Part 145 Repair Station Record Retention - Who's Responsible?

Enter another dilemma. What happens to these records when a CRS goes belly up? Not so easy an answer here, but the reality is that, once a CRS Certificate is surrendered the FAA has no authority to enforce any record keeping requirement and the issue turns into a civil matter with the former certificate holder. However it is not always that simple. Suppose this CRS went belly up because the owner died. This is exactly the situation I was in on a pre-purchase evaluation of a light twin recently. The aircraft had suffered an inadvertent gear retraction on landing when the aircraft was still light on the wheels and the WOW circuit was in the flight condition. The right main unlocked and the weight was on the wheels before the pilot could put the lever back down. So the aircraft slowly dropped the right wing to the ground. The airframe suffered very light damage because the other two wheels were down and locked. The props of both engines did strike the ground and that was the extent of the mishap.

The repairs were made to the airframe IAW the SRM and with factory parts. The details of this repair were recorded as a stand alone logbook entry. Both props were replaced with new and the engines were sent out for a prop strike inspection. This is where it gets bad. The engines were inspected and work was performed by a CRS and the details were on file under a work order number with this repair station. Now as a mechanic I want to see this work order. As a matter of fact, the work performed by a CRS need not be described in the Maintenance Release as per FARs. I looked in the bag of papers and found no work order. So I called the CRS and low and behold the number was disconnected. Out of business, the owner was dead and I was stuck with a $430,000.00 pile of questions. Where can I get this work order? Who is responsible for these records? How do I get them?

The answer is, you don’t.

We wasted time, money, and energy on a big question – Did the work get performed? Or was it just a pencil whipped logbook entry for an inspection that never took place. This question of ultimate record custody plagued me for several weeks so I finally broke down and called the FAA Legal office that reinforced my thoughts that at this point it would be a civil matter and a judge would have to issue a subpoena for those records to the survivors of the CRS owner. This was followed up by a suggestion that you should approach the record holders privately first and ask for the records. In most cases this would work because they probably have no interest in these records, and would supply them happily. In my case the survivors had no obligation to provide the records without a subpoena from the court, and from all accounts, would have chosen not to cooperate with us due to the difficulty and liability they seemed to think would be involved.

A word of advice to aircraft owners and mechanics – Get copies of each and every work order for Any maintenance or inspection performed and keep them with the aircraft records.