Opinion: Are Back-To-Birth Trace Documents Help Or Hindrance?

Thoroughness of documentation is a good thing, but perhaps a definitive standard is needed to satisfy trace requirements.

In engine transactions, one issue that continues to crop up is how back-to-birth trace documentation is used.

It is fair to say there is still no set list of documents or accepted industry standard that describes what is required to show sufficient trace for an engine and its life-limited parts (LLP). As such, it is an objective process and one which, in my experience, has caused issues on potential aircraft engine transactions.

The FAA requires the operator of an incoming aircraft or engine to establish that the current status of LLPs is true and correct. The FAA has provided some guidance on what might be acceptable, but it is: (a) only guidance, (b) not definitive and (c) subject to differing interpretation and objectivity. The European Aviation Safety Agency seems not to have moved much further on this topic since 2014, when it acknowledged that the concept of in-service history should be introduced but stopped short of advocating keeping records from “birth.”

Take, for example, “dirty finger print” cards or DFPs—the task lists completed by the MRO engineer when repairing or overhauling an engine part. These cards are produced by the MRO for its internal record-keeping. At the end of a repair or overhaul, the MRO will certify that part with the relevant paperwork, so why then is that not sufficient? It seems akin to asking to see someone’s completed exam paper as well as their certificate of qualification. Are MROs prepared to accept that these internal records may attract liability in the event of an engine failure? I am sure that is not what is intended.

It seems there is a growing desire to obtain every bit of paper pertaining to an engine, regardless of its actual value in assessing the quality of the engine.

Thoroughness in this industry is a good thing, but if it is interfering with deals and stifling transactions within the industry for no valuable reason, should the industry be doing more to agree to a definitive standard to satisfy trace requirements?

Daniel James is a senior associate at Stevens & Bolton LLP in London.


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