Aircraft maintenance records a flight school has to keep
There are two lists in 14 CFR 91.417 and they have very different lifespans. One can be thrown away after a year. The other follows the aeroplane until somebody scraps it, and goes with it when you sell. Knowing which is which is most of the job.
What has to exist
The maintenance record entry itself
§ 43.9(a)A description of the work, the date it was completed, the name of the person who did it, and the signature, certificate number and kind of certificate held by the person approving the aircraft for return to service. The kind of certificate is the field most often left off, and it is the one that separates an A&P from an IA.
Records you may discard after a year
§ 91.417(a)(1)Records of maintenance, preventive maintenance, alterations and 100 hour, annual and progressive inspections. These may be discarded once the work is repeated or superseded, or after one year.
Records you keep for the life of the aircraft
§ 91.417(a)(2)Total time in service of the airframe, each engine, each propeller and each rotor. The current status of life-limited parts. Time since last overhaul of anything overhauled on a time basis. The current inspection status. The current status of applicable Airworthiness Directives, with the method of compliance, the AD number and the revision date, plus the next action for a recurring one. And a copy of the form for each major alteration.
The inspection entry
§ 43.11(a)For an annual, 100 hour or progressive inspection: the type and extent of the inspection, the date and the aircraft total time in service, the signature and certificate details, and the certification wording. Where the aircraft is not approved for return to service, a signed and dated list of the discrepancies and unairworthy items goes to the owner.
A tracking system is not a logbook
This is the distinction worth being pedantic about, because every maintenance tracking product blurs it and a school that believes the blur has a gap where its records should be.
A tracking system counts down what is due, warns you before it lapses, and keeps its own record of what was signed off in it. The maintenance record entry required by 43.9 and the inspection entry required by 43.11 are documents a certificated person makes, and no software makes them for you. AerScheduler puts that sentence directly above the signature on the sign-off screen, where somebody about to sign will actually read it.
The status question, and why it is harder than it looks
91.417(a)(2)(v) asks for the current status of applicable Airworthiness Directives. That word is doing a lot of work. A log of what you signed off is not the same as a status against everything that applies, because the second requires knowing what applies, which is a determination made by a certificated person against a serial number.
It is the single most common gap in a flight school's records, and it is worth checking who at your school owns it. Airworthiness Directive tracking goes through the split in detail.
Related
Calendar months and due dates covers the intervals these inspections run on. Maintenance and squawks is the product side. Flight training records is the same question for people rather than aeroplanes.
Questions
- What aircraft maintenance records does a flight school have to keep?
- Two lists, and the difference between them matters. 14 CFR 91.417(a)(1) covers records of maintenance and inspections, which may be discarded once the work is repeated or superseded, or after a year. 91.417(a)(2) covers a shorter list kept for the life of the aircraft: total time in service, life-limited part status, time since overhaul, current inspection status, current Airworthiness Directive status, and major alteration forms.
- Which records transfer when the aircraft is sold?
- The 91.417(a)(2) records. 91.417(b)(2) requires them to be retained and transferred with the aircraft at the time it is sold. That is the practical reason to keep them in a form somebody can hand over as a set rather than reconstruct from a filing cabinet.
- Is a maintenance tracking system the same as a logbook?
- No, and any tracking product that lets you think so is doing you harm. A tracking system tells you what is due and keeps a record of what you signed off in it. The maintenance record entry required by 14 CFR 43.9, and the inspection entry required by 43.11, are separate documents that a certificated person makes. AerScheduler says this above the signature on the sign-off screen rather than in a help article nobody opens.
- What is time in service, exactly?
- 14 CFR 1.1 defines it as the time from the moment the aircraft leaves the surface until it touches down at the next point of landing. It is not Hobbs and it is not tach. A Hobbs runs on master or oil pressure and includes taxi and runup; a tach is proportional to engine RPM. Both are useful and neither is time in service, so a record that captures a meter reading should say which meter rather than implying it is time in service.
- Why record both Hobbs and tach on a sign-off?
- Because a record naming one clock is hard to read later for somebody working off the other, and the aircraft is in front of the mechanic now and will not be later. It costs nothing to capture both at the moment of the work, and it makes the record legible for the life of the airframe.
- Can a maintenance record be edited afterwards?
- In AerScheduler, a signed compliance record cannot be edited or deleted by anybody, including us. A mistake is corrected by adding another record that supersedes it, and the original stays readable. Records are evidence, and evidence that can be quietly changed is worth less than none.
- How long do we have to keep them?
- The 91.417(a)(1) group until the work is repeated or superseded, or one year. The 91.417(a)(2) group for the life of the aircraft, and then they go with it when it is sold. In practice most schools keep everything, because storage is cheap and reconstructing a discarded record is not possible.
See what your fleet owes
14 days, no card. Add an aeroplane, apply the standard airworthiness set, and the countdown starts from the dates you already have.