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Federal AviationAdministrationAircraft Maintenance
Records & AirworthinessDirectives
Mark Laughridge – FAASTeam Program ManagerMarch 9, 2013
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Introduction
This course provides a review of aircraft
maintenance documentation requirements,
emphasizing the importance of accurate and complete documentation.
It identifies common documentation problems
that can lead to maintenance errors.
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Aircraft Maintenance Records
The basic requirements for Aircraft Maintenance Records are the same.
The method of meeting those requirements may be different depending on the type of operation.
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Common problems
• No documentation.• Inadequate description of work performed.• Using the wrong references.• Poor shift turnovers
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Regulation Cited
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Sept. 11, 1999 near Eagle Lake Texas.
Continental Express Flight 2574 an EMB 120
In flight the left horizontal stabilizer leading edge bent down and then separated from the aircraft.
Attaching hardware had been left out of the upper left horizontal stabilizer leading edge.
14 passengers and crew killed near Eagle Lake Texas.
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NTSB Finding
Departures from approved procedures included failures to give proper shift / turnover reports, failures to use maintenance work cards as approved, failures to complete required maintenance/inspection shift / turnover forms, and a breach in integrity of the quality control system.
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Shift /Turnover
The transfer of critical information between work groups or shifts
It needs to be as detailed as necessary, depending on the tasks involved
Sharing of information by the people doing the task
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Why is Shift/Task Turnover Important
Data shows that poor shift/task turnover is a contributing factor to accidents/incidents.
Challenges related to shift turnover include:
1. A high demand for teamwork and communication skills
2. Lack of structured and standardized policies and procedures
3. Using a location that is not conducive for discussion and planning
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Why is Shift/Task Turnover Important
4. Finishing workers are tired and want to depart the facility.
5. Lack of adequate shift overlap to provide time to give one-on-one briefings between the teams.
6. Absence of a process to ensure departing personnel have documented all tasks accomplished or started.
7. Minimal training on procedures for shift/task turnover.
High-quality shift/task turnover procedures enable improvement in safety and accountability to all involved in the work.
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Implement a Shift/Task Turnover process
• Formalize policy and procedures that make the turnover as important as the work.
• Communicate policy and procedures to all personnel.
• Deliver initial and recurrent training on how to conduct a good shift/task turnover.
• Provide a time and place for formal shift/task turnover.
• Consider technology enhancements that improve the transfer of visual information (e.g., photos, graphics).
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Part 43.3 Persons Authorized to Perform Maintenance
The holder of a Mechanic Certificate…
The holder of a Repairman Certificate…
The holder of a Repair Station Certificate…
The holder of a Air Carrier Operating Certificate…
The holder of a Pilot Certificate…
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Part 43.5 Approval for Return to Service After Maintenance, Preventive Maintenance…
No person may approve for return to service any aircraft… that has undergone maintenance…unless,
(a) The maintenance record entry required by 43.9 or 43.11 has been made…
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Part 43.7 Persons Authorized to Approve Aircraft, Aircraft engines…for return to service after maintenance…
The holder of a mechanic certificate or an inspection authorization…
The holder of a repair station certificate…
The manufacturer…
The holder of a air carrier operation certificate…
The holder of a private pilot certificate…
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Part 43.9 Content, Form, and Disposition of Maintenance Records
(a)…each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, engine, propeller, appliance, or component part, shall make an entry in the maintenance record of that equipment
(1) A description of work performed.
(2) Date of completion of the work performed.
(3) The name of the person performing the work
(4) The signature, certificate number, and kind of certificate held by the person approving the work.
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“Note”
“The signature constitutes the approval for return to service only for the work performed.”
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Part 43.11 Content, Form, and Disposition of Records for Inspections
(a) The person approving an aircraft for return to service …shall make an entry in the maintenance record of that equipment containing the following information:
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Part 43.11 Content, Form, and Disposition of Records for Inspections
(1) The type of inspection and a brief description.
(2) The date of the inspection and aircraft total time in service.
(3) The signature, the certificate number, and kind of certificate held by the person approving the aircraft for return to service.
(4) Certifying statement
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43.13 PERFORMANCE RULES (GENERAL)43.13 PERFORMANCE RULES (GENERAL)
(a) Each person performing maintenance, alteration, or (a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or preventive maintenance on an aircraft, engine, propeller, or appliance appliance shall use the methods, techniques, and practices shall use the methods, techniques, and practices prescribed in the current manufacturer’s maintenance prescribed in the current manufacturer’s maintenance manual or Instructions for Continued Airworthiness prepared manual or Instructions for Continued Airworthiness prepared by its manufacturerby its manufacturer, or other methods, techniques, and , or other methods, techniques, and practices acceptable to the Administrator, except as noted in practices acceptable to the Administrator, except as noted in 43.16. He 43.16. He shall use shall use the tools, equipment, and test apparatus the tools, equipment, and test apparatus necessary to assure completion of the work in accordance necessary to assure completion of the work in accordance with accepted industry practices. with accepted industry practices. If special equipment or If special equipment or test apparatus is recommended by the manufacturer test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus involved, he must use that equipment or apparatus oror its its equivalent acceptable to the Administrator. equivalent acceptable to the Administrator.
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I’ve always done it this way!
This is an example of what happens when we do not pay attention to detail, and do not follow instructions and checklists!
A KC-135 Aircraft was being pressurized at ground level. The outflow valves which are used to regulate the pressure of the aircraft were capped off during a 5 year overhaul and never opened back up. The post-investigation revealed: that a civilian depot technician who, "had always done it that way," was using a homemade gauge, and no procedure.
The technician's gauge didn't even have a max "peg" for the needle and so it was no surprise he missed it when the needle went around the gauge the first time. As the technician continued to pressurize the aircraft, and as the needle was on its second trip around the gauge the aircraft went "boom" - the rear hatch was blown over 70 yards away, behind a blast fence!
An incident like this is never funny and is further regrettable when we consider that this mistake is one that we (the taxpayers) will end up paying for. Fortunately, no one was reported as being injured.
This was a good "Lessons Learned" for making sure we have trained people, who have the right tools, and who are following detailed procedures. And it should serve as a reminder that just because you’ve always done it that way, it does not make it the “right” way!
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(c) ((c) (CContinuous ontinuous AAirworthiness irworthiness MMaintenance aintenance PPrograms rograms approved under FAR Part 121, 127, 135, and 129 constitute an approved under FAR Part 121, 127, 135, and 129 constitute an acceptable means of compliance with this section). acceptable means of compliance with this section).
(b) Each person maintaining or altering or performing (b) Each person maintaining or altering or performing preventive maintenance, preventive maintenance, shall do that work in such a manner shall do that work in such a manner and use material of such a quality, that the condition of the and use material of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly worked on will be at least equal to its original or properly altered conditionaltered condition (with regard to aerodynamic (with regard to aerodynamic function, structural strength, vibration and deterioration function, structural strength, vibration and deterioration resistance, and other qualities affecting airworthiness). resistance, and other qualities affecting airworthiness).
43.13 PERFORMANCE RULES (GENERAL) (cont.) 43.13 PERFORMANCE RULES (GENERAL) (cont.)
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91.417 Maintenance Records
Records of maintenance…must include--
A description (or reference to data acceptable to the Administrator) of the work performed; and
The date of completion of the work performed; and
The signature, and certificate number of the person approving the aircraft for return to service.
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91.417 Maintenance Records
The total time in service of the airframe, each engine, each propeller, and each rotor.
The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.
The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and appliances are maintained.
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The current status of applicable airworthiness directives (AD) and safety directives including, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
Copies of the forms prescribed by Sec. 43.9(a) for each major alteration to the airframe, and currently installed engines, rotors, propellers, and appliances.
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Record retention
• The owner or operator shall retain the following records for the periods prescribed:
• 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 1 year after the work is performed.
• The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.
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INCORPORATION BY REFERENCE
• You don’t have to write a book.
• The regulations permit reference to technical data in lieu of making a long step by step detailed entry.
• Common references include maintenance manuals, service letters, bulletins, work orders, advisory circulars (AC43.13-1B), and others.
• Major alterations may reference STC’s.
• Reference documents must be retained.
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Aircraft Maintenance Records
What Must Be In The Maintenance Records?
• Description of the work performed
• Date the work was completed
• Signature and certificate number of the person approving the work
SIGNATURE
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AIRWORTHINESS DIRECTIVES
An unsafe condition exist in a product.
The condition is likely to exist or develop in other products
of the same design.
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RESPONSIBILITY
The Owner/Operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with ADs
The Owner/Operator is responsible for ensuring that properly certificated persons perform the work.
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RESPONSIBILITY
Maintenance personnel are responsible when they are
performing inspections to determine that all airworthiness
requirements are met.
Part 43.15
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RECORDS
The owner must keep a record showing the current
status of all applicable ADs.
This record must include the following:
The current status of ADs applicable to the aircraft,
including the AD number and revision date, the method
of compliance, and the time‑in‑service, or the cycles,
and the date and/or time when the next action is
required for a recurring AD.
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Steps to performing a successful AD research
• Un-cowl and completely open the aircraft for the inspection.
• Clean the aircraft.
• Starting with the aircraft serial number, write down each and every part number and serial number of all installed equipment, to include the engine and its components, and the prop.
• There are a number of good forms available for this on the internet.
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• Climbing under the panel with a flashlight and mirror to collect the model and serial numbers from all the instruments is difficult.
BUT…..
• Murphy’s Law says that the instrument you miss will be the one with the AD note that is overdue.
Steps to performing a successful AD research
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AD sign offs in the records.
• Some common yet incorrect entries found in some records are:
– “PCW” with no other information
or
– “N/A” with no other information
or – an entry without enough information
or – “All ADs complied with”
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•No reference to next due date and time. “All other AD notes checked for compliance” is an incorrect signoff.
Problem maintenance record entry?
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Sample Logbook EntryN12345 Tach/Hobbs: ____________ ACTT: ____________ Enter the type of inspection(s) performed:
Enter accomplishment of all A.D.’s including the number, revision date, method of compliance, and if recurring, the next time/date it is due.
Enter replacement or inspection of any component part with Airworthiness Limitations (include part, serial number, and total time in service for that component).
Enter removal and installation of any serialized components (include part, serial number, and total time in service for that component).
Enter description of any other general maintenance performed.
I certify that this aircraft was inspected in accordance with a (insert type) inspection and was determined to be in an airworthy condition. All work was accomplished in accordance with current Federal Aviation Regulations and manufacturer’s maintenance instructions.
Signature_______________ Certificate #_______________ Date__________
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DESCRIPTION OF WORK PERFORMED
The description should be in sufficient detail to permit
a person unfamiliar with the work, to understand what
was done, and the methods and procedures used.
“Show the same pride in your record entries as you do in your work”.
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Summary It may be a simple airframe, engine, propeller log book,
or an air carrier’s maintenance record system.
A description of the work performed, date the work was performed and the signature with certificate number and type are always required.
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Common problems
• No documentation.• Inadequate description of work performed.• Using the wrong reference.• Poor shift turnovers
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Easy solutions
• Follow the regulations.• Follow company procedures (GMM).• Use the Maintenance Personal Minimums Checklist !
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Before the task
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AFTER
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Aircraft Maintenance Records
The Southern Region FAASTeam is dedicated to quality customer service
and we would appreciate your feedback on the critique sheet
provided.
Thank You