The National Air Transportation Association (NATA) asked the FAA to clarify certain references in draft Advisory Circular AC 43-D on maintenance recordkeeping to ensure alignment with FAA regulations. In comments on the draft AC, NATA also recommended that the agency develop a tool that could enable the immediate recall of all issued forms as needed.
Updating current guidance in use since 1998, the draft AC would provide acceptable means of compliance for general aviation maintenance record-making and recordkeeping.
The FAA in August extended the comment period for the draft AC until October 18 at the request of 11 trade associations, including the Aeronautical Repair Station Association (ARSA), Aircraft Electronics Association, Aircraft Owners and Pilots Association, and General Aviation Manufacturers Association, along with NATA.
ARSA noted, “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.”
In their request for the extension, the associations stated: “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. 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.”