6/8/98 AC 43-9C
Par 9 Page 6
9. MAINTENANCE RECORDS FOR AD COMPLIANCE. This subject is covered in
AC 39-7, Airworthiness Directives. A separate AD record may be kept for the airframe and each
engine, propeller, rotor, and appliance, but is not required. This would facilitate record searches
when inspection is needed, and when an engine, propeller, rotor, or appliance is removed, the
record may be transferred with it. Such records may also be used as a schedule for recurring
inspections. The format, shown in Appendix 1, is a suggested one, and adherence is not
mandatory. Owners should be aware that they may be responsible for non-compliance with ADs
when their aircraft are leased to foreign operators. They should, therefore, ensure that leases
should be drafted to deal with this subject.
10. MAINTENANCE RECORDS FOR REQUIRED INSPECTIONS.
a. Section 43.11 contains the requirements for inspection entries. While these requirements
are imposed on maintenance personnel, owners and operators should become familiar with them
in order to meet their responsibilities under § 91.405.
b. The maintenance record requirements of § 43.11 apply to the 100-hour, annual, and
progressive inspections under part 91; inspection programs under parts 91 and 125; approved
airplane inspection programs under part 135; and the 100-hour and annual inspections under
§ 135.411(a)(1).
c. Appropriately rated mechanics are authorized to conduct these inspections and make the
required entries. Particular attention should be given to § 43.11(a)(7) in that it now requires a
more specific statement than previously required under § 43.9. The entry, in addition to other
items, must identify the inspection program used, identify the portion or segment of the
inspection program accomplished, and contain a statement that the inspection was performed in
accordance with the instructions and procedures for that program.
d. Questions continue regarding multiple entries for 100-hour/annual inspections. As
discussed in paragraph 5c, neither part 43 nor part 91 requires separate records to be kept.
Section 43.11, however, requires persons approving or disapproving equipment for return to
service, after any required inspection, to make an entry in the record of that equipment.
Therefore, when an owner maintains a single record, the entry of the 100-hour or annual
inspection is made in that record. If the owner maintains separate records for the airframe,
powerplants, and propellers, the entry for the 100-hour inspection is entered in each, while the
annual inspection is only required to be entered into the airframe record.
11. DISCREPANCY LISTS.
a. Before October 15, 1982, issuance of discrepancy lists (or lists of defects) to owners or
operators was appropriate only in connection with annual inspections under part 91, inspections
under § 135.411(a)(1), inspection programs under part 125, and inspections under § 91.217.
Now, § 43.11 requires that a discrepancy list be prepared by a person performing any inspection
required by parts 91, 125, or § 135.411(a)(1).
b. When a discrepancy list is provided to an owner or operator, it says in effect, except for
these discrepancies, the item inspected is airworthy. It is imperative, therefore, that inspections
be complete and that all discrepancies appear in the list. When circumstances dictate that an