U.S.Defxlmmt of Wanspoctation FMHdAvktkn AdmMsttatkrr Advisory Circular RECORDS D91t: Initintcd by: 6/8/98 AFS-340 AC No: Change: 43-9<3 subjm: MAINTENANCE This advisory circular (AC) describesmethods, proceduresand practices that have been determined to be acceptablemeans of showing compliance with the general aviation maintenancerecord making and record keeping requirements of Title 14 of the Code of Federal Regulations ( 14 CFR) parts 43 and 9 1. This material is not mandatory, nor is it reg]ulatoryand acknowledgesthat the Federal Aviation Administration (FAA) will consider other methods that may be presented. It is issued for guidancepurposesand outlines several methods of compliance with the regulations. 1. PURPOSE. NOTE: The information in this AC does not apply to air carrier maintenance records made and retained in accordance with 14 CFR part 121. 2. CANCELLATION. 3. RELATED AC 43-9B, Maintenance Records, dated January 9, 1984, is canceled. 14 CFR parts 1,43,9 1, and 145. REGULATIONS. 4. DISCUSSION. The Code of Federal Regulations state that a U.S. standard airworthiness certificate is effective until it is surrendered, suspended,revoked, or a termination date is otherwise establishedby the Administrator. In addition to those terms, a U.S. standard ainvorthiness certificate is effective only as long as the maintenance,preventive maintenance, and:alterations are performed in accordancewith parts 43 and 9 1, and the aircraft are registered in the united States. Theseterms and conditions are further restated, in block 6, on the front of F& Form 8 100-2, StandardAirworthiness Certificate. Qualified persons,who perform the maintenance, preventive maintenanceand alterations, shall make a record entry of this accomplishment, thus maintaining the validity of the certificate of airworthiness. Adequate aircraft records provide tangible evidence that the aircraft complies with the appropriate airworthiness requirements. In accordancewith the terms and conditions listed in block 6 of the Standard Airworthiness Certificate, insuEcient or non-existent aircraft records may render that standard airworthiness certificate invalid. work orders. Section 9 1. provides for signature entry. Requires a record of maintenance.417(a) contains an exception regarding work accomplished in accordance with section 91. is intelligible. may be I / Page!2 Par5 .for each aircraft (including the airfiime) and each engine. Responsibilities.417(a)(1) through 9 1.417 states that an aircraft owner/operator shall. and applianceof an aircraft.9 and 43.oved inspectionsto be retained until the work is repeated.417(a)(l). d. and.417(a)(1) has no cuJnterpart in section 43. specified in section 91. The exclusion is necessary since the retention period of one year is inconsistent with the 24-month interval of test and inspection specified in section 91. MAINTENANCE RECORD REQUIREMENTS.on9 1.9 or section 43. includes required contents. or how it was done.11 state’that maintenancepersonnel. It also requires the records. and the methods and procedures used in doink it.keep and maintain aircraft maintenancerecords. Maintenance Records That Are to Be Retained. section 9 1. the rule permits reference to technical data acceptableto the Administrator in lieu of making the detailed entry. c: Section 91. many owners and operators find it advantageousto keep separateor individual records since it facilitates transfer of the record with the item when ownership changes. When the work is extensive. Manufacturer’s manuals. sections43.supersededby other work. and required or app.11. Entries for work done per this section are to be retained for 24 months or until the work is repeated or superseded.AC 43-9C 6/8/98 5. which accurately describe what was done. As a practical matter. Section 91.405 requires each owner or operator to ensurethat maintenancepersonnel make appropriate entries in the maintenance recoi-dsto indicate that the aircraft has been approved for return to service. 14 CFR part 9 1. / NOTE: Section 91. and others. Requires the maintenancerecord entry to include “a description of the work performed.417(b) requires records of maintenance. This does not exclude the making of entries for this work. or for one year. Section 9 1.417(a)(l)(i). This does not require separateor individual records for each of these items. service letters. lends itself to the addition of new entries.417(a)(2). It does require the information specified in settions 9 1. zi. but applies to the retention period of the records for work done in accordance with this section. FAA AC’s.411. b. To provide for this contingency.” The description should be in sufficient detail to permit a person unfapiliar with the work to understandwhat was done. Maintenance records may be kept in any format that provides record continuity.411. rotor. propeller.417(a)(2)(vi) to be kept for each item as appropriate. Secti. 14 CFR part 43. to be retained and trandferred with the aircraft at the time of sale. Section 9 1.however.417(a) sets forth the content requirements and retention requirements for maintenancerecords. this results in a voluminous record.alterations. bulletins. are required to make the record entries. The work order copy must include the information. The six items are discussedas follows: (1) Section 91. Requires six items to be made a part of the maintenancerecord and maintained as such.AC 43-9c referenced. This is normally the date upon which the work is approved for return to service. in lieu of maintenance record entries. which are in common usage. Is identical to section 43. and each propeller. and retained per section 91. Part 1. with respect to maintenancetime records.417(a)(l)(i) is identical to its counterpart. Two signatures may also appearunder this circumstance.417(a)(2)(i). This procedure is not the same as that for maintenance releasesdiscussed in paragraph 16.417(a)(l)(iii).1. which assistsowners and operators in meeting their responsibilities. defines time in service.9(a)(l). and does not require the type of certificate being exercised to be indicated as does section 43.417(a)(2). I I!e. Page 3 . however. a single entry in accordancewith section 43. Differs slightly from section 43. Definitions. Requires a record of total time-in-service to be kept for the airframe. section 43. f. However. To provide for this situation. _ g. Section 43. as that time from the moment an aircraft leavesthe surface of the earth until it touches down at the next point of landing.9(a)(2) and requires entries to contain the date the work was completed. Except for the documents mentioned. Section 91. but they are all the responsibility of the owner or operator.9(a)(4). or alterations. the dates may differ.11 requires some of them to be part of entries made for inspections. rebuilding. Section 43. Maintenance personnel may indicate the type of certificate exercisedby using airframe (A). required by section 91. Section 91. section 1.9(a)(4).9(a)(3) is acceptable. powerplant (P).417(b). However.417(a)(l)(ii). inspection authorization (IA).417(a)(l) through section 91.417(b). which imposes the same requirements on maintenance personnel. b e made a part of the maintenance record.9(a)(4) in that it requires the entry to indicate only the signature and certificate number of the person approving the work for return to service. and it may not be used when maintenance records are available.11 requires maintenancepersonnel to make it a part of the entries for inspections made under parts 9 1. airframe & powerplant (A&P). when work is accomplishedby one person and approved for return to service by another. Section 91.preventive maintenance. 125. and time-in-service in all entries.9 does not require this to be part of the entries for maintenance. This is a new requirement of section 43. repair stations should supply owners and operators with copies of work orders written for the work. each engine. Section 43. Section 91.9 does not require maintenancepersonnel to enter these items.referenced documents are to be made a part of the maintenancerecords and retained in accordancewith section 9 1. or certificated repair station (CRS). NOTE: Certificated repair stations frequently work on components shipped to them without the maintenance records.417(a)(l)(iii). section 43. presently in-service.. and revision date. is entered in the record when a life-limited part is installed and the time-in-ser. subsequentto the rebuild.41?(a)(2)(i).417(a)(2)(ii). the normal record of time-in-service automatically meets this requirement. propeller.417(a)(2) are to be kept with the module. time-in-service may be kept since last complete overhaul..417(a)@)(iv). at minimum. the imaintenancerecord and time-in-service. engine.practicable procedures for compliance with the record reqmrements must be used. Neither of these proceduresis acceptablewhen life-limited parts status is involved or when airworthiness directive (AD) compliance is a factor. If owners and operators wish to take advantageof this modular design. were put into service before the requirements to keep maintenancerecords on them. (b) Many components. the explanation in paragraph 5g (2) is appropriate even though section 43.421 permits the maintenancerecord to be discontinued and the engine time to be started at zero. (c) Sometimes enginesare assembledfrcm modules (turbojet and some turbopropeller engines) and a true total time-in-service for the total engine is not kept. total time-in-service may be derived using the procedures described in paragraph 12. then total time-in-service and a maintenancerecord for each module is to be maintained.the owner or opera!or would not have a way of knowing the total time-in-service. (4) Section 91. in the caseof rebuilt engines. Requires the maintenancerecord to indicate the time since last overhaul of all items installed on the aircraft that are required to be overhauled on a specified time basis. Only the actual record since new may be used in these instances. the AD number. since section 9 1. or if records prior to the regulatory requirements are just not available from any source.417(a)(2)(v). The maintenancerecords specified in section 9 1. Tinerecord is to include.AC 43-9C WV98 (a) Some circumstances impact the owner’s or operator’s ability to comply with section 9 1. j (5) Section 91. The exp!anation in paragraph 5g (2) also applies to this requirement. In these instances. For example. the method used to comply with the AD.417(a)(2)(iii).lce of the lifelimi. and if the AD has requirements for recurring Page 4 . If total time-in-service of the aircraft.11(a)(:!) requires maintenancepersons to determine timein-service of the item being inspected and to include it as part of the inspection entry. etc. Again. I (2) Section 91. For example. In this case. Deals with the current inspection status and requires it to be reflected in the maintenancerecord. Requires the current status of life-limited parts to be part of the maintenancerecord. (3) Section 91. comprise a satisfactory record.ted part is included. Requires the current status of applicable AD’s to be a part of the maintenance record. Propellers are probably foremost in this group. Section 9 1.1. when the service bulletin specifically requestsan entry to be made. The manufacturer or an agency approved by the manufacturer that rebuilds and grants zero time to an engine is required by section 9 1.421 provides that zero time may be granted to an engine that has been rebuilt by a manufacturer or an agency approved by the manufacturer. The type of certificate exercised when maintenanceor preventive maintenanceis accomplishedmust be indicated in the maintenancerecord. PREVENTIVE MAINTENANCE. a. rotor(s). respectively.417(a)(2)(v). the owner/operator may use a new maintenancerecord without regard to previous operating history. AC 43-12. Preventive Maintenance. be made a part of the maintenancerecord. In the past. (6) Section 91. Pilots are not authorized by section 43. Section 43. the time-in-service and the date when that action is required. 6.3(g). b. Part 43. propeller(s). contains further information on this sub-ject. Pilots may only approve for return to service preventive maintenancethat they themselveshave accomplished.421 to provide a signed statement containing: 1) the date the engine was rebuilt.7 authorizes appropriately rated repair stations and mechanics. current edition. commercial pilot (CP). section 1. 127. 2) each changemade. and personsholding at least a private pilot certificate to approve an aircraft for return to service after they have performed preventive maintenance. It now prescribes that copies of FAA Form 337. or air transport pilot (ATP) to indicate private. and 3) each changemade in compliance with service bulletins.3(g) to perform preventive maintenanceon aircraft when they are operated under part 121. maintenancepersonsare required to include the items specified in section 4i. a. REBUILT ENGINE MAINTENANCE RECORDS. the owner or operator has been permitted to maintain a list of current major alterations to the airframe. When this is done. commercial. or airline transport pilot certificate. appendix A. c b.9. or 135. When AD’s are accomplished.417(a)(Z)(vi). issued for the alteration. 7. paragraph (CB lists those items which a pilot may accomplish under section 43. This procedure did not produce a record of value to the owner/operator or to maintenancepersons in determining the continued airworthiness of the alteration since such a record was not sufficient detail. as required by an AD.618198 AC 43-9C action. A!! of these persons must record preventive maintenanceaccomplished in accordancewith the requirements of section 43. This section of the rule has now been changed. in approving preventive maintenance for return to service. An example of a maintenancerecord format for AD compliance is contained in Appendix 1. Preventive maintenanceis defined in part 1. Par5 Page5 . or appliances. 129. Pilots may use private pilot (PP). and (4) in addition to those required by section 91. (3).9(a)(2). engine(s). Otherwise. rotor. etc. Airworthiness Directives for General Aviation Aircraft.421(c). Page 6 Par 7 . reconditioned. These functions are listed in section 43. or appliance is removed. therefore. when the device fails and requires change. do not meet the requirements of section 9 1.AC 43-9C 6/8/98 c. alone. Some owners and operators mistakenly believe these devices may be used in lieu of keeeing time-in-service in the maintenancerecord. owners and operators cannot assumethat the functions outlined in section 43. but is not required. and the loo-hour and annual inspections under section 135. and adherenceis not mandatory. except for testing requirements.2(b) prohibits the use of the term rebuilt in describing work accomplished in required maintenancerecords or forms unlessthe component worked on has had specific work functions accomplished. a.2(b) and. propeller. ensurethat leasesshould be drafted to deal with this subject. I$ The maintenancerecord requirements of section 43.11 apply to the loo-hour. or other terms coined by various aviation enterprises are used in maintenancerecords. Thissubjectiscoveredin AC 39-7. record continuity is lost. are the same as those set forth in section 9 1. and from these conditions provide an indication of time-in-service. MAINTENANCE RECORDS FORADCOMPLIANCE. current edition. shown in Apdendix 1. Such records may also be used as a schedule for recurring inspections. oil pressure. is a suggestedor 0. wheels on the ground. They should. it is necessaryto enter timein-service and the instrument reading at the change. 8. and appliance. For example. propeller. 9.11 contains the requirements for inspection entries. Owners should be aware that they may be responsiblefor nun-compliance with AD’s when their aircraft are leasedto foreign operators. . 10. RECORDINGTACHOMETERS. and progressive inspections under part 91. rotor. The format. annual. the record may be transferred with it. b. Section 43.4 11(a)( 1). mspection programs under parts 91 and 125. Section 43. When terms such as remanufactured. Time-in-service recording devices sensesuch things as electrical power on. This would facilitate record searcheswhen inspection is needed. the indications are approximate.2(b) have been done. A separate AD ‘record may be kept for the airframe and each engine.and when an engine. such instruments.417.405. While these requirements are imposed on maintenancepersonnel. While they are of great assistancein arriving at the time-in-service. ~IAINTENANCERECORDSFORREQUIREDINSPECTIONS. With the exception of those that senseaircraft lift-off and touchdown. approved airplane inspection programs under part 135. a. owners and operators should become familiar with them in order to meet their responsibilities under section 9 1. d. / Par 16 Page7 . I 1. 12. inspectionsunder section 135. c. or section 135.9. that inspections the be complete and that all discrepanciesappear in the list. Section 43. must identify the inspection program used. requires personsapproving or disapproving equipment for return to service. In order to re-construct them.~Appropriately rated mechanicsare authorized to conduct these inspections and make the required entries.ento section 43.lnder section 43.61819a AC 43-9C c. It is imperative. and propellers. When circumstances dictate that an inspe. The entry . 1982.11 requires that a discrepancy Iist be prepared by a person performing any inspection required by parts 91. In addition to other items. however. to make an entry in the record of that equipment. Now. while the annual inspection is only required to be entered into the airframe record.417(b)(3). and contain a statement that the inspect ion was performed in accordancewith the instructions and procedures for that program.41l(a)( 1). the entry of the 100-hour or annual inspection is made in that record. the entry for the loo-hour inspection is entered in each. it is necessaryto establish the total time-in-service of the airframe. As discussedin paragraph 5c. The entry made by maintenancepersonnel in the maintenancerecord should reference the discrepancy list when a list is issued. It is no longer a requirement that copies of discrepancy lists be forwarded to the iocal Flight StandardsDistrict Office (FSDO). the records for an aircraft are lost or destroyed. The entry should meet all the other requirements of section 43. When a discrepancy list is provided to an owner or operator. after any required inspection.1 l(a)(7) in that it now requires a more specific statement than previously required . issuanceof discrepancy lists (or lists of defects) to owners or operators was appropriate only in connection with annual inspections under part 91..411(a)( 1). b.’ Discrepancy lists (or lists of defects) are part of the maintenancerecord and the owner/operator is responsibleto maintain that record in accordancewith section 91. therefore.11. If the owner maintains separaterecords for the airframe.1 1. inspection programs under part i25.ctionbe terminated before it is completed. and inspections under section 91. item inspectedis airworthy. Therefore. neither part 43 nor part 91 requires separaterecords to be kept. LOST OR DESTROYED RECORDS. This can be done by reference to other records that reflect the time-in-service. section 43. when an owner maintains a single record. except for these’discrepancies.. Particular attention should be giv.. identify the portion or segment of the inspection program accomplished. d.217. al’ Before to October 15. Occasionally. it says in effect. Questions continue regarding multiple entries for lOO-hour/annualinspections. I)IsCREPANCY LrsTs. 125. the maintenancerecord should clearly indicate that the inspection was discontinued. pow&plants. the owner/operator may make a notarized statement in the new record describing the loss and establishing the time-in-service basedon the researchand the best estimate of time-in-service. Prospective purchasersof aircraft that have beenused as public aircraft. kJBLIC AIRCR4FT. The aircraft may not be certificated or used without such records. service life limitations. a.and current list of major alterations. Some items may be easier to reestablishthan others.etc.417. If not. AD’s. such as the current status of life-limited parts. and reference to records maintained by indivi&al mechanics. including signatures. . Additionally. The current status of applicable AD’s may present a more formidable problem.9 or 91. or the iimitations section of FAA-approved airplane or rotorcraft fligh’t manuals. When these things have been done and the record is still incomplete. but all are problems.417(a)(2). The owner/operator who usessuch a system is required to ensurethat it provides the information required by section 9 1. Safekeepingof the records is an integral part of a good record keeping system.8 Par 12 . It can readily be seenthat this could entail considerabletime. cycles of operation. Considerableresearchmay be involved in establishingthe required records when these a?craft are purchasedand brought into civil aviation. COMPUTERIZED RECORDS.and in some instances. costly. a! Presentday aircraft and powerplants commonly have life-limited parts installed. Page. 14. Many of these systems are offered to owners/operators on a commercial basis. may apply (See CFR 23 Appendix G and CFR 27 Appendix A). parts retirement limitations. Other items required by section 9 1.417. Losing maintenancerecords can be troublesome. time since last overhaul. which require life-limits be specified. instructions for continued airworthiness. may present difficult problems. current inspection staLus. retirement life limits. 13. life limitations. and time consuming. This may require a detailed inspection by maintenancepersonnelto establish that the applicable AD’s have been complied with. or other such terminology and may be expressedin hours. LIFE-LIMITED PARTS. 15. alone they normally do not meet the requirements of sections 43. They are set forth in type certificate data‘sheets(TCDS).might require recompliance with the AD. expense.417. should be aware that public aircraft may not be subject to the certification and maintenancerequirements in Title 14 of the Code of Federal Regulations and may not have records that meet the requirements of section 9 1. or calendar time.AC 43-9C 6/8/98 research of records maintained by repair facilities. There is a growing trend toward computerized maintenancerecords. modification to make them complete is the owner’s/operator’s responsibility and @at responsibility may not be delegated. These life limits may be referred to as retirement times. b. While these are excellent scheduling systems. . as stated in paragraph 16.. appendix B of part 43. as described.. all of the requirements of section 43. Some repair stations use what they call a maintenancereleasefor other than major repairs.. If a separaterecord is not kept. When this is done. The maintenancereleasemust contain the information specified in paragraph (b)(l). This is sometimes a tag and sometimes information on a work order. on FAA Form 337). 16. however. The maintenancereleaseis usually a special document (normally a tag) and is attached to the product when it is approved for return to’service. b. and retained by the owner/operator as specified in section 9 1. FAA FORM 337. _. date removed.- . and signature and certificate number of the person installing or removing the part. -_. appendix B. The maintenancereleasemay.6/8/98 AC 43-9C b. and (3) a maintenancereleasewhich has been signed by an authorized representative of the company. MAJOR REPAIR AND ALTERATION. This form is executedby the person making the repair or alteration. which allows repair stations certificated under part 145 to use a maintenancereleasein lieu of the form for major repairs (and on.__. Both must be supplied to the customer. be made a part of the aircraft maintenancerecord. A separate record. total time-in-service. That is i Jsay that the Repair Station is re@ired to give the owner: (1) the customers work order upon which the repair is recorded. part number. serial number. Ah exception is provided in paragraph(b) of that appendix. section 43. (i. the aircraft record must contain sufficient information to clearly establish the status of the life-limited parts installed. a.a work order and a maintenance releasemay be a different document. facilitates transferring the record with the part in the event the part is removed and later reinstalled or installed on another aircraft or engine. Many owners/operators have found it advantageousto have a separaterecord for such parts showing the name of the part.9 must be met (paragraph (b)(3).e. and (3) of the appendix. . Provisions are made on the form for a person other than that person performing the work to approve the repair or alteration for return to service. Section 91.4 17 per discussionin paragraph 5c. When this is done (for major repairs only) the entry on the work order mnst meet paragraph (b)(l). date of installation. In some cases. Par 15 Page9 -. ‘. MAJNTENANCE RELEASE..417(a)(2)( ii ) requires the owner or operator of an aircraft with such parts installed to have records containing the current status of these parts. In addition to those requirements discussedpreviously. 17. i c.-. be on a copy of the work order written for the product. (2) a signed copy of the work order._..ly major repairs). (2). Major repairs and alterations are to be recorded on FAA Form 337. (2) arrd (3). not applicable) and the document is to be made and retained as part of the maintenancerecords unber section 91..9 requires that major repairs and alterations be recorded as indicated in appendix B of part 43.417. a. Stuck& Acting Director. The basic authorization for berforming these tests and inspections.alterations. on their service letters and bulletins. found in section 43 3.take the time to review and learn the system of the previous owner to ensure co&pliance and continuity when you modify nr continue that system.4 I I and 9 I .9 and 43. When multiple personsare involved in the performance of tests and inspections. Some manufacturers have initiated a policy of indicating. AND AIR TRAFFIC CONTROL (ATC) TRANSPONDERS. as well as the aircraft.: look at the maintenancerecords of any used aircraft you expect to purchase. Many prospective owriers have f‘ound it advantageousto have a reliable unbiasedmaintenanceperson examine the maintenance records. ALTITUDE REPORTING EQUIPMENT. When there. There are essentially three tests and inspections (the altimeter system. care must be exercised to insure proper authorization under these three s&ions and compliance with sections43. and the data correspondencetest). is generally a good indicator of the aircraft condition. If the airdraft is purchased. whether or not the changesconstitute major repairs or alterations. C. Flight Standards S+vice I . and other documents dealing with changesto their aircratt. before negotiations have progressedtoo far.:BEFORE YOU BUY. This is the proper time to take a clos. Thomas I<. it is advisable to contact the local FSDO for guidance.9(a)(3) in pa-titular.4 17. d.is a question. Some manufacturers also indicate that the responsibility for completing FAA Form 337 lies with the person accomplishing the repairs or alterations and cannot be delegated. each of which may be subdivided relative to who may perform specific portions of the test. the transponder system. current edition. 19. is supplementedby sections 9 I . Instructions for Completion of !:A/\ Form 337.9-l. but in any event. 18.b. This is not always the case. and AD compliances. Detailed instructions for use of this form are contained in AC 43. which properly identifies all previously performed maintenance.‘. and reqhire correction of-any discrepanciesfound on the aircraft or in the records. Thcsc forms art’ now required to bc made part of the maintenancerecord of the product repaired or altcrcd and retained in accordancewith section 91.4 13. The recordation requirements for these tests and inspections are the same as for other maintenance. A well-kept set of maintenancerecords. before you buy. TESTS AND INSPECTIONS FOR ALTIMETER SYSTEMS. require the owner to produce the maintenancerecords for your examination. N. Propeller. N .!-iqz&q= Next Compbu Authorized Signature. Engine. Rotor. l Aircraft. or Appliance: Make Model S.