GM1 21L.A.7(a);(b) Record-keeping

RECORD-KEEPING AND ARCHIVING SYSTEM

The main purpose of record-keeping for organisations responsible for design and production is to ensure the retrievability of data required for the continued airworthiness of in-service products.

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

In the production environment, the records are 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, organisations responsible for design or production 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 required by points 21L.A.124, 21L.A.174 or in the manual/procedures required by point 21L.A.273 as appropriate.

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

— ensure the continued readability of the records;

— demonstrate to the competent authority the proper functioning of the records system;

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

— production data that supports the conformity of a product or part, 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 which supports the compliance of a product or part with the certification basis or applicable technical specifications, as well as data that is considered essential for continuing airworthiness is kept throughout the operational life of the product or part; such continued airworthiness data may include but are not limited to in-service occurrence reports and mandatory continuing airworthiness information;

— organisations responsible for design or production should ensure that the recording and record-keeping system used by the partners, suppliers and subcontractors meet the record-keeping objectives with the same level of confidence as 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.

* In relation 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);

— ‘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).