AMC-ELA No 1 to 21.A.165(d);(h) Obligations of the holder –Recording and archiving system    

CAA ORS9 Decision No. 1

Records of production that have been used to determine conformity with the type design, such as those records mentioned in relation to point 21.A.165(c) and (d), should be archived and preserved using an adequate archiving method that should be defined within the company manual. Those records need to be held at the disposal of the CAA, and need to be retained in order to provide the information necessary to ensure the continuing airworthiness of the products, parts or appliances.

All forms of recording media are acceptable (paper, database, etc.), provided that the preservation of the records for the retention period for archiving can be ensured.

The production organisation should:

1. define the records to be retained. If the type design defines which data needs to be recorded, the production organisation is not required to go beyond this data;

2. implement a structured method of archiving. If IT-based ERP systems with workflow management are used, a detailed description of the system is not required;

3. ensure that there is effective protection of the records from deterioration or accidental damage, e.g. by holding hard and soft copies in separate locations;

4. ensure the continued readability of the records by selecting an adequate method of archiving;

5. define a retention period for each type of data, taking into account that the determination of conformity is subject to the following:

— data which supports the conformity of a product, part or appliance should be kept for not less than 3 years from the issue date of the related statement of conformity or authorised release certificate;

— data considered to be essential for continuing airworthiness should be kept throughout the operational life of the product, part or appliance.

If the production organisation has decided that the records of any partner, supplier or subcontractor do not need to be supplied to the production organisation, then the production organisation should extend its requirements for record keeping to that partner, supplier or subcontractor.