SINGLE PILOT, SINGLE PILOT IN COMMAND, AND BASIC FULL FAR PART 135 OPERATORS
Operators Using Electronic Manuals, Recordkeeping, and Signatures
The FAA recently updated the standards for certificate holders who use electronic manual systems including electronic signatures and electronic recordkeeping systems. This will include revised OpSpec, MSpec, TSpec, and a revised LOA (A025), which is the FAA's authorization to use these electronic systems. A six month transition period has been established for operators to make the necessary changes.
Who is affected?
The following entities who either currently use or are planning to use electronic signatures, recordkeeping, and signatures (taken from AC 120-78A):
Foreign air carriers or foreign persons operating a U.S.-registered aircraft in accordance with 14 CFR part 129, 129.14
-Certificate holders conducting operations in accordance with 14 CFR part 121, 125 (including part 125 Letter of Deviation Authority (LODA) holders), 133, 135, or 137.
-Fractional ownership program managers conducting operations in accordance with 14 CFR part 91 subpart K (part 91K).
-Operators conducting operations in accordance with part 91.
-Airmen certification course operators who provide instruction and evaluation in accordance with 14 CFR part 61, 63, 65, 141, or 142.
-Persons performing airmen certification in accordance with part 61, 63, 65, 141, or 142.
-Individuals performing maintenance or preventive maintenance in accordance with 14 CFR part 43.
-Repair stations operating in accordance with 14 CFR part 145.
-Aviation maintenance technical schools who provide instruction and evaluation in accordance with 14 CFR part 147.
-Organization Designation Authorization (ODA) holders in accordance with
14 CFR part 183 subpart D.
Basically, this change will affect all Air Carriers, Maintenance Facilities, and Training Centers who are currently approved to use:
-Electronic Flight Bag (EFB) manuals and procedures
-Electronic Weight and Balance procedures
-Flight Planning systems and other hardware/software applications
-Ipad tablets and Apple products and devices
-Microsoft, Google and Android products and devices
What documents are affected by this change?
AC 120-78A applies to the following categories (taken from AC 120-78A):
-Certification of Training or Qualification
-Fitness for Duty
-Operational Control Briefing
-Preflight Risk Analysis Worksheet
-Continuous Airworthiness Maintenance Program (CAMP) Extended Operations (ETOPS) Predeparture Service Check
-Training and Qualification
-Flight, Duty and Rest
-ODA Records and Reports
-Effective March 9, 2018, Safety Management System (SMS) Records required by 14 CFR part 5, § 5.97
-General Operations Manuals
-Air Carrier Manuals used in operations
-Flight Operations (including dispatch, flight following, and onboard/cabin)
-Ground Operations (including ground and passenger handling)
-Certificate Holder Aircraft Performance Manuals (Airplane Flight Manual (AFM) and Weight and Balance (W&B) information, etc.)
-Maintenance (including overhaul, standard practices, etc.)
-Minimum equipment list (MEL)
-General Policy and Procedures
-User (e.g., Flight Management System (FMS), Flight Planning System, etc
ACCG can help you update your existing policies and procedures for electronic signatures, electronic recordkeeping systems and electronic manual systems in accordance with the new standards.
Advisory Circular, AC 120-78A, describes an acceptable means for certificate holders to utilize electronic signatures, electronic recordkeeping, and electronic systems. We've included a link to this Advisory Circular below: