The Importance of Aircraft Maintenance Records
Maintenance Records are the foundation of the Continuing Airworthiness of an aircraft and provide the operators, the aircraft owners and the National Aviation Authorities (NAA’s) with the evidence that an aircraft complies with the international and national requirements for airworthiness and safety. Without proper and complete maintenance records an aircraft is deemed as unairworthy and therefore its C of A is invalid and the aircraft unsafe and illegal to fly!
Commercial aircraft have an important role in today’s modern economy. They connect businesses and people across regions, countries and continents and are perceived by most as a very safe means of travel.
This perception of safety is earned by the rigorous management of airworthiness requirements laid down by ICAO which are deployed through the NAA’s where Operators and CAMO’s are compelled to ensure and be able to demonstrate an aircraft’s compliance with its Type Certificate, its Maintenance Program, the AD’s applicable to the aircraft, engines and appliances and, all Service Life Limited parts and components remain within their service life limits together with any other Instructions for Continuing Airworthiness.
Maintenance records are the certified records of any servicing, maintenance, replacement, adjustment, inspection, test, function, check or disturbance of any system, component, structure or assembly or any changes made to an aircraft by modification or repair. Any such event, no matter how minor, is required to be recorded and ultimately, Released to Service by an appropriately approved person, who is responsible to ensure the work is properly detailed and the maintenance data has been complied with. Actual maintenance records are sometimes referred to as Dirty Fingerprints (DFP’s) which refers to the original document being handled by the Mechanic with ‘dirty’ hands, most DFP’s held on a system are simply PDF’s of the original document recording and evidencing the work performed, the hard copies being retained and securely stored.
It is the Operator’s responsibility to know an aircraft is airworthy whenever it is operated and not to assume the condition. Maintenance records provide the proof that work was done, when it was done and that it was in compliance with approved maintenance data using approved materials, parts and components. Maintenance is planned by tracking each task and when it was last performed to calculate when it is next due to be performed. This applies to all required tasks; scheduled maintenance and inspections defined in the operator’s Approved Maintenance Program, AD’s for the airframe, engines and appliances defined by the NAA, Service Life Limited parts and components (Hard Time Components, LLP’s), defined by the manufacturers and other Instructions for Continuing Airworthiness (ICA’s) associated with repairs, modifications embodied and some components fitted to the specific aircraft.
Some maintenance records must be retained for the life of the aircraft such as those for modifications and repairs, and others must be retained until such time the task is superseded or repeated but in reality, many aircraft owners retain all maintenance records from date of delivery from the manufacturer to be retained.
As you can imagine, these records also form an important part of the asset (aircraft) value. They ‘prove’ the aircraft complies with the airworthiness requirements currently in force. Conversely, incomplete or missing maintenance records can significantly reduce the value of an aircraft. (An aircraft which cannot be shown to comply with airworthiness requirements is ‘unairworthy’ and therefore unable to be flown until such time the ‘missing’ evidence (DFP’s) can be found or the task(s) repeated in order that the aircraft and its components, engines and appliances can be demonstrated to be compliant with the airworthiness requirements in force)! These ‘missing’ records may require the aircraft to be grounded until the record has been repaired.
Similarly, when it’s time to sell or to return the aircraft to the lessor, poor records can extend the time the aircraft is grounded and inoperable by months pending technical acceptance where the purchaser/lessor tries to piece together the records available which often requires additional maintenance to repair the records costing sometimes millions of dollars in restoration, compensation and/or penalty rent! (Repairing records requires investigations and often means repeating a task or replacing a component to create a ‘new’ record to replace the ‘poor’ or missing record).
Furthermore, in the event of an incident or fatal accident, there can be serious legal consequences for operators for poor record keeping as the aircraft may be deemed to have been operated in an unairworthy condition (unsafe) and the aircraft C of A therefore invalid (if the C of A is invalid it may mean the aircraft’s insurance is also invalid!), which can lead to criminal negligence charges!
Maintenance record requirements are comprehensive, and compliance requires discipline by the maintenance technicians, as well as by the designated body responsible for the review of the completed records. This role is normally fulfilled by a small in-house or independent body responsible for the continuing airworthiness management of the aircraft (known as Continuing Airworthiness Management Organisation (CAMO) in Europe), working under an AOC of a commercial operation or, may be the FBO or Chief Pilot who performs the continuing airworthiness oversight and the maintenance management for business and private jets. Whoever it is, the person in charge of the aircraft’s maintenance must be sure all records are complete, errors are corrected, and missing entries, data, or documents are obtained.
This Continuing Airworthiness management task is very complex but we can simplify it by understanding that all changes to the aircraft’s airworthiness status are captured in one of 4 ways!
1. Flight’s, PIREPS (faults), minor maintenance, minor repairs, component changes, oil uplifts etc. carried out during operations are captured and certified on a Technical Log Page.
2. All scheduled maintenance and inspections other than that carried out above is captured in a Works Order performed, documented and certified by the maintenance provider.
3. All new AD’s are issued by the NAA at regular intervals.
4. All changes to the Maintenance Program recommended by the OEM are published at regular intervals.
By diligently managing these 4 activities we can ensure the aircraft always complies with its continuing airworthiness requirements.
Airbourne Fleet Technical Management system (FTM) is a tool which helps simplify and manage this complex process and provides total visibility of each aircraft’s Continuing Airworthiness at a glance. As each Maintenance Record is processed by the nominated person or organisation (CAMO), a copy of the DFP is loaded against the task, inspection, component replacement etc. in the system together with any other associated supporting evidence of compliance such as a component Release Certificate or a modification SB/STC etc. to provide the required Maintenance Record of compliance of that specific task. Once the PDF is on the system, it is locked in and can be quickly accessed at any time to demonstrate the aircraft’s compliance with a requirement (ICA, AMP, AD, SB/STC, Hard Time/LLP, Repair Scheme etc.) or may be reviewed by the CAMO as part of their oversight responsibilities.
Besides demonstrating compliance, secure read only access to the Maintenance Records can be made available via the internet enabling the buyer and/or the lessor to review and accept the aircraft much easier and quickly savings the operator time, effort and money.
Airbourne FTM – designed by operators for operators (and CAMO’s).
Contact us below to arrange a demonstration of the Airbourne FTM.