Operational Integrity: The Three Pillars of Maintenance Records & Safety Compliance
Regulatory

Operational Integrity: The Three Pillars of Maintenance Records & Safety Compliance

TBX Team
Regulatory

Operational Integrity: The Three Pillars of Maintenance Records & Safety Compliance

TBX Team

We’ve had the privilege of speaking with hundreds of maintenance shops, flight schools, and inspectors across the country about how they run their shop. “This is a circus act every day,” was how one shop owner put it.

A well-oiled operation, one that turns over planes efficiently and safely—while dialing in the paperwork side—is the end goal for most shop owners. How does one begin to think about the balance between regulatory requirements, the maintenance itself, and the business side of things? As one shop owner put it, "Mechanics, we’re wrench guys, although a major part of my time is spent figuring out how to do the paperwork!"

“Mechanics, we’re wrench guys, although a major part of my time is spent figuring out how to do the paperwork!”

Because paperwork is treated like a chore, people forget how it plays into the larger picture: documentation underpins a maintenance philosophy focused on a consistent safety practice.

A consistent safety practice, one driven by repeatable processes and technical prowess, is the bedrock of a “dialed-in” maintenance operation. Three fundamental pillars—regulatory, technical, and business—underpin a maintenance recordkeeping philosophy ensuring nothing rolls out of your shop that isn’t safe, airworthy, legal, and right.

The Three Pillars of Maintenance Recordkeeping

  1. Regulatory: we demonstrate compliance with the FARs (i.e., Parts 43 & 91) to “follow the rules” and protect ourselves against an audit or litigation
  2. Technical: we leverage manuals, approved data, checklists, service instructions, and our own internal procedures to “do maintenance the right way” and provide an audit trail for the history of the aircraft’s maintenance
  3. Business: as maintenance professionals, we follow a repeatable process and take pride in our work. We stand behind not only our maintenance but the record itself as proof of our high standards

In this piece, we break down these three fundamental pillars into a safety framework applicable to any A&P/IA working on fine-tuning their operation.

The Regulatory Side

As the saying goes, “If we’re going to do maintenance, then we have to make an entry…” Even so, improper maintenance entries—and their omission—are still a common occurrence.

The FARs act as guiderails for us to properly document an aircraft’s maintenance (and preventative mx) history. As we like to point out, the Airworthiness Certificate itself is effective as long as “maintenance, preventative maintenance, and alterations are performed in accordance with Parts 21, 43, and 91 of the Federal Aviation Regulations, as appropriate, and the aircraft is registered in the United States.” Note: this is specified directly under 21.181(a)(1).

21.181(a)(1) Standard airworthiness certificates, special airworthiness certificates—primary category, and airworthiness certificates issued for restricted or limited category aircraft are effective as long as the maintenance, preventive maintenance, and alterations are performed in accordance with Parts 43 and 91 of this chapter and the aircraft are registered in the United States.

Every record backs up that evidence of airworthiness and the sign-off itself certifies the airworthiness of the aircraft, stating that it “conforms to its type design and is in a condition for safe operation” Note: this is defined under 3.5(a).

3.5(a) Airworthy   means the aircraft conforms to its type design and is in a condition for safe operation.

We often take the FARs as a given, so we thought it would be helpful to breakout the key FAR elements below and what they mean from a regulatory and legal perspective as we expand on the foundational principles governing maintenance and recordkeeping. Beyond the Trinity (Part 21, 43, and 91), Parts 39, 65, 120, 135, and 145 go beyond the basics to define the “edges” of a regulatory framework.

Part Scope/Focus Commentary
Part 21 Type Certification and Airworthiness Design and production approvals – establishes approved data and approved parts; establishes link between mx and preventative mx as a requirement for certificate (21.181)
Part 39 Airworthiness Directives Makes AD compliance and documentation mandatory
Part 43 Maintenance and Recordkeeping Establishes who may perform maintenance (43.3), standards for work (43.13) and required entries (43.5, 43.9, 43.11).
Part 65 Certification for Repairmen and Mechanics Defines privileges/responsibilities, your legal authority to sign records.
Part 91 General Operating & Flight Rules 91.403–91.417 set the operator’s duty to keep and retain maintenance records.
Part 120 Drug & Alcohol Testing Part 121, 135, and 145 require drug and alcohol testing to anyone performing safety-sensitive functions and their recordkeeping
Part 135 Commuter / Charter Ops Requires maintenance and return to service recordkeeping (135.427 and 135.443) including progressive inspections (135.421)
Part 145 Repair Stations Recordkeeping and quality control provisions (145.219)
AC 43-9D & AC 39-7D Advisory Circulars Non-regulatory FAA “guidance” to recordkeeping


Consistent with our “Three Pillars”, the regulatory side helps guide how we manage, refer to, and track maintenance to provide a clear audit trail. These regulations ensure maintenance records are legally defensible, transparent, traceable, and repeatable.

The Technical Side

A&Ps are held to standards set by the FAA (the Mechanical Practical Test Standards) in addition to industry standards and best practices. This is the baseline on which we can bolt-on different accepted procedures related to specific maintenance activities, like inspections.  

These accepted procedures are defined by strict, technical documentation for how that maintenance is performed. This ensures repeatability and consistency across the entire GA universe helping underpin aviation safety and compliance.

Sometimes our approved technical data is broad in application, as would be with a Type Certificate or an AD, and sometimes approved technical data can be specific only to one aircraft, such as a field approval. In any case, these sources all coalesce to give us a potential pool of data to do maintenance the right way.

Type of Data Source Status Use Case
Type Certificate Data Sheet (TCDS) OEM / FAA Approved Establishes type design limits & conformance
Supplemental Type Certificates (STCs) FAA Approved Modifications outside of type design
Parts Manufacturer Approval (PMA) FAA Approved Permits production of replacement parts meeting TC specs by a 3rd party
Technical Standard Orders (TSO) FAA Approved Certifies a part meets a minimum performance standard
Maintenance Manuals (MM or CMM) OEM Acceptable (sometimes approved if part of a TC) Primary reference for maintenance procedures from OEMs
Overhaul Manuals OEM Acceptable Step-by-step component overhaul instructions
Service Bulletins OEM Acceptable (unless incorporated by an AD) Inform owners and operators about critical and useful information on aircraft safety, maintenance, and inspections
Service Instructions or Service Letters OEM Acceptable Clarifications or updates to maintenance procedures.
Illustrated Parts Catalogs OEM Reference Only Identifies part numbers and configurations
FAA Form 8110-3 (DER Approved Data) DER / FAA Approved Engineering data generated by a DER to indicate compliance with airworthiness standards
Field Approval (Form 337) FAA / FSDO Approved One-time approval for unique major repairs/alterations.
Airworthiness Directives FAA Mandatory Define mandatory inspections, replacements, or limitations related to unsafe conditions
Advisory Circulars FAA Acceptable Data Clarify acceptable means of compliance (i.e, AC 43.13-1B)


While 43.9 specifically asks us to describe the work performed (or reference to data acceptable to the Administrator), referring to the documentation builds in transparency, defensibility, repeatability, and traceability. Essentially, anyone can read the record and repeat the exact procedure at any time.

Quality standards, such as AS9100, The Air Transport of America’s Specs (ATA Chapters), and FAA Advisory handbooks augment this to provide a holistic, all-encompassing technical “library” for mechanics to have the right data for the right maintenance activity at the right time.

"Regulations tell you WHAT.
Approved/accepted data tells you HOW.
Company procedures tell you WHO and WHEN."

The Business Side

Too often, the regulatory and technical side of things drowns out what many might argue is the most important—the business side. For many, paperwork is just another plate we have to keep spinning in the never-ending “circus act”.

The reality, however, is that proper maintenance recordkeeping can actually become an enabler of process and consistency that can allow your shop to charge more, turnover more aircraft, and reduce labor hours—how is that possible?

It all starts with a repeatable business process from the moment the owner throws you the keys to you putting in the log entry. It has been proven many times over that a consistent, standardized way of doing things will allow you to build in continuous improvement, show customers all the work you’re doing, and reduce inefficiencies in labor hours within your maintenance shop.

Often, the A&Ps/IAs without a clear, standardized process find the paperwork to be a chore, and it ends up getting the shaft, creating unnecessary risk while also cheapening the maintenance work itself. After all, the record is a reflection of the work.

While you don’t necessarily need software to run a shop, there is a strong case to use it given the rise in complexity across GA and helping organize clear workstreams for maintenance functions. As one of our customers attested, “I’ve buried myself in 2 aircraft repair businesses, there’s no instruction book on how to run it.”

"I’ve buried myself in 2 aircraft repair businesses, there’s no instruction book on how to run it."

Process is a safety enabler that underpins a “professionalism” mindset often lost on mechanics (“we’re wrenchers!”) too focused on the technical aspects and not enough on the business side. Ultimately, we see the business side as the third key pillar bolstering the technical and the regulatory, creating one holistic view of safety and compliance.

Running a streamlined maintenance shop with everything in one place—technical data, forms, service docs, log entries, aircraft and customer information—allows shops to produce robust, professional maintenance records that satisfy both the FAA and their discerning customers.

In Summary

Taken together, the regulatory side, technical side, and business side all coalesce to form a holistic foundational view of safety and maintenance recordkeeping best practices.

To help guide proper maintenance recordkeeping, we created “Five Principles” of proper maintenance to remind us every day how we can make great entries as part of our holistic safety practices.

Did we miss anything? If there’s something you’d like to share with us, please don’t hesitate to reach out here. If you are interested in joining the thousands of other shop owners who have leveraged TBX to improve their shop performance, save time (and money)—take a look at our 10-day free trial here.