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ALC-180: Aircraft Maintenance Documentation for AMTs (AMT Core Crs 2012)
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NOTE: These excerpts were current at time of publishing, always check current regulations before exercising your certificate privileges. Links are provided to current regulations, in most cases, for your convenience.
  • Improper documentation of maintenance is too frequently cited in FAA enforcement actions.  Part 43.9 and  43.11 are among the most common regulations cited
  • Maintenance-related accidents and incidents are on a downward trend. However, maintenance-related accidents result in a higher likelihood of injury.
  • Mechanic violations fall into very consistent categories. Failure to perform maintenance and inspections in accordance with approved methods (43.13, 43.15) and failure to document such actions prior to return to service (43.5, 43.9) accounted for 90% of all maintenance violations
  • Common problems are improper documentation of maintenance.  No documentation.  Inadequate description of the work performed.   Citing the wrong reference.
  • Part 43 is where you find the basic rules for Maintenance, Preventive Maintenance, and Alterations.
  • Part 91 is where you find the basic operating rules for aircraft owners/ operators regarding Maintenance, Preventive Maintenance, and Alterations
  • Part 135 Subpart J. is where we find the rules for Maintenance, Preventive Maintenance, and Alterations that must be followed by 135 operators.
  • Part 145 is where we find the rules for Maintenance, Preventive Maintenance, and Alterations that must be followed by 145 repair stations.

 



(For Current Regulation Click HERE!)

Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:

(1) A description (or reference to data acceptable to the Administrator) of the work
performed.
(2) The date of completion of the work performed.
(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

 


(For Current Regulation Click HERE!)

(a) Definitions used in this section. For the purposes of this section the following definitions apply.

Life-limited part means any part for which a mandatory replacement limit is specified in the type design, the Instructions for Continued Airworthiness, or the maintenance manual.

Life status means the accumulated cycles, hours, or any other mandatory replacement limit of a life-limited part.

(b) Temporary removal of parts from type-certificated products. When a life-limited part is temporarily removed and reinstalled for the purpose of performing maintenance, no disposition under paragraph (c) of this section is required if--

(1) The life status of the part has not changed;
(2) The removal and reinstallation is performed on the same serial numbered product; and
(3) That product does not accumulate time in service while the part is removed.

(c) Disposition of parts removed from type-certificated products. Except as provided in paragraph (b) of this section, after April 15, 2002 each person who removes a life-limited part from a type-certificated product must ensure that the part is controlled using one of the methods in this paragraph. The method must deter the installation of the part after it has reached its life limit.

Acceptable methods include:

(1) Record keeping system. The part may be controlled using a record keeping system that substantiates the part number, serial number, and current life status of the part. Each time the part is removed from a type certificated product, the record must be updated with the current life status. This system may include electronic, paper, or other means of record keeping.
(2) Tag or record attached to part. A tag or other record may be attached to the part. The tag or record must include the part number, serial number, and current life status of the part. Each time the part is removed from a type certificated product, either a new tag or record must be created, or the existing tag or record must be updated with the current life status.
(3) Non-permanent marking. The part may be legibly marked using a non-permanent method showing its current life status. The life status must be updated each time the part is removed from a type certificated product, or if the mark is removed, another method in this section may be used. The mark must be accomplished in accordance with the instructions under Sec. 45.16 of this chapter in order to maintain the integrity of the part.
(4) Permanent marking. The part may be legibly marked using a permanent method showing its current life status. The life status must be updated each time the part is removed from a type certificated product. Unless the part is permanently removed from use on type certificated products, this permanent mark must be accomplished in accordance with the instructions under Sec. 45.16 of this chapter in order to maintain the integrity of the part.
(5) Segregation. The part may be segregated using methods that deter its installation on a type-certificated product. These methods must include, at least--

(i) Maintaining a record of the part number, serial number, and current life status, and
(ii) Ensuring the part is physically stored separately from parts that are currently eligible for installation.

(6) Mutilation. The part may be mutilated to deter its installation in a type certificated produce. The mutilation must render the part beyond repair and incapable of being reworked to appear to be airworthy.
(7) Other methods. Any other method approved or accepted by the FAA.

(d) Transfer of life-limited parts. Each person who removes a life-limited part from a type certificated product and later sells or otherwise transfers that part must transfer with the part the mark, tag, or other record used to comply with this section, unless the part is mutilated before it is sold or transferred.

 


(For Current Regulation Click HERE!)

(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with Part 91, 125, Sec. 135.411(a)(1), or Sec. 135.419 shall make an entry in the maintenance record of that equipment containing the following information:

(1) The type of inspection and a brief description of the extent of the inspection.
(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 or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.
(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement--"I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition."
(5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement--"I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator."
(6) For progressive inspections, the following or a similarly worded statement--"I certify that in accordance with a progressive inspection program, a routine inspection of (identify whether aircraft or components) and a detailed inspection of (identify components) were performed and the (aircraft or components) are (approved or disapproved) for return to service." If disapproved, the entry will further state "and a list of discrepancies and unairworthy items dated (date) has been provided to the aircraft owner or operator."
(7) If an inspection is conducted under an inspection program provided for in Part 91, 125, or Sec. 135.411(a)(1), the entry must identify the inspection program, that part of the inspection program accomplished, and contain a statement that the inspection was performed in accordance with the inspections and procedures for that particular program.

(b) Listing of discrepancies and placards. If the person performing any inspection required by Part 91 or 125 or Sec. 135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicable type certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that persons must give the owner or lessee a signed and dated list of those discrepancies. For those items permitted to be inoperative under Sec. 91.213(d)(2) of this chapter, that person shall place a placard, that meets the aircraft's airworthiness certification regulations, on each inoperative instrument and the cockpit control of each item of inoperative equipment, marking it "Inoperative," and shall add the items to the signed and dated list of discrepancies given to the owner or lessee.

 


(For Current Regulation Click HERE!)

(a) General. Each person performing an inspection required by Part 91, 125, or 135 of this chapter, shall--

(1) Perform the inspection so as to determine whether the aircraft, or portion(s) thereof under inspection, meets all applicable airworthiness requirements; and
(2) If the inspection is one provided for in Part 125, 135, or Sec. 91.409(e) of this chapter, perform the inspection in accordance with the instructions and procedures set forth in the inspection program for the aircraft being inspected.

(b) Rotorcraft. Each person performing an inspection required by Part 91 on a rotorcraft shall inspect the following systems in accordance with the maintenance manual or Instructions for Continued Airworthiness of the manufacturer concerned:

(1) The drive shafts or similar systems.
(2) The main rotor transmission gear box for obvious defects.
(3) The main rotor and center section (or the equivalent area).
(4) The auxiliary rotor on helicopters.

(c) Annual and 100-hour inspections.

(1) Each person performing an annual or 100-hour inspection shall use a checklist while performing the inspection. The checklist may be of the person's own design, one provided by the manufacturer of the equipment being inspected or one obtained from another source. This checklist must include the scope and detail of the items contained in appendix D to this part and paragraph (b) of this section.

(2) Each person approving a reciprocating-engine-powered aircraft for return to service after an annual or 100-hour inspection shall, before that approval, run the aircraft engine or engines to determine satisfactory performance in accordance with the manufacturer's recommendations of--

(i) Power output (static and idle r.p.m.);
(ii) Magnetos;
(iii) Fuel and oil pressure; and
(iv) Cylinder and oil temperature.

(3) Each person approving a turbine-engine-powered aircraft for return to service after an annual, 100-hour, or progressive inspection shall, before that approval, run the aircraft engine or engines to determine satisfactory performance in accordance with the manufacturer's recommendations.

(d) Progressive inspection.

(1) Each person performing a progressive inspection shall, at the start of a progressive inspection system, inspect the aircraft completely. After this initial inspection, routine and detailed inspections must be conducted as prescribed in the progressive inspection schedule. Routine inspections consist of visual examination or check of the appliances, the aircraft, and its components and systems, insofar as practicable without disassembly. Detailed inspections consist of a thorough examination of the appliances, the aircraft, and its components and systems, with such disassembly as is necessary. For the purposes of this subparagraph, the overhaul of a component or system is considered to be a detailed inspection.

(2) If the aircraft is away from the station where inspections are normally conducted, an appropriately rated mechanic, a certificated repair station, or the manufacturer of the aircraft may perform inspections in accordance with the procedures and using the forms of the person who would otherwise perform the inspection.

 


(For Current Regulation Click HERE!)

a) Except for work performed in accordance with 91.411 and 91.413, each registered owner of operator shall keep the following records for the periods specified in paragraph (b) of this section:

1) . . . The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.

2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
(iv) 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.
(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, 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.]
(vi) Copies of the forms prescribed by Sec. 43.9(a) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.


(b) The owner or operator shall retain the following records for the periods prescribed:

(1) 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.
(2) 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.
(3) A list of defects furnished to a registered owner or operator under Sec. 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

(c) The owner or operator shall make all maintenance records required to be kept by this section available for inspection by the Administrator or any authorized representative of the National Transportation Safety Board (NTSB). In addition, the owner or operator shall present Form 337 described in paragraph (d) of this section for inspection upon request of any law enforcement officer.

(d) When a fuel tank is installed within the passenger compartment or a baggage compartment pursuant to Part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner or operator.

 


(For Current Regulation Click HERE!)

(a) A certificated repair station must retain records in English that demonstrate compliance with the requirements of Part 43. The records must be retained in a format acceptable to the FAA.

(b) A certificated repair station must provide a copy of the maintenance release to the owner or operator of the article on which the maintenance, preventive maintenance, or alteration was performed.

(c) A certificated repair station must retain the records required by this section for at least 2 years from the date the article was approved for return to service.

(d) A certificated repair station must make all required records available for inspection by the FAA and the National Transportation Safety Board.

 



If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

 


(For Current Regulation Click HERE!)

Each AD issued is an actual amendment to FAR Part 39.   An AD is issued when it is found that an unsafe condition exists in a product, and the condition is likely to exist or develop in other products of the same design.

Responsibility:  The Owner/Operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with ADs The Owner/Operator is also responsible for ensuring that properly certificated person perform the work. Maintenance personnel have the responsibility of compliance at the time they are performing inspections to determine all airworthiness requirements are met.

Records:  The owner must keep a record showing the current status of 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/or the date when the next action is required for a recurring AD.

 



Shift Turnover is the transfer of critical information between work groups or shifts. It needs to be as detailed as necessary, depending on the tasks involved. It is the sharing of information by the people doing the task. Data show that poor shift/task turnover is a common contributing factor to events. 
  
NTSB Finding related to one accident caused by improper Shift turnover have been “Departures from approved procedures included failures to solicit and 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 

Challenges related to shift turnover include:

  • A high demand for teamwork and interpersonal communication skills
  • The need for structured and standardized policies and procedures
  • Using a location that is not conducive for discussion and planning
  • Ineffective verbal and written communication
  • Finishing workers are tired and want to depart facility
  • Lack of adequate shift overlap to provide time to give one-on-one briefings between the team leaving and the team coming on
  • Absence of a process to ensure departing personnel have documented all tasks accomplished or started
  • Minimal training on procedures for shift/task turnover

  
Best practices to implement a Shift/Task Turnover process may include:

  • Create and instill standard policies, procedures, and protocol
  • Formalize policy and procedures that make the turnover as important as the work
  • Develop, improve, and implement policies and procedures
  • Communicate policy and procedures to all personnel
  • Consider technology enhancements that improve the transfer of visual information (e.g., photos, graphics, and movies)
  • Provide a time and place for formal shift/task turnover
  • Ensure the quality of shift/task turnover Information
  • Deliver initial and recurrent training on how to conduct a good shift/task turnover
  • Define acceptable communication practices

  
Common problems have been:

  • No documentation
  • Inadequate description of work performed
  • Citing the wrong maintenance manual reference
  • Poor shift turnovers


Easy solutions:

  • Follow the rules
  • Follow company procedures
  • Use of the Maintenance Personal Minimums Checklist

 



This checklist contains 10 questions you should ask yourself and honestly answer BEFORE you do a task.

  • Do I have the knowledge to perform the task? 
  • Do I have the technical data to perform the task? 
  • Have I performed the task previously? 
  • Do I have the proper tools and equipment to perform the task? 
  • Have I had the proper training to support the job task? 
  • Am I mentally prepared to perform the job task? 
  • Am I physically prepared to perform the task? 
  • Have I taken the proper safety precautions to perform the task? 
  • Do I have the resources available to perform the task? 
  • Have I researched the FAR’s to ensure compliance?

 



This Checklist contains 10 questions you should ask yourself and honestly answer at the completion of task.

  • Did I perform the job task to the best of my ability?
  • Was the job or task performed equal to the original?
  • Was the job task performed in accordance with appropriate data?
  • Did I use all the methods, techniques, and practices acceptable to the industry?
  • Did I perform the job or task without pressure, stress, and distractions?
  • Did I re-inspect my work or have someone inspect my work before return to service?
  • Did I make the proper record entries for the work performed?
  • Did I perform the operational checks after the work was completed?
  • Am I willing to sign on the bottom line for the work performed?
  • Am I willing to fly in the aircraft once it is approved for return to service?

 


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