John Upham with AirVault explores how to manage aviation maintenance (Mx) records in the cloud at a Records Management conference sponsored by AeroPodium in London. Topics include: Saas; Why Cloud? and FAA & EASA regulations.
"It's All Up in the Air..." - A cloud-based approach to Mx Records Management
1. ”It’s All Up in the Air…”
A Cloud-based Approach to Mx Records Management
John Upham, VP-EMEA
AirVault
May 4, 2012
Event Hashtags:
#RecordsManagement
#Cloud
Twitter:
@aeropodium
@uphamj
@AirVaultCloud
3. Owners are primarily responsible for Mx records
– FAA – 14 CFR §121.363
– EASA – Part M, §A, Subpart B, M.A. 201 (a), (b)
– Leased Aircraft? Operator responsible
How long must operators retain aircraft
Mx records?
– FAA – 1 year, or until work superseded
– EASA – 3 years, or until work superseded
For engines: Keep everything until next overhaul
To preserve hull value: Keep everything until you
transfer the asset—aircraft or engine
Compliance Breeds Documents
3
4. Mx Records & Regulations
Owner & Operator Mx Records Systems:
– A Mx Records Manual must:
• specify the recordkeeping system
• preserves for retrieval and inspection - all required Mx
records
• Maintained for required time periods
– Must always contain all Mx records needed to
prove the current airworthiness of all operating
aircraft
– Records must be clear and legible
– All required records must be transferred with
aircraft when sold
– Operator must make all required Mx records
available for inspection…at any time
4
5. Mx Records & Retention
What Mx records to retain—and how?
– FAA – 14 CFR §91.47, 112.380, 121.380a, 135.439,
135.441
– EASA – Part M, §A, Subpart C, M.A. 305 et seq.
Are electronic Mx records approved?
– FAA – YES; Advisory Circular 120-78
– EASA – YES; Part M, § A, Subpart C,
M.A. 305(h), and Subpart F, M.A. 614a
Special e-records requirements
– System must prevent damage, alteration, loss
– One backup copy stored separate location
– Backup must be made with 24 hours of original
– All terminals must prevent unauthorized access
5
6. Mx Records & MROs
FAA - 14 CFR § 145.219
EASA - Part M, § A, Subpart F, M.A. 614 et seq.
Must provide Mx record copies to the
owner or operator
Must retain the Mx Records for
– FAA - 2 years
– EASA - 3 years
Must make all required Mx records available
for inspection…at any time
6
12. Global Uptake of SaaS
$0.0
$2.0
$4.0
$6.0
$8.0
$10.0
$12.0
$14.0
$16.0
Global North America Western Europe Asia Pacific
12.3
7.8
2.7
0.7
14.5
9.1
3.2
0.934
2011 2012
12
In billions USD
Source: Gartner, Inc., 3/2012
13. What Do Cloud Vendors Provide?
13
SIMPLICITYCOMPLEXITY
14. Choosing a Cloud Vendor
Decide: public cloud or
private cloud?
Reputation, years in
operation, references,
discussions and site visits
with customers
Ask about SLA commitment
and actual uptime for the
past few years
Review security and
functionality audits
Ask about business
continuity, redundancy,
backups
14
16. Global Responsiveness
16
“As AirVault is a cloud-based
system…we tested carefully the
responsiveness and performance
from our several outstations. At
all times, we were able to load,
index, search, retrieve, and share
documents without any delay.”
— Jörgen Olsson
Scandinavian Airlines