AD Compliance Recordkeeping

[SoCal 182 Driver]

Friends -

Every annual I receive a 16-page print-out verifying compliance with Airworthiness Directives. As the owner of the aircraft, is it sufficient for me to keep a scanned (and backed-up) electronic copy of these records in the maintenance directory for the aircraft, or do I have to keep the actual paper print-out?

Thanks!

 

[flyingron]

There's no strict requirement for any paper records, but it's handy to keep one. The Airworthiness Directive status list under 91.417 isn't even something that requires a signature, it's just a list of ADs and times.

 

[Bell206]

do I have to keep the actual paper print-out?

Are there pen and ink mechanic signatures on the list?

 

[SoCal 182 Driver]

There's no strict requirement for any paper records, but it's handy to keep one. The Airworthiness Directive status list under 91.417 isn't even something that requires a signature, it's just a list of ADs and times.

So if I have a scanned copy that can be printed if necessary in case I need it handy, that would be OK. Excellent. Thank you, Ron.

Are there pen and ink mechanic signatures on the list?

There are signatures, but it appears I have a copy and the mechanic has the originals. I looked carefully at the signatures, and I don't see any indentations...like a pen would make.

 

[Bell206]

There are signatures, but it appears I have a copy and the mechanic has the originals.

If you are talking 91.417 then you need the originals for the ADs unless there is a separate signed entry in your logbooks for each applicable AD. While the FAA is moving toward digital signatures/copies, the Part 43.9/11 and 91.417 requirement for records requiring an A&P signature are an outlier. The guidance basically states that as owner you have to show any digital/copied maintenance signature can not be altered from the original or risk having that digital signature invalided, which by extension invalidates your AWC. It's a goat rope at best. But until there is solid guidance accepting copies of maintenance signatures, you are best to keep the original hardcopy signature for those 91.417 requirements and for the appropriate length of time.

 

[Magman]

My experience had been that many owners do not realize just how important some of these Records are. Often “superseded” docs contain info like” p/n xyz” or “per method b” etc. Suggest you keep this in a Superceded File just in case. There are times when trying to match compliance with a Rev 4 AD and the original AD is not easy.

I’m not into digital yet so I hope this comment is not out of place.
My practice is to put all RECURRENT ADs on one sheet of paper. Easy to identify.
If the aircraft has an AD overflown a new sheet is generated and the old “tossed”.
This can be significant on a Accident or incident as now you are showing Current Compliance only. “Volunteering “ an overfly is not good.

Suggested by FSDO.

 

[flyingron]

This stuff all goes in the MAINTENANCE records, not in the plane. The limit of what I have to show an inspector at a Ramp Check are my docs (Airworthiness Certificate, Registration) and the various fight manual supplements (w&b, and the stuff for the STCs).

Inspections and AD compliance he's going to have to take my word for (or arrange a time when I can produce my records from the safe in my home).

 

[Magman]

Note I altered #6 by changing Ramp Check to accident or incident .

My INTENT has no changed though.

Do not volunteer records of over flights .

 

[flyingron]

I still have the package I made up for the FAA over my accident. They never much looked at the random maintaineance data. It contains scans of:
1. Registration/Airworthines certificate
2. The serial number page and the last page of the engine log
3. The last page of the airframe log
4. My personal statement
5. the last page of my pilot log
6/ my pilot and medical certs.

 

[Randomskylane]

Do not volunteer records of over flights .

over flights?

 

[rotormatic1]

The current status of AD’s required by 14 CFR part 91.417(a)(2)(v) does not require a signature from a properly rated person...

(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.

The status list is based on the method of compliance recorded in the maintenance records I/A/W 14 CFR part 43.9...

 

[Magman]

“Overflight” or flying past the required compliance time for an AD.

Other Ron that flys:

You have a case history of 1 case. ( non-fatal )

Other times it may not go so easy. You are required to show the CURRENT status of all ADs. Why would anyone want to keep records of recurring inspections of ADs that have been superceded many times over? The ASI really doesn’t want to be informed that you went over the required compliance 9 months (or other) ago.
WHY volunteer it?

 

[Silvaire]

I used to use T-Data which, as you noted, prints out about 19 or 20 pages and really is a big waste of paper IMO. These days I just use a simple Excel spreadsheet that lists all applicable AD's with their compliance status, date and certificate number of the person who signed it off, whether it's recurring and next due date. It all fits on a single sheet of paper. The AD compliance list is nothing more than an index reference that will allow you to quickly locate the entry and signature in the appropriate maintenance logbook and as an Excel file the AD number is a hyperlink to the AD text or .pdf on the FAA website.

 

[Magman]

I find updates are easier using Airframe, Engine/Prop , Appliances and Recurrent.

 

[Domenick]

Why do you get a list of all applicable ADs every year? Why not just the new/updated ones over the past year?
Check this out: https://www.adlog.com/

 

[Bell206]

Why do you get a list of all applicable ADs every year? Why not just the new/updated ones over the past year?

Each service does it their own way, but I've found it reduces the chance of missing a revision or a new one if a complete yearly AD search is performed. Even before I started to recommend ADLog, I would print out a complete new AD list every year to review it. Regardless, as for your 91.417 AD record, it falls to whatever the owner wants in the way of records. But having a separate, signed AD listing apart from the logbooks is one method that ensures compliance with 91.417 and one I usually recommended. ADLog just makes it easier.

 

[bradg33]

If you are talking 91.417 then you need the originals for the ADs unless there is a separate signed entry in your logbooks for each applicable AD. While the FAA is moving toward digital signatures/copies, the Part 43.9/11 and 91.417 requirement for records requiring an A&P signature are an outlier. The guidance basically states that as owner you have to show any digital/copied maintenance signature can not be altered from the original or risk having that digital signature invalided, which by extension invalidates your AWC. It's a goat rope at best. But until there is solid guidance accepting copies of maintenance signatures, you are best to keep the original hardcopy signature for those 91.417 requirements and for the appropriate length of time.

A digital signature is not the same as a scanned copy of a manual signature. A scanned copy of a manual signature is always an acceptable "Electronic Signature" under both AC 120-78A and the federal E-Sign Act. A digital signature is, more or less, what's done via Docusign, etc., which do in fact keep very specific records and standards for verification. But that's not necessary for scanned manual signatures.

 

[Bell206]

A scanned copy of a manual signature is always an acceptable "Electronic Signature" under both AC 120-78A

Its only acceptable provided the electronic records follow the requirements in AC120-78. My use of digital was improper and used only to paraphrase the point. While Part 91 aircraft don't require any FAA approvals or acceptability of an electronic records system, i.e., scanned copies, that system must still meet the same requirements as noted below. I've had several discussions with AFS-300 and they were the ones who pointed me in this direction. The maintenance side has been lagging in this and at present has no specific rule to back up "scanned signatures" unless your records systems meets the 120-78, Chapter 3 requirements. Unfortunately, there is no Part 91 only section in this chapter. So at a minimum, unless you want to follow the guidance in Chapter 3, for those records required to be maintained per 91.417, I still recommend owners to maintain the original hardcopies with the original signatures for the prescribed times.

AC120-78, 1-8(e):

 

[SoCal 182 Driver]

OK, so now I'm thoroughly confused.

Scenario: Part 91 aircraft. After the annual, my IA hands me a printed list of ADs with handwritten sign-offs. I scan that document and keep it on my computer. If the records are ever requested, is the scanned copy of the document sufficient under the appropriate FAA standards.

Thanks!

 

[bradg33]

OK, so now I'm thoroughly confused.

Scenario: Part 91 aircraft. After the annual, my IA hands me a printed list of ADs with handwritten sign-offs. I scan that document and keep it on my computer. If the records are ever requested, is the scanned copy of the document sufficient under the appropriate FAA standards.

Thanks!

I'd certainly argue yes, that's sufficient. AC 120-78A aside, the federal E-Sign act makes pretty clear that a scanned copy is fine. That said, even if it doesn't "meet" the convoluted standards in AC 120-78A, that doesn't render it invalid. It just means that FAA "may" question its validity. If the FAA questions its validity, it's pretty darn easy to prove it is in fact valid. Testimony from your A&P or the production of the original (which it sounds like you plan to keep anyway) resolves that question.

 

[Bell206]

If the records are ever requested, is the scanned copy of the document sufficient under the appropriate FAA standards.

the production of the original (which it sounds like you plan to keep anyway) resolves that question.

If you are keeping the originals then the whole exercise is moot. But the reason I only push the 91.417 requirements is there are other rules that can come into play like 91.419. If you sell your airplane its up to the purchaser whether they will accept electronic records as noted below. It is further defined as a records system that is in a manner acceptable to the Administrator. Which I've been informed is a 120-78 system. But I'm just the messenger here. I've been up and down this topic with a number of people especially on the helicopter side where the aircraft records fill boxes. Would make my day to trade all those boxes for one flash drive. Outside of 91.417/419 scan to your hearts content, but unless you want to ensure there will be zero validity issues with those other signatures, I'd keep the 91.417 originals.

 

[Silvaire]

In regards to AD's if it is applicable and action is taken to comply then there is going to be a signed entry in the logbook. You don't need a separate signed paper and if the AD is not applicable due to time, date, part number, serial number, model or whatever else you don't need any indication of compliance. Generally when an IA makes an AD compliance list they will often include the N/A's with the reason just as a reminder to themselves or a courtesy for those who follow.

 

[Magman]

Entries must be in the Aircraft Records .
Not necessarily a logbook.

Separate sheets allow say revision and disposal of superceded data.

I try to show the status of each AD as to why it does or does not apply.
Always nice to see someone else did the same.