Record Retention Periods

by Sing Joo
(Singapore)

During aircraft re-deliveries, the Lessor/Buyer will always ask for the release certificates of the On Condition and Condition Monitored OC/CM components installed on aircraft. Some of those are installed ten years ago and the release certificates have been misplaced.

Is it really necessary to show the Lessor/Buyer each and every release certificate for all the OC/CM components?

How long must we keep these release certificates?

ANSWER: You are right. This is always an issue during a lease return. It usually doesn't mater what the aviation authorities require, because it all comes down to how it is written in the return conditions of the lease agreement.

For OC/CM components, a good rule of thumb is to keep records of those components listed on the manufacturers delivery document (Boeing readiness log or Airbus inspection report for example).

FAR 91.417 Maintenance records says:

(a) Except for work performed in accordance with 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

I agree with the first part of 91.417(b)(1), but whole heartily disagree with the "or 1 year" part. I have done may records audits over the years and there are times when you need to have a record of a maintenance action from several years ago. That one piece to the puzzle is sometimes missing because of this rule.

FAR 121.380 Maintenance recording requirements has similar wording:

(a) Each certificate holder shall keep (using the system specified in the manual required in 121.369) the following records for the periods specified in paragraph (c) of this section:

(1) All the records necessary to show that all requirements for the issuance of an airworthiness release under 121.709 have been met.

(c) Each certificate holder shall retain the records required to be kept by this section for the following periods:

(1) Except for the records of the last complete overhaul of each airframe, engine, propeller, and appliance, the records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for one year after the work is performed.