Clarifying (by Dividing) Recordkeeping Guidance
On Nov. 19, ARSA submitted a pair of draft advisory circulars for FAA consideration to replace its proposed update to AC 43-9, Maintenance Records.
The documents divide overlapping responsibilities previously combined into a single AC. The revision to AC 43-9 provided to the FAA now focuses exclusively on recordkeeping responsibilities of persons authorized by part 43 to perform maintenance, preventive maintenance, or alteration. The elements of compliance with record-making and keeping regulations in part 91, applicable to operators, have been placed in a proposed AC 91-417, Part 91 Miantenance and Inspection Records.
The submission follows an August request for extension to the comment period, made by ARSA and a collection of industry allies. The review and drafting period took longer than projected, but produced documents that can provide useful guidance regardless of FAA action. The association encourages its members to download each document, review, circulate among personnel, and use as internal instruction for compliance with the various requirements of parts 43 and 91 – particularly in service of customers who must comply with the rules for operators.
Draft AC 43-9D, Maintenance Records
Purpose: This AC provides certificate holders authorized to perform maintenance, preventive maintenance, and alterations under Title 14 of the Code of Regulations (14 CFR) part 43 with acceptable methods for showing compliance with the maintenance recording requirements in §§ 43.9 and 43.11.
Draft AC 91-147, Part 91 Maintenance and Inspection Records
Purpose: This AC describes methods, procedures, and practices that have been determined to be acceptable means of showing compliance with the record-making and maintenance recordkeeping requirements of Title 14 of the Code of Federal Regulations (14 CFR) part 91.