An aircraft owner is required to keep aircraft maintenance records for the airframe, engine, propeller, and appliances. These records must contain a description of the work performed on the aircraft, the date the work was completed, the certificated mechanic’s signature, the type of Federal Aviation Administration (FAA) certificate, and the certificate number and signature of the person approving the aircraft for return to service.
Responsibilities of the Aircraft Owner
All recordkeeping is primarily the responsibility of the aircraft owner. The airframe and powerplant (A&P) mechanic is responsible for the work he or she performs. The owner of an aircraft must also ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service. The owner’s aircraft records shall also contain the inspections required pursuant to Title 14 of the Code of Federal Regulations (14 CFR) part 91, section 91.409.
Proper management of aircraft operations begins with a good system of maintenance records. A properly completed maintenance record provides the information needed by the owner and maintenance personnel to determine when scheduled inspections and maintenance are to be performed.
Aircraft maintenance records must include:
- The total time in service of the airframe, each engine, and each propeller;
- The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance;
- The time since the last overhaul of all items installed on the aircraft, which are required to be overhauled on a specified time basis;
- The identification of the current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained;
- The current status of applicable Airworthiness Directives (ADs) including, for each, the method of compliance, the AD number, and the revision date. If the AD involves recurring action, the time and date the next action is required; and
- A copy of the major alterations to each airframe, engine, propeller, and appliance.
These records are retained by the owner and are transferred with the aircraft when it is sold. Figure 8-1 is a maintenance records checklist you can use to document compliance with the applicable maintenance requirements.
These records may be discarded when the work is repeated or superseded by other work, or 1 year after the work is performed.
CAUTION: Keep in mind that as a result of repairs or alterations, such as replacing radios and installing speed kits, it may be necessary to amend the weight and balance report, equipment list, flight manual, etc.
Most maintenance performed on an aircraft is recorded in the aircraft logbooks. As an aircraft owner, it is important to ensure that your aircraft’s logbooks are complete and up to date at all times. The aircraft logbooks outline the maintenance history of your aircraft, and any prospective buyer will want to review the aircraft and all maintenance performed. In addition, any A&P or certificated repair station performing maintenance on your aircraft will want to review the prior maintenance performed on the aircraft.
An aircraft owner is required to comply with all applicable ADs issued by the FAA for his or her aircraft. The FAA issues ADs to notify aircraft owners and other interested persons of unsafe conditions and to specify the corrective action required, including conditions under which the aircraft may continue to be operated.
The aircraft’s maintenance records should indicate the current status of all applicable ADs, including for each:
- AD number,
- Method of compliance,
- Revision date, and
- Recurring action (if applicable) including the time and date of the next action required.
The owner or operator of an aircraft having a special airworthiness certificate must comply with each safety directive applicable to the aircraft that corrects an existing unsafe condition or corrects the condition in a manner different from safety directive specifications if the person issuing the directive agrees with the action. Otherwise, the owner or operator may, in accordance with 14 CFR part 91, section 91.327, “obtain an FAA waiver from the provisions of the safety directive based on a conclusion that the safety directive was issued without adhering to the applicable consensus standard.”
Light-sport category aircraft certificated pursuant to 14 CFR part 21, section 21.190 have mandatory compliance with all manufacturer safety directives.
A service bulletin contains a recommendation from the manufacturer, with which that manufacturer believes the aircraft owner should comply, that often reflects a safety-of-flight issue that the manufacturer believes should be addressed within a certain timeframe. It may result from an improvement developed by the manufacturer, or it may address a defect in a product or published documentation.
The manufacturer responds to one of these situations by issuing a service bulletin that recommends a certain type of inspection, replacing certain components, performing maintenance in a specific manner, or limiting operations under specified conditions. Sometimes, compliance with a service bulletin may be triggered by the occurrence of a particular event (e.g., the lapse of time or operation under certain types of conditions).
FAA Form 337, Major Repair and Alteration
A mechanic who performs a major repair or major alteration shall record the work on FAA Form 337 and have the work inspected and approved by a mechanic who holds an inspection authorization (IA). (Light-sport aircraft do not require Form 337 when altering a non-approved product.) A signed copy shall be given to the owner and another copy sent to the FAA Aircraft Registration Branch (AFS-750) in Oklahoma City, Oklahoma within 48 hours of aircraft approval for return to service. However, when a major repair is done by a certificated repair station, the customer’s work order may be used and a release given as outlined in 14 CFR Part 43, Appendix B, Recording of Major Repairs and Major Alterations. You can obtain additional information and instructions for completing FAA Form 337 in Advisory Circular (AC) 43-9 (as revised), Aircraft Maintenance Records. Figure 8-2 is a sample FAA Form 337.
Entries into Aircraft Maintenance Records
Each time maintenance, including preventive maintenance, is performed on your aircraft, an appropriate entry must be added to the maintenance records.
14 CFR Part 43, Section 43.9, Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records (except inspections performed in accordance with part 91, part 125, §135.411(a)(1), and §135.419 of this chapter
Any person who maintains, rebuilds or alters an aircraft, airframe, aircraft engine, propeller, or appliance shall make an entry containing:
- A description of the work or some reference to data acceptable to the FAA,
- The date the work was completed,
- The name of the person who performed the work, and
- If the work was approved for return to service, the signature, certificate number, and kind of certificate held by the person approving the aircraft for return to service.
14 CFR Part 43, Section 43.11, Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter
When a mechanic approves or disapproves an aircraft for return to service after an annual, 100-hour, or progressive inspection, an entry shall be made including:
- Aircraft time in service,
- The type of inspection,
- The date of inspection,
- The signature, certificate number, and kind of certificate held by the person approving or disapproving the aircraft for return to service, and
- A signed and dated listing of discrepancies and unairworthy items.
14 CFR Part 91, Section 91.409, Inspections
Inspection entries for 14 CFR part 91, section 91.409(e) airplanes over 12,500 pounds, turbo jet, or turbopropeller-powered multiengine airplanes are made according to 14 CFR part 43, section 43.9, and shall include:
- The kind of inspection performed,
- A statement by the mechanic that the inspection was performed in accordance with the instructions and procedures for the kind of inspection program selected by the owner, and
- A statement that a signed and dated list of any defects found during the inspection was given to the owner, if the aircraft is not approved for return to service.
14 CFR Part 91, Section 91.411, Altimeter system and altitude reporting equipment tests and inspections
14 CFR part 91, section 91.411, requires that every airplane or helicopter operated in controlled airspace under instrument flight rules (IFR) conditions have each static pressure system, each altimeter, and each automatic pressure altitude reporting system tested and inspected every 24 calendar months. The aircraft maintenance records must include:
- A description of the work,
- The maximum altitude to which the altimeter was tested, and
- The date and signature of the person approving the aircraft for return to service.
14 CFR Part 91, Section 91.413, ATC transponder tests and inspections
14 CFR part 91, section 91.413, requires that anyone operating an Air Traffic Control (ATC) transponder specified in 14 CFR part 91, section 91.215(a), have it tested and inspected every 24 calendar months. The aircraft maintenance records must include:
- A description of the work, and
- The date and signature of the person approving the airplane for return to service.
14 CFR Part 91, Section 91.207, Emergency locator transmitters
14 CFR part 91, section 91.207, requires that no person may operate a U.S. registered civil airplane unless there is attached to the airplane a personal type or an automatic type emergency locator transmitter (ELT) that is in operable condition and meets applicable requirements of Technical Standard Order (TSO)-C91.
CAUTION: New ELT installations after June 21, 1995, must meet TSO-C91A (the first revised, or amended, version).
Batteries used in ELT shall be replaced when:
- The transmitter has been in use for more than 1 cumulative hour, or
- 50 percent of the ELT’s useful life has expired.
The expiration date for replacing the battery shall be legibly marked on the outside of the transmitter and entered in the aircraft maintenance records.
The condition inspection for amateur-built aircraft replaces the annual inspection.
Your local FSDO can help you establish your aircraft maintenance program and the necessary maintenance records. Additional information relating to aircraft maintenance records can be obtained from:
- 14 CFR Part 39, Airworthiness Directives
- 14 CFR Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration
- 14 CFR Part 91, General Operating and Flight Rules
- AC 43-9 (as revised), Maintenance Records
These publications are available on the FAA website at www.faa.gov and from U.S. Government Printing Office (GPO) bookstores located throughout the United States.