What is the minimum set of information that must be recorded for each person exercising privileges in a Part 21 Subpart G or J approved organisation?

The minimum information to be recorded includes: name; date of birth; basic training received and standard attained; specific training received and standard attained; continuation training received (if appropriate); experience gained; scope of the authorisation; date of first issue of the authorisation; expiry date of the authorisation (if appropriate); identification number of the authorisation (or equivalent means to identify the link between the authorisation and the staff member); and changes to the data.

Which staff members, beyond those in Subpart G and J organisations, are covered by the record-keeping requirements of AMC1 21.A.5(d) and (e)?

The requirements also cover persons who carry out the independent monitoring of compliance and adequacy according to points 21.A.139(e) and 21.A.239(e), and persons who carry out the independent verification function of demonstration of compliance pursuant to point 21.A.239(d)(2).

For a person carrying out independent monitoring of compliance under point 21.A.239(e), which of the following is NOT a required recorded item: date of birth, scope of authorisation, or home address?

Home address is not a required recorded item. The required items include date of birth and scope of the authorisation, but not home address.

If a staff member's authorisation is withdrawn, what is the maximum time the organisation must keep the record after that withdrawal?

The record must be kept for at least 3 years after the withdrawal of the authorisation, or after the staff member is no longer employed or has changed position, whichever occurs sooner.

Does the AMC require that the record include the date of first issue of the authorisation?

Yes, the date of first issue of the authorisation is one of the minimum items to be recorded for each person covered by the AMC.

Is the record-keeping procedure considered part of the organisation's management system?

Yes, the procedure to control the records is part of the management system of the organisation.

Which regulation is referenced for staff access to their own records?

Regulation (EU) 2016/679 is referenced for staff access to their own records.

What is the minimum retention period for records of a production staff member whose authorisation is withdrawn but who remains employed?

Records of authorisation of production staff must be archived for at least 3 years after the authorisation is withdrawn, or after the staff member is no longer employed, whichever occurs sooner.

Does the AMC require recording the expiry date of the authorisation in all cases?

The expiry date of the authorisation is required to be recorded if appropriate, meaning when an expiry date exists.

What is the purpose of recording the identification number of the authorisation or an equivalent means?

The identification number of the authorisation (or equivalent means) is recorded to identify the link between the authorisation and the staff member that holds the authorisation.

AMC1 21.A.5 (d) & (e) Record-keeping

Q: How long must a design or production organisation retain the record of a staff member after the staff member leaves the organisation or changes position?

The record must be kept 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 sooner.

Q: What is the minimum retention period for records of authorisation of production staff whose activity is essential for ensuring conformity to applicable design data or a condition for safe operation?

Records of authorisation of such production staff must be archived for at least 3 years after the staff member is no longer employed by the organisation or as soon as the authorisation is withdrawn.

Q: Which specific points in Part 21 require the independent verification function of demonstration of compliance, and are those persons covered by this record-keeping AMC?

The independent verification function of demonstration of compliance is pursuant to point 21.A.239(d)(2). Yes, persons carrying out that function are covered by the record-keeping requirements of AMC1 21.A.5(d) and (e).

Q: What is the minimum information to be recorded for each person that exercises the privileges of an organisation approved according to points 21.A.163 or 21.A.263?

The minimum information includes: name; date of birth; basic training received and standard attained; specific training received and standard attained; continuation training received (if appropriate); experience gained; scope of the authorisation; date of first issue of the authorisation; expiry date of the authorisation (if appropriate); identification number of the authorisation (or equivalent); and changes to the data.

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AMC1 21.A.5 (d) & (e) Record-keeping

ED Decision 2022/021/R

RECORD OF STAFF INVOLVED IN DESIGN OR PRODUCTION

(a) The following should be the minimum information to be recorded for each person that exercises the privileges of an organisation that is approved according to Part 21, Subparts G and J, or according to points 21.A.163 or 21.A.263, or that carries out the independent monitoring of compliance and adequacy according to points 21.A.139(e) and 21.A.239(e), or that carries out the independent verification function of demonstration of compliance pursuant to point 21.A.239(d)(2):

(a) name;

(b) date of birth;

(d) specific training received and standard attained;

(e) continuation training received (if appropriate);

(f) experience gained;

(g) scope of the authorisation;

(h) date of first issue of the authorisation;

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

(j) identification number of the authorisation (or equivalent means to identify the link between the authorisation and the staff member that holds the authorisation); and

(k) changes to the data.

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

(c) The staff member should be given reasonable access, on request, to their own records as per Regulation (EU) 2016/679.

(d) A design organisation (DO) or production organisation (PO) should keep the record 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 sooner.

(e) Records of authorisation of the production staff are to be archived for at least 3 years after the staff member is no longer employed by the organisation or as soon as the authorisation is withdrawn. This staff member is any person that has an activity that is essential for ensuring:

— the conformity to applicable design data, or

— a condition for the safe operation of a product, part, or appliance.

Details

Source-Title: AMC1 21.A.5 (d) & (e) Record-keeping View latest amendments

Erulesid: ERULES-1963177438-20312 Compare versions

Domain: Initial airworthiness

Amendedby: Issue 2, Amendment 14

Applicabilitydate: 7 March, 2023

Entryintoforcedate: 20 December, 2022

Regulatorysource: ED Decision 2022/021/R Navigate

Regulatorysubject: Part-21

Typeofcontent: AMC to IR (Acceptable means of compliance to implementing rule)

Origin: EASA

Category: EAR