I get asked the question all the time: do I need to scan my existing paper records and convert them to digital in order to move forward with an Electronic Record Keeping System? Simply stated, the answer is … NO.
IF YOU’RE A PART 91 OPERATOR
AC120-78A Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manuals states in Section 1-8, paragraph e: There is No Requirement for Formal Approval, Acceptance, or Authorization for Part 61, 63, 65, 91 (Excluding 91K), 137, or 183. The use of an electronic signature, electronic recordkeeping system, or electronic manual system under parts 61, 63, 65, 91 (excluding 91K), 137, or 183 does not require formal FAA approval, acceptance, or authorization.
Clearly: no formal acceptance is required for Part 91 Operators to use an Electronic Recordkeeping System, or even an Electronic Signature for that matter. So, moving into an electronic record keeping program for part 91 operators is simply a matter of deciding which system to use.
IF YOU’RE A PART 91K, 125, 135, OR 145 CERTIFICATE HOLDER
AC120-78A Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manuals states in Section 1-8, paragraph c: Op Spec Authorization Required. The FAA will authorize the use of electronic signatures, electronic recordkeeping systems, and electronic manual systems via Op Spec A025. Op Spec authorization is required for parts 91K, 121, 125, 133, 135, 141, 142, 145, and 147. FAA guidance on the issuance of A025 can be found in FAA Order 8900.1, Flight Standards Information Management System (FSIMS), Volume 3, Chapter 18, Section 3, Part A Operations Specifications -General.
Most of AC 120-78A is devoted to FAA Authorization for certificate holders. And it has a lot to say. But, keep in mind, this is to replace the paper record keeping system, not to operate an electronic system side-by-side with the FAA accepted paper system described in your company’s Op Spec. Since most paper documents begin life as electronic documents, it only makes sense to update an electronic record with the electronic document, then print the document onto paper and update the paper record accordingly. That way, you have both systems updated and working on your behalf.
Once you are operating with both a paper system, and an electronic system you can begin to take advantage of the many benefits the electronic system offers. And, at the same time, keep the paper record safe and secure (and untouched) in the place it normally resides.
CONVERTING EXISTING PAPER RECORDS INTO ELECTRONIC RECORDS
The Advisory Circular does go on to say in Section 3-3, paragraph 9 Continuity of Data Between Legacy and Electronic Systems. The system should have a method of ensuring continuity of data during transition from a legacy (hardcopy) system to an electronic system.
What is doesn’t say is that the paper records must be converted to electronic before the operator adopts an Electronic Record Keeping System. Certainly, the easiest and most beneficial way to have continuity between the paper records and the electronic records is to scan and convert the paper records to electronic. But this shouldn’t stop us from using and benefiting from an electronic record keeping system right now.
The time to convert paper records to electronic records needs to be determined by the operator in concert with what is going on with the airplane at the time. The best time to convert paper to electronic is when the aircraft is in a large maintenance event, or about to be sold, or when you have the time to allow the access needed to scan the records.
THE BOTTOM LINE