It Must Be Signed to Be Legal
Signature — A mark or sign made by an individual on an instrument or document to signify knowledge, approval, acceptance or obligation.
— From The Free Dictionary
This article is the first in a series of three that will cover the evolution of electronic signatures in detail, particularly in the area of business aviation maintenance records. The three-part series will help us understand aircraft maintenance records processes, the evolution of electronic records and electronic signatures, the position of the FAA with respect to electronic signatures, and where the use of electronic signatures makes the most sense versus where they don’t really belong.
In this first article, I want to cover the current process for documentation of aircraft maintenance. We tend to focus on the portion of the aircraft maintenance records-keeping process where we spend our time. In doing so, we tend to forget the other elements that feed into our process. When we are done here, we will share a high-level view of the entire process and where signatures actually come into play. In addition, we will understand the very basics of the purpose of the signature and how it weaves into the very fabric of business aviation maintenance.
I first want to break the aircraft maintenance cycle down into seven phases:
Aircraft in service
Unplanned in-service maintenance
Maintenance planning
Visual inspection (identification of discrepancies)
Corrective action (correction of discrepancies)
Inspection of work accomplished
Approval for return to service
Aircraft In Service
You might wonder why I include the in-service phase in this assessment. First of all, the availability of an aircraft is arguably the most important thing to its owner. In the business aviation community, by the time a businessperson or corporation purchases an aircraft, they need it and its use adds significant value to their business. Not having it available is in many ways intangible, but in every way a cost. I choose to keep our focus on that phase as well, for the benefit of the aircraft owner who ultimately buys all our groceries.
Unplanned in-service maintenance
It is inevitable for aircraft to be taken out of service. It is just part of the deal. Our objective should always be to make service events as infrequent and as short as possible. Even with the best of planning, we will have in-service unplanned maintenance surprises that need addressing. This is when an aircraft lands at its scheduled destination, no maintenance is planned, and a fault takes place and needs the attention of a technician to ensure the aircraft remains airworthy. In the best case, these maintenance actions are done quickly and the aircraft is ready for the principal when they return from their engagement to fly back. When the maintenance is completed, it is either recorded in the aircraft flight log or on a separate piece of paper to be added to the permanent aircraft maintenance records later. The permanent aircraft maintenance records are usually kept at the home base for the aircraft and only taken to a maintenance facility when the aircraft has a scheduled maintenance event. Regardless, the maintenance accomplished must be recorded properly and must include a signature certifying that the work was inspected and verified to have been accomplished in an airworthy manor. In this cycle discussion, this is the first type of recorded signature for maintenance.
Maintenance Planning
The maintenance-planning phase is one that should take place at some level continuously. The key is to have the next scheduled maintenance event scope defined clearly well before the beginning of the event. If we are to make the most of the time the aircraft is down, we need to know what tools, parts and people will be needed to accomplish the work. In order to plan for maintenance effectively, that aircraft must be enrolled in a high-quality maintenance-tracking system that provides revisions to the maintenance program for the aircraft as the program is revised.
Visual Inspection
(Identification of discrepancies)
When the aircraft enters the hangar for the scheduled maintenance event, certain inspections are required at that time, depending upon the maintenance program for that aircraft. The first thing to do is remove parts scheduled for overhaul or maintenance and then use a checklist to conduct the visual inspection required for the aircraft. In all cases, the visual inspection will uncover discrepancies. As these discrepancies are uncovered, the person uncovering them should record them in a paper or electronic form. As the inspection is completed, the discrepancies are recorded and the inspection checklist is marked off until all of the required visual inspections have been done.
Corrective Action
(Correction of discrepancies)
Next comes the corrective action that is required in order to correct the discrepancies found during the inspection. This might sound simple, but now the signature part of things gets interesting. As these discrepancies are corrected, the person performing the work should record their signature (or some unique identifying mark) to that particular maintenance action on whatever form it is recorded, to signify that they indeed have performed the work. There are several reasons for the signature. For example, the corrective action might be in phases or might need some sort of functional test, but for our purposes here, the signature at this point meets the requirements of Part 43.9 (a)(3), requiring, “The name of the person performing the work.” Although there is not a specific requirement for a “signature” to identify the person who performed the work, a signature does just that. This is the most common method of meeting the requirement of 43.9(a)(3). Where I have seen it fall down is that this information rarely (if ever) makes it to the “permanent aircraft maintenance records.”
Inspection of work accomplished
Inspection of the work is the process of going behind the person who performed the work and verifying that the work was done correctly and results in an airworthy condition. Often the person inspecting the work is the same person who performed the work in the first place. Personally, I support double inspection wherever possible. Some organizations incorporate double inspection into their processes and sometimes even identify critical work processes that require a more experienced inspector to evaluate the work.
As the inspector passes through the aircraft and inspects each individual piece of work that was accomplished, approval of the work should be signified by a signature. This signature validates the inspection itself. It is at this granular level that we can actually tie back to the inspection guide used as a checklist in the first place.
The flow goes like this:
Inspection task from guide
Discrepancy
Corrective action
Inspection of corrective action
The inspection of the corrective action is follow-on to the initial, scheduled inspection, this time resulting in no further discrepancies. The signature approving any maintenance performed is one of two that are required by FAR Part 43:
Part 43.9 (a)(4) “If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work ...”
Approval for return to service
Lastly is the approval for return to service. One could argue that the signature applied to each individual corrected discrepancy constitutes approval for return to service. This is true. It constitutes approval for return to service. However, this is when the reality of how we function as an industry comes into play. You see, in order to maintain the value of the aircraft, the “permanent aircraft maintenance records” must be both maintained well and protected. It is known that as much as 25 percent of the value of an aircraft can be impacted by lost or stolen maintenance records. It’s clear that sloppy or disorganized maintenance records can also have significant impact on the value of the aircraft. For this reason, when the maintenance event is completed all of the work accomplished is summarized into an aircraft maintenance logbook entry that is inserted (usually adhered) to the aircraft, engine, propeller, or rotor maintenance log book. While the maintenance is being accomplished, the work is being recorded internally to the maintenance provider using their internal system. Some are more elaborate than
others and some have means for electronic signatures as well, which we will get into next month. The aircraft logbook set is the final resting place for a signature that literally approves the aircraft for return to service.
Part 43.9 (a)(4) “… the signature constitutes the approval for return to service only for the work performed ...”
Upon completion of the inspection, a record entry must also be made in the log book to indicate what inspection was performed and that the aircraft is either airworthy or it isn’t. That entry must also have a signature.
Part 43.11 (a)(3) “The signature, the certificate number and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof ...”
The combination of the log book entry for maintenance (43.9) and the log book entry for inspection (43.11) allows the aircraft owner or operator to place the aircraft back into service, thus beginning the cycle again.
This lays out the process of the operation of the aircraft and how maintenance fits into that process. It also identifies what signatures are required as a part of that process and why.
In closing, I want to identify several places where a signature is required for aircraft maintenance, most of which are to meet the requirements of Part 43.9 or Part 43.11 in one way or another. The list consists of records of the maintenance organization and the records of the aircraft itself.
Maintenance organization maintenance records
Incoming inspection
Inspection guides
Work order systems and forms
Final inspections
Aircraft maintenance records
Aircraft logbooks
Major alteration and repair forms (337)
Aircraft flight/maintenance log
Minimum equipment list deferrals
8130 tags
Maintenance tracking task cards
As we look at this list, we become aware of the challenge of creating systems that support electronic signatures across the board. At minimum, we need to consider the difference between the records created and maintained by a maintenance provider and the records required in order to keep and maintain an aircraft as the owner or operator.
Next month, we will begin to dive into the technologies available for electronic signatures and understand the requirements that we have as a regulated industry to comply with aging rules. Technology is moving much more quickly than the regulating bodies can keep up with. Even so, there are creative people who are coming up with some cool ways to utilize the latest technologies. Until next month ...
Joe Hertzler has more than 25 years of experience in business aviation. He has earned a reputation as an efficiency expert when it comes to aircraft maintenance and is well known for his in-depth understanding of maintenance regulations and how they affect aircraft compliance. He has helped many in dealing with critical and urgent FAA interactions and often speaks on the topic of aircraft maintenance and compliance at industry events, such as the NBAA Maintenance Managers Conference, PAMA meetings and IA renewal seminars. Hertzler also serves on the National Air Transportation Association’s (NATA) Maintenance and Systems Technology committee. Contact him at JoeHertzler@gmail.com.