GM1 21.A.5(a) and (b) Record-keeping

CAA ORS9 Decision No. 40

RECORDING AND ARCHIVING SYSTEM

The main objective of record-keeping in design organisations (DOs) and production organisations (POs) is to ensure the retrievability of data that is required for the continued airworthiness of in- service products.

In addition, records within the design environment are essential to ensure proper control of the configuration of the type design and of its compliance with the certification basis.

In the production environment, records are also 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, the approved DO or PO (or a natural or legal person that is demonstrating their design capability through an agreement on alternative procedures or through the acceptance of the organisation’s certification programme, or a natural or legal person that produces products and parts under Part 21, Subpart F) 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 that is required by points 21.A.139 and 21.A.239 or to the manual/procedures that are required by points 21.A.14(b), 21.A.125A(b), or 21.A.602B(b)(2), as appropriate. This also applies in case of demonstrating the design capability through the acceptance of the certification programme under point 21.A.14(c).

All forms of recording media are acceptable (paper, film, magnetic, etc.), including the use of electronic records*, provided that they can meet the required duration for archiving under the given conditions 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 from deterioration or accidental damage, alteration, and tampering;

— ensure the continued readability of the records;

— demonstrate to the CAA the proper functioning of the record system; and

— define an archiving period for each type of data as follows:

— production data that supports the conformity of a product, part, or appliance 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 that supports the compliance of a product, part, or appliance with the certification basis (see GM1 21.A.5), as well as data that is considered essential for continuing airworthiness, is kept throughout the operational life of the product, part, or appliance; such continued airworthiness data may include, but are not limited to, in- service occurrence reports and mandatory continuing-airworthiness information;

— for organisations that are approved according to Part 21, Subparts G and J and organisations that demonstrate their design capability through an agreement on alternative procedures or acceptance of their certification programme by the CAA, ensure that the recording and record- keeping systems that are used by the partners, suppliers, and subcontractors meet the record- keeping objectives with the same level of confidence as they do 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; and

— for natural or legal persons that produce items under Part 21, Section A, Subpart F, the data on supplied parts may be retained by the supplier if the supplier has a system that is agreed by the CAA under Part 21, Section A, Subpart F; in each case, the PO is required to define the archiving period and satisfy itself and the CAA that the recording media are acceptable.

*Related 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); and

— 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).