Problems Created by Missing Aircraft Records and Documents

Aircraft records and documentation may only be considered of paramount importance a few times during the life of an aircraft. But during those few times, for some individuals, they will probably be viewed with the weight of life or death; particularly for the individual who was last responsible for the maintenance records. These occasions of importance usually occur during a Prepurchase Inspection at the time of sale of the aircraft, at return to the Bank at the end of a lease, during an FAA audit or during a conformity inspection for FAR Part 135 compliance.

When selling an aircraft, if there are missing maintenance documents and records it will diminish the perceived value of the aircraft to the buyer and increase the cost of the transaction to the seller. Missing documentation at the end of a lease will be costly to the Lessee. The Lessee is responsible for the care, custody and control of all documentation transferred to them at the onset of the lease. The Lessee is also responsible for the updating of any maintenance log books, documentation and manuals used in the maintenance of the aircraft during the lease period. Undocumented maintenance and inspection functions could require the function to be recompiled with and any missing time controlled component documents could result in replacement of the affected component.

The complications associated with missing documentation can be numerous. Inspections, component certifications, engineering data, burn certifications, Airworthiness Directive compliance and Service Bulletin compliance, etc., cannot be recreated without substantiating evidence. It can be impossible to recreate records if the Certified Repair Station is unknown, out of business or has destroyed the records. 14 CFR 145.219 only requires a Certified Repair Station to retain records for a minimum of 2 years. Electronic document storage has certainly made it much easier to retrieve many archived documents, but if the missing information is several years old, it could be permanently lost.

In the eyes of the FAA, computerized tracking records alone for Time Controlled Components or an Inspection function are not adequate; if there are not certification documents in the records to substantiate the event, the component is un-airworthy or the inspection was not complied with. In the instance of a component, the component would require replacement if the documentation could not be located or reproduced. An inspection without a proper log entry or work order to prove compliance, would be required to be performed again. These items are a critical part of the pre-buy or conformity process of an aircraft and can result in significant, unnecessary cost.

Some examples and resulting consequences of missing documentation include:

An unsubstantiated modification or repair could result in being required to perform a conformity inspection of the work to confirm it was performed per standard practices and approved data. This could include rework of the modification or repair.
An incomplete burn certification could result in being required to re-perform the burn test of materials, if possible. It could also require seats to be recovered or the replacement of fabrics and woodwork.
A missing inspection entry may result in the requirement to re-comply with an entire inspection.
A missing component certification may require replacement of the affected component. Missing component documents could also result in a warranty claim being denied.
A missing Instruction for Continued Airworthiness (ICA) would indicate the Inspection Program requirements are not complete. In addition, inspection requirements may be over due.

Depending on the circumstances, any of the examples mentioned above could result in unnecessary cost to the aircraft owner or lessee, may diminish the interest of a buyer and could tarnish the reputation of a good flight department. Missing documentation may even kill a sales transaction.

If a log entry references a Work Order for details of what work was completed, the operator must ensure a copy of that work order is maintained in the historical records. After two years, the work order may no longer be available from the facility that performed the work.

An operator should keep separate files of currently installed Time Controlled Components documents, Burn Certifications for interior materials and any Instructions for Continued Airworthiness (ICA) referenced on Major Repairs & Alterations Form 337. The operator must also make sure that all requirements of the ICAs are included in the aircraft inspection program and appropriately tracked. An operator should also ensure all Time Controlled Component certification documents are scanned into the aircraft’s computerized maintenance tracking program.

While technically not considered maintenance documents or records, some Aircraft Flight Manual (AFM) Supplements are linked to modifications recorded on Major Repair & Alteration Form 337s. All the AFM Supplements referenced on any form 337 must be included in the AFM Supplement file. This file may be the last section in the AFM or may be held in a separate binder kept onboard the aircraft. These Supplements must be guarded and protected. An AFM Supplement for an old STC may be very difficult, if not impossible to find. The AFM Supplement is part of the overall legal documentation of a system modification and its operation. A system or its modification is not complete and airworthy if a required AFM Supplement is missing. If an AFM Supplement is discovered missing during an FAA ramp inspection, the Captain and the Operator could face a violation and the airworthiness of the aircraft could come into question. In addition to an index for the Form 337 file, an operator should maintain an index of all AFM Supplements referenced on the 337s. This will allow for easy periodic audits of the AFM by the Operator. And remember, if a system is modified or removed from the aircraft, remove any associated Supplement from the AFM if it is no longer applicable.

Always be prepared for the sale, end of lease evaluation or an FAA audit of your aircraft and records. Don’t pay twice for a part or inspection you already paid for. It is always harder to mine and produce information when you are under the pressure of an audit or conformity inspection. Well organized records allow for quick, easy access to critical information, will impresses the FAA with the professionalism of your operation and will contribute to the overall perception of the value of the aircraft.

To the extent as reasonably possible, electronically back up aircraft historical maintenance records and documents. When accomplished using the latest generation of storage programs, you will not only have provided protection for the records, you will also have the ability to securely access these records for reference from any computer in the world.

An ounce of prevention can save a pound of cure. Historical maintenance records not only substantiate the legal airworthiness of the aircraft, they support the market value of the aircraft. Make sure you protect the investment. Be prepared and ready at all times. Have all historical information organized and easily retrievable on demand.

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