approved data.
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