Recordkeeping is the bane of business; keep too much and get are overrun, keep too little and risk not being able to establish compliance. The government runs on paperwork and in aviation, records go beyond what is required by the FAA. All businesses must keep financial records for the IRS, and depending upon your size and contracts, the Occupational Safety and Health Administration, the Environmental Protection Agency, the Department of Defense, not to mention state and local governments. (The city of Alexandria requires ARSA’s offices to have a documented procedure for trash management.)
Good practices dictate a business establish a solid recordkeeping policy and stick to it. Unfortunately, it is difficult to decipher what records need to be kept and for how long. The result: many companies just keep everything forever, a practice that makes it almost impossible to find a requested document short of searching for hours. Without going into all the requirements that may dictate the type of records that must be kept, let’s focus on a business or individual with a U.S. mechanic or repair station certificate.
Surprisingly, mechanics have no recordkeeping requirements; they have record making requirements under §§ 43.9 and 43.11 for the maintenance, alterations, and inspections performed. Those regulations require a record to be made by any person performing work on a civil aviation aircraft or component. The rules do not require the mechanic keep a copy…but individuals not keeping track of what they did, for whom, and when open themselves to accusations of non-compliance. A mechanic should not be performing work without recency of experience or having done the work under supervision. How can that be “shown” without records?
For companies with repair station certificates, there are records that must be kept and those that should be kept. Maintenance records (those required by §§ 43.9 and 43.11) must be kept for two years after the work is completed. That is only to satisfy the FAA, not customers. Contracts may require retention for ten 10 or twenty 20 years.
Training records for technicians must be kept for two years after the training has been given, but many companies keep them for two years after the individual separates from the company. There is no requirement to keep old versions of the repair station quality manual, rosters, or forms, but without them it is hard to show continued compliance.
So, what is one to do?
Start by making sure you know why you are keeping what data. Since everyone must answer to the IRS, state, and local tax authorities, it is essential to work with an accountant or bookkeeper to identify the financial records expected to be retained. Next, look at your contracts and obligations to customers, identify the types of records required, and the retention times. Match those expectations to the business data that supports the forms created during the maintenance, alteration, or inspection process; identify those that are the same. Once the types of records are matched to the forms and documents created or obtained, identify the “purely” business documents from the “quality” records, and set the time parameters of what is kept for which agency or customer.
Don’t forget maintenance manuals and other instructions relating to the work performed, older versions of those documents should be retained to establish compliance for past work and to use in the future if a manufacturer removes a process for its business purposes.
Records are a bane, but you can use them to create boons by tracking good and bad vendors, processes that increase reliability, parts that are improperly designed, manufactured, or are declining ins quality. Through thoughtful procedures, your recordkeeping practices and can help you demonstrate compliance and improve your business.
Sarah MacLeod is managing member of Obadal, Filler, MacLeod & Klein, P.L.C. and a founder and executive director of the Aeronautical Repair Station Association. She has advocated for individuals and companies on international aviation safety law, policy, and compliance issues for more than 30 years.
