21L.A.7 Record-keeping

(a)The record-keeping system should ensure that all the records required by point 21L.A.7 are accessible within a reasonable time. Those records should be organised in a manner that ensures their traceability and retrievability throughout the required retention period.

(b)The records should remain legible throughout the required retention period and be protected against damage, alteration and tampering.

(c)The format of the records should be specified in the organisation’s procedures.

(d)The organisation should ensure that copies of all the documents and supporting information that are developed:

(1)under the privileges that are defined under points 21.A.163 and 21.A.263 of Annex I (Part 21); or

(2)under the design and production activities conducted under points 21L.A.126, 21L.A.176 or 21L.A.274;

(3)for type certificates, supplemental type certificates, major changes and major repair design approvals that are not issued under the privileges defined under point 21.A.263 of Annex I (Part 21), or

(4)for declarations of design compliance in accordance with Subpart C, F or N, are retained throughout the operational life of the product or part.

(e)The retention period starts when the record is created or when it was last amended. If the organisation transfers a certificate to another natural or legal person, the records related to the certificate should be transferred to the new holder.

For organisations that hold or have applied for a type certificate, supplemental type certificate, change to the type-certificate approval, repair design approval, permit to fly or have submitted a declaration of design compliance or a declaration of design or production capability under Part 21 Light or produces (or intends to) using Subpart R, the relevant design information/data should include at least, as applicable: design data such as type design data as defined in points 21L.A.26 and 21L.A.46 and changes to that data, and repair design data; drawings and test reports, including inspection records for the product tested; the certification demonstration plan, including related certification basis data (certification review items (CRIs), special conditions (SCs), equivalent safety findings (ESFs)); and compliance-demonstration data. For production organisations, the relevant records should include at least: conformity justification data; and conformity attestation data (e.g. EASA Form 1, EASA Form 52B).

REPAIR DESIGN AND RECORD-KEEPING

(a)The relevant substantiation data associated with a new major repair design and record-keeping should include:

(1)identification of the damage and the source of the report;

(2)the major repair design approval/declaration sheet, identifying the applicable specifications and the references of the justifications;

(3)the repair drawing and/or instructions, and the scheme identifier;

(4)any correspondence with the type-certificate holder, supplemental type-certificate holder or declarant, if their advice on the design was sought;

(5)the structural justification (static strength, fatigue, damage tolerance, flutter, etc.) or references to that data;

(6)the effect on the aircraft, engines and/or systems (performance, flight handling, etc., as appropriate);

(7)the effect on the maintenance programme;

(8)the effect on the airworthiness limitations, the flight manual and the operating manual;

(9)any change in the weight and moment;

(10)any special test requirements; and

(11)the justification that the certified or declared noise or emissions level remain unchanged after the repair.

(b)The relevant minor repair documentation includes points (a)(1) and (a)(3). Other elements of point (a) may be included where necessary. If the repair is outside the approved or declared data, a justification for the classification is required.

(c)Special consideration should be given to repairs that impose subsequent limitations on the part or product (e.g. oversizing of fastener holes, etc.).

(d)Special consideration should also be given to life-limited parts and critical parts, notably with the involvement of the type-certificate or supplemental type-certificate holder, when deemed necessary under point 21.A.208(c).

(e)Repairs to engines and/or propeller critical parts would normally only be accepted with the involvement of the type-certificate holder or the declarant if compliance of the engine has been included within the aircraft declaration of compliance.

RECORD-KEEPING AND ARCHIVING SYSTEM The main purpose of record-keeping for organisations responsible for design and production is to ensure the retrievability of data required for the continued airworthiness of in-service products. In addition, the records within a design environment are essential to ensure a proper control of the configuration of type design and its compliance with the certification basis or applicable technical specifications. In the production environment, the records are required to ensure that products or parts are in conformity with the applicable data throughout the manufacturing cycle. In addition, certain records of milestones are needed to subsequently provide objective evidence that all the prescribed stages of the production process have been satisfactorily completed. Therefore, organisations responsible for design or production are required to implement a system for the compilation and retention of records during all stages of design or production, which covers short-term and long-term records as appropriate to the nature of the product and its processes. The management of such information is subject to the appropriately documented procedures in the management system required by points 21L.A.124, 21L.A.174 or in the manual/procedures required by point 21L.A.273 as appropriate. All forms of recording media (paper, film, magnetic, etc.) are acceptable, including the use of electronic records*, provided they can meet the required duration for archiving under the conditions provided and that the continued readability of the records is ensured. The related procedures are required to: identify the records to be kept; describe the organisation of, and responsibility for, the archiving system (its location, compilation, format) and the conditions for access to the information (e.g. by product, subject, etc.); control access to the data and provide effective protection against deterioration or accidental damage; ensure the continued readability of the records; demonstrate to the competent authority the proper functioning of the records system; define an archiving period for each type of data subject as follows: production data that supports the conformity of a product or part, is kept for not less than 3 years from the issue date of the related statement of conformity or authorised release certificate; and design data, including data which supports the compliance of a product or part with the certification basis or applicable technical specifications, as well as data that is considered essential for continuing airworthiness is kept throughout the operational life of the product or part; such continued airworthiness data may include but are not limited to in-service occurrence reports and mandatory continuing airworthiness information; organisations responsible for design or production should ensure that the recording and record-keeping system used by the partners, suppliers and subcontractors meet the record-keeping objectives with the same level of confidence as for their own system; in each case, it should be defined who should retain the data record (organisation, partner, supplier or subcontractor) as well as the method of surveillance of the recording / record-keeping system of the partners, suppliers or subcontractors. * In relation to electronic records, the following definitions apply: ‘electronic record’: electronic or digital data that is created, generated, sent, communicated, received, or stored by electronic means; ‘electronic data’: it is typically in the form of documentation that is statically stored in a computer file that is not modifiable (e.g. pdf of a scanned document with wet ink signatures); ‘digital data’: it is typically in the form of computer-generated bytes of information that is stored in a computer-workable file (e.g. MS Word file, MS Excel file, 3D CAD file).

RECORDS OF PERSONNEL INVOLVED IN DESIGN OR PRODUCTION

(a)The following should be the minimum information to be recorded for personnel that are involved in design or production and in the independent function to monitor the compliance, if required by points 21L.A.125(c), 21L.A.125(d), 21L.A.175(b) or 21L.A.175(e):

(b)

(1)first name and surname;

(2)date of birth;

(3)basic training received and qualifications attained;

(4)specific training received and qualifications attained;

(5)continuation training (if appropriate);

(6)experience gained;

(7)scope of the authorisation;

(8)date of first issue of the authorisation;

(9)expiry date of the authorisation (if appropriate);

(10)identification number of the authorisation (or equivalent means to identify the link between the authorisation and the individual that holds the authorisation);

(11)changes to the data.

(c)The record may be kept in any format and should be controlled by an internal procedure of the organisation. That procedure is part of the management system of the organisation.

(d)Staff members should be given reasonable access, on request, to their own records as per Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Regulation) (OJ L 119, 4.5.2016, p. 1).

(e)A design or production organisation should keep the record of a particular staff member for at least 3 years after the staff member is no longer employed by the organisation or has changed their position in the organisation, or after the withdrawal of the authorisation, whichever occurs first.