Is it a requirement to record/maintain flight hours for serialized A/C parts? I have searched the FAA website with no luck.
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2$\begingroup$ For the airframe, engine yes, but I don't believe you have to break it down by component. What parts are you talking about in particular? $\endgroup$– Ron BeyerCommented Mar 16, 2016 at 13:40
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2 Answers
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Short answer: only for the airframe, engines, propellors and rotors (as applicable).
This legal interpretation is a response to someone who asked which records are required to identify when life-limited parts need to be replaced. It says that you're only required to keep flight time records of the airframe, engine(s), propellor(s) and rotor(s), as appropriate:
Existing regulations, specifically 14 C.F.R. § 91.417(a)(2)(i), require each owner or operator to keep records containing the total time in service of the airframe, each engine, each propeller, and each rotor. This is accomplished by the owner or operator recording and tracking in some form and manner the time in service of the airframe, engines(s), propeller(s), and rotor(s) from the moment the aircraft leaves the surface of the earth until it touches it at the next point of landing, as referenced in 14 C.F.R. § 1.1. In addition, § 91.417(a)(2)(ii), and similar provisions in 14 C.F.R. §§ 121.380(a)(2)(iii) and 135.439(a)(2)(ii), require owners or operators (certificate holders) to keep records that show the current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.
91.417 does indeed say - among other things - that owners and operators have to record the time in service and status for the airframe, engines, props and rotors, but only the status for life-limited "appliances":
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.
1.1. defines "time in service":
Time in service, with respect to maintenance time records, means the time from the moment an aircraft leaves the surface of the earth until it touches it at the next point of landing.
And 43.10 defines "life-limited parts":
Life-limited part means any part for which a mandatory replacement limit is specified in the type design, the Instructions for Continued Airworthiness, or the maintenance manual.
To summarize:
- You only need to record service time for the airframe, engine, props and rotors
- For any other life-limited parts, you only need to record their status, i.e. you need to be able to say when it's time to replace them
answered Mar 16, 2016 at 15:02
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$\begingroup$ Things get a little more complicated with life-limited parts if the part is intended to be reused (transplanted from one airframe to another, like if you wreck the wing on a Tomahawk and replace it with one from a salvage yard). Most folks I know interpret 43.10(c) as "Write the accumulated hours/cycles on the yellow tag when you pull a life-limited part." because otherwise you wouldn't be able to determine the status in a new installation. $\endgroup$– voretaq7Commented Mar 16, 2016 at 17:44
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14 CFR 91.417(a)(2) States:
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
In addition, if you read closely (a)(2)(ii) requires you to keep records of any life limited parts which means that if the manufacturer identifies it to be "life-limited", like a gearbox, then the status for that must be recorded as well, with some exceptions for the time being included in other life-limited recordings.
How do you know if it is life-limited? You need to read the Type Certificate Data Sheet, Airworthiness Directives, or Limitations of FAA approved manuals. Its also useful to note that while you certainly can keep copies of records in computerized form, the FAA requires paper records mostly because there is a signature requirement that is not satisfied by electronic signatures.
answered Mar 16, 2016 at 15:03