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.
August 20, 2024
On Aug. 9, ARSA joined 11 other aviation trade associations requesting additional time to comment on the FAA’s Draft Advisory Circular (AC) 43-9D, “Maintenance Records.” The FAA subject matter expert in charge of the AC quickly responded with an additional 60 days – the new deadline is Oct. 18.
The draft would replace the current version of the guidance document in use since 1998. The AC provides acceptable means of showing compliance with general aviation record-making and recordkeeping requirements according to parts 43 and 91. Though not regulatory – it provides a method, not the only method for showing compliance – the industry continues to push the FAA to carefully align its guidance with the regulations.
“The document contains changes that must be reviewed carefully to ensure compliance with both parts 43 and 91, while accommodating the proper method for completing an FAA Form 8130-3,” the request said. “To use an FAA Form 8130-3 as a maintenance record, information on its completion must be reconciled with the elements required by § 43.9 and multiple bilateral agreements, maintenance implementation documents, and other advisory material.”
To read the complete request, click here.
To view the coordinated copy of the draft AC, click here.
In addition to ARSA, the following organizations supported the request*:
Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
General Aviation Manufacturers Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
Professional Aviation Maintenance Association
Regional Airline Association
*The Aerospace Industries Association confirmed to ARSA its own separate request in support of the group’s need for more time to comment.
