In today's digital age, the aviation industry is rapidly embracing electronic record-keeping systems to streamline operations, improve efficiency, and enhance compliance. Many Part 145 repair stations have successfully integrated electronic record keeping into their manuals, receiving FAA approval in the process. In this blog post, we will share valuable tips and insights gathered from our clients who have achieved this milestone. Whether you're considering transitioning to electronic record keeping or looking to optimize your existing system, these tips will help you navigate the process effectively.
To successfully integrate electronic record keeping into your Part 145 repair station manual, it's crucial to know the FAA regulations that govern it, such as 14 CFR Part 145, Appendix D. Additionally, customizing your Repair Station Manual (RSM) to reflect your specific electronic record keeping system and its integration into daily processes demonstrates a comprehensive understanding of how the system aligns with your repair station's operations. This ensures a smooth transition and enables you to gain FAA approval.
Disclaimer: The following includes examples provided by clients who have written EBIS into their repair station manuals to describe how the system will be used for maintaining their work orders, billing, inventory, etc. and have successfully received approval from the FAA. This is not an exhaustive list and for additional support or guidance, please defer to your local FSDO and/or FAA contact.
General Statements
The general first rule of thumb is to not by too restrictive on how your manual is written. Each FSDO interprets the rules slightly differently, so it's difficult to ever create a single document that be applicable everywhere. While ultimately the RSM author's responsibility on what to put in their respective manual, here are some example general statements that could be included:
{Company Name} utilizes EBIS software to create a work order quote, invoices, track and store records for aircraft, parts inventory controls, track tool calibration dates and create logbook entries. EBIS is accessed with an encrypted UserID and password which is administered by the Accountable Manager. EBIS stores all records created with it, electronically. Standalone forms are also used throughout this manual. Forms are listed as they appear and are used in the RSQCM and the RSTP. Forms are maintained in a Forms Manual.
Purpose
1.1 To define sequence and methods to be followed within the Repair Station to ensure structured Work Order System in the EBIS program. The EBIS system is a cloud-based program that manages customer-related information including aircraft maintenance records, parts/service requests, sales orders and billing. These are organized through a system of process modules and related data entry windows.
Creating Records
Records are created by completing forms. Forms are maintained in a Forms Manual and in EBIS (the Repair Station's software application). Forms are controlled documents. EBIS creates work orders and invoices, tracks and stores records for aircraft, maintains parts inventory, tracks tool calibration dates and creates logbook entries.
Maintaining Records
Records created in EBIS are stored in EBIS. Individual forms are stored electronically and may also be stored in a hardcopy format. Maintenance Records are also maintained together in the Work Package. Upon releasing an aircraft to service, the customer is provided with a copy of the maintenance record (see Section 9.5.2.3).
Logbooks
When it comes to electronic record keeping, the logbook is a critical component. To ensure accuracy and compliance with FAA regulations, it's essential to define clear logbook procedures for making and accessing entries electronically. This includes outlining user roles, access controls, data entry requirements, and record retention procedures. Additionally, implementing robust security measures such as digital signatures or audit trails can help protect logbook entries from unauthorized modifications or tampering, ensuring the integrity and authenticity of records.
Invoices
When creating electronic invoices, it's important to ensure that all necessary information is included, such as the date, customer details, work description, labor and material costs, and any additional charges or taxes required by the FAA. To minimize errors and ensure consistency, implementing automated calculations and data validation checks can be helpful. It's also essential to regularly review and update invoice templates to stay compliant with FAA guidelines.
Work Orders
When implementing electronic record keeping in your Part 145 repair station manual, it's crucial to streamline your work order procedures. Develop a standardized workflow that outlines each step involved, such as initiating work orders, assigning technicians, tracking progress, and closing out completed work. Additionally, incorporate procedures for documenting completion and verifying the accuracy of recorded information, including electronic signatures, quality control checks, and any necessary certifications or approvals. By creating a clear and organized system, you can ensure compliance with FAA regulations and enhance overall efficiency in your repair station.
Work Order by Task
To ensure efficient tracking and reporting of complex repair or maintenance jobs, it's essential to break them down into individual tasks or subtasks. Each task should have clear requirements, instructions, and necessary resources or materials defined for optimal accountability. To monitor task progress effectively, implement a system that tracks each task's progress and milestones, including time stamps, completion status, and any necessary sign-offs or approvals. Take advantage of your electronic record-keeping system's reporting capabilities to streamline the process.
Work Order by Task + Signoffs
Use the digital signature functionality in your electronic record-keeping system to capture approvals and sign-offs at each task level, linking them to the individuals responsible for performing or verifying the work. Develop procedures for retaining these sign-off records within the system to ensure easy access for audits or reference purposes while adhering to the FAA's record retention requirements.
In conclusion, integrating electronic record keeping into your Part 145 repair station manual is a complex process that requires attention to detail, strict adherence to FAA regulations, and a thorough understanding of your repair station's specific requirements. By implementing the tips and insights shared in this blog post, you can successfully navigate this transition and optimize your electronic record-keeping system for maximum efficiency and compliance.
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