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Any legal requirement to keep maintenance records for X years?

I've come across a situation concerning a registry transfer where this was not possible because records going all the way back to when the plane was made (in the 1970s) were not available.

Is that normal?

I am sure that many/most owners do not have paperwork going back that far.

There is a requirement for maintenance companies to retain records a certain time, I vaguely recall. But that's a different thing.

Administrator
Shoreham EGKA, United Kingdom

A fair fraction of aircraft operate legally with incomplete maintenance logs, not withstanding that any buyer would like to have them.

Are there missing records for AD compliance? That's the first thing that comes to mind. The basic requirement I've understood is proof of current compliance with the Type Certificate. That may necessitate a conformity inspection for 'export', but surely for that inspection the records for every maintenance operation are not the issue, only airworthiness related records.

I'd suppose that in the fairly unusual case of a GA airframe being certified with a life limit, or if an AD imposed an airframe/component life limit, it would be necessary to document AFTT to show conformity with the TC. That could've been done when creating the new maintenance log by reference to a known AFTT at a date in the past (possibly through a copy of a recent work order), plus estimated time from then to date.

I actually don't know any more details but yes it could well be there are component or airframe cycle limits being questioned, and with about 15 years of logbooks missing, the accepting registry is refusing to accept it because of missing data on a portion of the usage.

Sure enough, component issues can always be dealt with by scrapping and replacing the said components but that may render the aircraft worthless, and you cannot do that with an airframe limit, obviously.

And yes, AD compliance could be another one, if the AD concerns a component that doesn't carry a serial number, so without a logbook entry saying it has been complied with the only way of being sure is to do it again.

This of course means that any plane with missing logbooks is potentially worthless!

There are reports of a 737 having to be scrapped because somebody lost the paperwork for its landing gear, and fitting replacement gear was uneconomical.

Administrator
Shoreham EGKA, United Kingdom

We once agreed to buy an aircraft and myself and an engineer duly went to South Africa to inspect. While we were there several logbooks went missing although several engineers not involved in the transaction had seen then in the preceding few days. Coupled with the cracked turbine parts we had already found it somewhat put us off and so we walked away. I suspect that once we had found the engine problems the missing logbooks were designed to put us off as the seller had an expensive contractual obligation to put the engine faults right

Darley Moor, Gamston (UK)

Having records back to day one is ideal. There is no "permission" to do away with any after a period. That said, stuff happens. There will always be an expectation that the aircraft owner demonstrate that the aircraft is maintained in accordance with its Type Certificate. If you cannot prove it has been done, do it again.

We once looked at buying a Navajo really really cheap. It was a seized drug plane. The plane was fine, but not a bit of paper with it. I did the research. If we overhauled everything, for which there was an overhaul requirement, and otherwise went over the rest of the plane with a very thorough inspection, Transport Canada would allow us to issue zero time logs. The only reason we did not follow through was the plane was in Central America, and we could not get authority to fly it back through the US in that condition to do the overhauls at our shop in Canada.

During my 5 years of doing Twin Otter fleet research, I managed to gather hours and cycles in service information for more than 600 of the 623 Twin Otters flying at the time (844 total built). The airframe is both hours and cycles limited, based upon the rate of two cycles per hour. Whichever you run out of first invokes major maintenance requirements.

It turned out that a branch of the Canadian Government operated a "used" Twin Otter, for which the previous operator had never recorded cycles, and the operation was known to have been short commuter flights legs. How do these things happen!? I was called, could I help? I divided the total fleet cycles into the total fleet hours, and got an average cycle per hour ratio for the entire Twin Otter fleet. Transport Canada accepted this value as appropriate, and allowed it to be applied to this aircraft. A number of cycles was established, and the log maintained from there. That Twin Otter happily flies in service today.

If you don't have the records, the answer is not a complete no, but the road might be long and expensive...

Home runway, in central Ontario, Canada

It turned out that a branch of the Canadian Government operated a "used" Twin Otter, for which the previous operator had never recorded cycles, and the operation was known to have been short commuter flights legs. How do these things happen!?

This reminds me of an ex US Army King Air (U21 I think) that was used for some work with which I was involved. I remember it had main gear struts that were noticeably different side to side, that were from two different models of King Air. It turns out that military King Airs are not maintained in accordance with the type certificate, and so are essentially unsalable to the civilian market as a result. This one was bought by a contractor for (as I recall) $250K and was operated with a civilian N-number but with 'public use' paperwork, meaning in support of government. It was a handy work around because it could thereby be modified in any number of ways. And it was! The US federal government does not require aircraft operating for 'public use' to comply with type certificate airworthiness standards.

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