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EASA Aircraft Technical Records Foundation
What are Aircraft Technical Records?
At first it might seem obvious. They are the records, which demonstrate the maintenance performed on an aircraft. However, as we dig a little deeper we uncover a set of rules and regulations which describe exactly what we mean by both Aircraft Technical Records as well as Aircraft Continuing Airworthiness Records.
The regulatory rules, which we must follow, prescribe not just what we should look after, but also for how long we need to retain the records. In addition, they stress the need to maintain the records in a safe and secure manner.
According to a description provided by EASA, Technical Records are the means to assess the airworthiness status of a product and its components. Incomplete technical records may lead to a wrong assessment of safety risk.
It is of paramount importance that we maintain our Aircraft Technical Records to the highest possible standard. Poor or missing Technical Records may devalue an aircraft or compromise its certificate of airworthiness, so it is important to understand the basic requirements and obligations of Aircraft Technical Records Management. Let’s not underestimate the importance of the technical records, without documentary evidence supporting the airworthiness status of the aircraft it would simply not be allowed to fly. The retention period is different for different records and we need to be able to clearly identify which records we are referring to and for how long they should be kept.
Typically Part M Requirements relate to Continuing Airworthiness Records and Aircraft Records primarily relate to Part 145 Technical Records.
However, there are differences to be discussed and in addition there are other Aircraft Technical Records, which are relevant to either the Part M Organisation or the Part 145 Organisation.
Technical Records Administrators are typically members of the Continuing Airworthiness Management Organisation (CAMO) within a PART M organisation or as a member of the 145 Engineering and Documentation Team.
Continuing Airworthiness Records (CAR) typically include:
- The Status of Airworthiness Directives (AD’s);
- The Status of Service Bulletins (SB’s);
- Certificates of Release to Service;
- The Aircraft Technical Logs are considered as continuing airworthiness records but only for a period of 3 years;
- The Modification Status of the Aircraft;
- Life-limited Parts (components which must be removed at a certain frequency typically cycles or aircraft hours);
- A record of Airworthiness Reviews also form part of the continuing airworthiness records;
- The aircraft repair history going back to birth (delivery).
CARs include the recording of all the hours, cycles, and landings of the aircraft and engine and propeller log books.
In addition, it provides for evidence that the maintenance which must be performed on the aircraft has in fact been performed and that in respect of each maintenance check there is a Certificate of Release to Service (CRS).
What other Aircraft Technical records are available?
Well, not all records are considered essential for continuing airworthiness and in fact in accordance with European Aviation Safety Agency (EASA), it is actually permissible to dispose of some records. These records have a specified retention period after which they are not considered necessary by EASA – however, there may be other reasons to maintain such records, so make sure it is the organisation's policy to dispose of these records.
Ideally a procedure should be developed to manage the records, so that a consistent approach will be evident.
Note that EASA regulations concerning disposal are by no means an instruction and, ultimately, it is the decision of the Aircraft Maintenance Organisation (AMO) or the Continuing Airworthiness Management Organisation (CAMO) what to do.
Log Books
The Aircraft Airframe Log Book, Engine Log Book, APU Log Book, and Propeller Log Book are all form part of the continuing airworthiness records and are kept during the whole life of the aircraft (providing in the case of the engines that they are fitted to the aircraft).
The Aircraft Technical Log Book (which is mandatory for Commercial Air Transport Aircraft ) is not considered in the same way and is managed using different rules.
For example, the Aircraft Technical Log Book as opposed to the Airframe Technical Log Book (which is a different document) may be discarded after 3 years. Such practice may not be the policy of the organisation, however.
What about the responsibility of the EASA145 Organisation?
In fact, the EASA Part 145 Organisation must ensure that the Continuing Airworthiness Records (CAW) are passed to the CAMO to enable entering into the Technical records within the time limit of 30 days.
For details regarding the EASA Aircraft Technical Records Foundation course (or any other training) please email: office@sassofia.com or join us online at SofemaOnline.com.
