The Short Answer
14 CFR §145.219 requires a certificated repair station to retain records, in English, that demonstrate compliance with Part 43 for each article it maintains. For maintenance work, that means the §43.9(a) content, a description of the work performed (or a reference to acceptable data), the date of completion, the name of the person performing the work if other than the approver, and the signature, certificate number, and kind of certificate of the person approving return to service. Records must be retained for at least 2 years from the date the article is approved for return to service and must be available for inspection by the FAA and the NTSB; the owner or operator is entitled to a copy of the maintenance release.
In practice, inspectors review §145.219 compliance as a four-link traceability chain: the work order (§43.9 content), the release documentation (maintenance release or FAA Form 8130-3), the receiving inspection record (QC-manual incoming inspection), and the maintenance data used (the §43.13 performance standard). An FSDO Principal Maintenance Inspector can break a finding at any link. Many surveillance violations are documentation failures, not maintenance quality failures.
Most Part 145 repair stations understand that they need to keep records. Fewer understand exactly what those records must contain, how long to keep them, and, most critically, what an FSDO inspector cross-checks during a surveillance inspection. This article decodes 14 CFR §145.219 provision by provision, maps each requirement to the audit finding it prevents, and explains the 2-year retention trap that catches shops off guard.
This post is part of FileFlo's Part 145 repair station compliance guide. For a broader look at the regulation's certificate requirements, start there. For the specific recordkeeping obligations that drive FSDO enforcement actions, read on.
Many surveillance findings are documentation failures, not maintenance failures
A repair station can perform technically excellent work and still generate FSDO findings, if the approving signature on the work order is missing its certificate information, a part can't be traced to receiving inspection, or the training records for the signing mechanic are expired. §145.219 compliance is a documentation discipline problem, not a skill problem.
14 CFR §145.219 Decoded: Every Provision
The regulation has four subsections, (a) through (d). Here is what each actually requires and why each provision matters during a surveillance visit.
The record-retention obligation
"A certificated repair station must retain records in English that demonstrate compliance with the requirements of part 43. The records must be retained in a format acceptable to the FAA."
What this means in practice
§145.219(a) requires records that demonstrate compliance with Part 43. For maintenance, preventive maintenance, and alterations, the record-content rule, and the make-the-entry command, is 14 CFR §43.9(a) , the four-element content standard that governs maintenance records across civil aviation. A work order missing any §43.9(a) element does not demonstrate Part 43 compliance, and that is a §145.219(a) finding.
The four §43.9(a) elements every work order needs
Description of the work performed, or a reference to data acceptable to the FAA
Must be specific enough that another qualified person could determine what was done. A vague entry like "routine maintenance performed" fails this test; a reference to the acceptable data used also satisfies §43.9(a)(1).
Date of completion of the work performed
The calendar date the work was completed. Not the date the paperwork was filled out.
Name of the person performing the work, if other than the approving person
When the technician who did the work is not the person approving it for return to service, §43.9(a)(3) requires the record to name the performer.
Signature, certificate number, and kind of certificate of the approving person
Under §43.9(a)(4), the signature constitutes the approval for return to service, §43.9 prescribes no separate statement or required language. An illegible signature with no certificate number or kind of certificate fails. (The repair station's airworthiness certification belongs on the maintenance release under §145.213(b).)
Common §145.219(a) finding
Incomplete approval-for-return-to-service signoffs, a signature with no certificate number or kind of certificate, or no named performer where §43.9(a)(3) requires one. Each deficient work order can be cited as a separate violation.
Maintenance release copy to the owner or operator
"A certificated repair station must provide a copy of the maintenance release to the owner or operator of the article on which the maintenance, preventive maintenance, or alteration was performed."
§145.219(b) entitles the owner or operator of the article to one specific document: a copy of the maintenance release. It does not create a general right for the owner or operator to inspect the repair station's internal records, record availability for inspection is a separate obligation under §145.219(d), and it runs to the FAA and the NTSB, not to customers.
Operators will still ask for more than the release
Although §145.219(b) only entitles the owner or operator to the maintenance release copy, aircraft operators frequently request repair station work orders years after the fact for insurance purposes, liability investigations, or pre-purchase evaluations. A repair station that discards records at the 2-year §145.219(c) minimum may satisfy the FAA obligation while failing a contractual or practical obligation to the operator.
The 2-year retention floor
"A certificated repair station must retain the records required by this section for at least 2 years from the date the article was approved for return to service."
The 2-year clock has a single start trigger:
Clock start
Date the article was approved for return to service
This is the date of the approving signature in the work order, the date the article was released back to the owner or returned to service on the aircraft. It can fall later than the date the work was physically performed, so purging records by work date alone can cut the retention window short.
The 2-year minimum is a floor, not a ceiling
Most Part 145 repair stations should retain records substantially longer than 2 years. Aircraft operators keep §91.417 status records (total time, life-limited parts status, inspection status, AD status) with the aircraft for as long as they operate it. A repair station discarding records at exactly 2 years creates a gap in the operator's practical traceability chain, and may face operator or insurer demands for records years later that they cannot meet.
Records available for inspection, FAA and NTSB
"A certificated repair station must make all required records available for inspection by the FAA and the National Transportation Safety Board."
§145.219(d) creates an affirmative production obligation. The regulation doesn't say records must exist and be findable eventually, it says they must be available for inspection. A repair station that technically has records but can't produce them promptly during a surveillance inspection faces the same functional finding as a shop that never made the records. "I'll look for it" is not a compliant response during a surveillance visit.
The Six Record Types §145.219 Touches
§145.219 sits at the center of a web of related record requirements across Part 145 and Part 43. Here is every record type that feeds a §145.219-related finding during a surveillance inspection, including the audit finding each prevents.
Work Orders (Maintenance Records)
14 CFR §145.219(a) + §43.9What's Required
Description of the work performed (or reference to data acceptable to the FAA), date of completion, name of the person performing the work if other than the approver, and the signature, certificate number, and kind of certificate of the approving person, the signature constitutes the return-to-service approval (§43.9(a)). Citing the specific maintenance data used (AMM, SB, OEM manual) is best practice, not a §43.9 mandate.
Retention Period
2 years from date article approved for return to service
Audit Finding Prevented
Approving signature missing the certificate number or kind of certificate; incomplete description of work performed. Each deficient work order can be cited as a separate finding.
FAA Form 8130-3 (Airworthiness Approval Tag)
14 CFR §145.213 + §43.9What's Required
Customary, not required by Part 145, for domestic maintenance release of parts and components; §145.213(b) requires certifying airworthiness on the maintenance release but prescribes no form. Required for export airworthiness approval and bilateral dual-release work (e.g., EASA). Identifies the part by part number and serial number, the maintenance performed, and the signer, a part 65-certificated mechanic or repairman authorized by the repair station (§145.213(d)). Should correlate to the work order.
Retention Period
2 years (correlates to work order retention)
Audit Finding Prevented
Part installed on aircraft cannot be traced to its release documentation (8130-3 or maintenance release) in the repair station records. Inspector flags untraceability as a §145.219 + §43.9 combined finding.
Receiving Inspection Records
14 CFR §145.211(c)(1)(i)-(ii)What's Required
Quality control system documentation that incoming raw materials are inspected for acceptable quality and that each article maintained receives a preliminary inspection, per the station's QC manual procedures. Stations typically verify part serviceable status, conformance to type design, and source (approved vs. unapproved) at receiving.
Retention Period
2 years (tied to work order using the part)
Audit Finding Prevented
Work order references a part with no corresponding receiving inspection record. Creates an open traceability gap, a common finding in repair station surveillance.
Training Program Records (§145.163)
14 CFR §145.163What's Required
Initial and recurrent training records for each employee authorized to perform maintenance, including OJT signoffs, classroom completion, and proficiency check records. Each employee's training must be current per the repair station's approved training program.
Retention Period
At least 2 years (14 CFR §145.163(c))
Audit Finding Prevented
Inspector finds employees who signed off work orders but have expired or incomplete training records. Creates both a §145.163 training finding and casts doubt on the validity of the affected work orders.
Tool Calibration Records
14 CFR §145.109(b)What's Required
Calibration of test and inspection equipment and tools used to make airworthiness determinations, to a standard acceptable to the FAA (§145.109(b)). Calibration events typically document the tool ID, calibration date, due date, calibration standard used, and calibrating technician, a QC-manual practice under §145.211(c)(1)(viii), not a CFR field list.
Retention Period
Duration of calibration cycle + 2 calibration cycles back (common practice)
Audit Finding Prevented
Out-of-calibration tool was used during the period covered by the work orders under review. Inspector can invalidate work performed with the uncalibrated tool and require re-inspection.
Contract Maintenance Records (§145.217)
14 CFR §145.217What's Required
FAA approval before a maintenance function is contracted to an outside facility, plus a current list of the maintenance functions contracted to each outside facility, including each facility's name and type of certificate and ratings, maintained and made available to the responsible Flight Standards office (§145.217(a)). Contracting to a noncertificated person adds quality-control, direct-in-charge, and verification conditions (§145.217(b)).
Retention Period
List kept current; the prime's own article records follow the §145.219(c) 2-year clock
Audit Finding Prevented
Maintenance function contracted out without FAA approval, or the contracted-functions list is missing, incomplete, or out of date. Inspector holds the prime responsible for the work it approves for return to service.
What an FSDO Inspector Cross-Checks on §145.219
FSDO Principal Maintenance Inspectors (PMIs) conduct repair station surveillance under FAA Order 8900.1, Volume 6, the surveillance volume. A §145.219 records review tends to follow a predictable pattern. Here is what the inspector typically examines and in what order.
Work order sample pull
The inspector selects a random sample of recently completed work orders, typically covering the last 6-12 months. Each work order is checked against the §43.9(a) four-element checklist. Any missing element (work description or data reference, completion date, performer's name where applicable, approving signature with certificate number and kind of certificate) is documented as a §145.219(a) finding.
How to pass this step cleanly: Having work orders organized by date and accessible without a search delays findings only; a well-organized shop with all four elements present on every work order ends this step clean.
Parts traceability, 8130-3 trace from work order to receiving inspection
For each part identified in the sampled work orders, the inspector traces backwards: work order → FAA Form 8130-3 → receiving inspection record. If any link in this chain is missing or the part number/serial number doesn't match across documents, the inspector flags it as a traceability gap. This is a common documentation finding in Part 145 surveillance.
How to pass this step cleanly: A physical or digital cross-reference log that links part numbers across all three documents (work order, 8130-3, receiving inspection) eliminates this finding for any inspector who follows the trace.
Maintenance data review, §43.13 methods
For each maintenance action in the sampled work orders, the inspector verifies the work was performed using methods, techniques, and practices acceptable to the FAA, the current manufacturer's manual or other data acceptable to the Administrator (§43.13). On the record side, §43.9(a)(1) is satisfied by a work description or a reference to acceptable data; citing the specific document and revision number is not mandated by rule, but generic entries like "per manufacturer's data" invite follow-up questions and slow the review.
How to pass this step cleanly: List the specific manual, chapter, and revision number used on every work order. It is not a regulatory requirement, but it takes 15 seconds per work order and pre-answers the inspector's data question.
Training record correlation
The inspector cross-checks the names on the sampled work orders against the training records for those employees. Under §145.163, every person who performs or supervises maintenance must have training appropriate to the work performed. An employee whose training records are expired, incomplete, or missing, who also signed work orders, generates both a §145.163 finding and a shadow finding on every affected work order.
How to pass this step cleanly: Sort training records by employee name and align with signatory names on work orders. Any employee with a lapsed training record who is still signing work orders is a dual-finding waiting to happen.
Tool calibration correlation
For work orders involving precision measurements or test equipment, the inspector checks whether the specific tools used were in calibration on the date of the work. Out-of-calibration tool use doesn't just generate a §145.109(b) calibration finding, it can require re-inspection of every article worked on with that tool during the out-of-calibration period.
How to pass this step cleanly: Calibration records should be cross-referenced by tool ID, not just kept in a separate binder. An inspector asking "what tools were used on this work order on this date" should get an immediate answer.
Contract maintenance documentation review
If maintenance functions are contracted out under §145.217, the inspector verifies the functions were approved by the FAA for contracting and that the station maintains, and can produce, the required list of contracted maintenance functions with each outside facility's name and type of certificate and ratings (§145.217(a)). For work sent to noncertificated persons, the inspector also checks the §145.217(b) quality-control, direct-in-charge, and verification conditions.
How to pass this step cleanly: Keep the contracted-functions list current and the FAA approvals on file. Retaining the agreement and a copy of the subcontractor's completed work order is good traceability practice, even though §145.217 does not require it.
See how your repair station scores before the inspector does
FileFlo's FAA readiness score reviews your record documentation across all six §145.219 checklist areas and shows you the findings an FSDO inspector would likely cite, before the surveillance visit. Takes under 10 minutes.
Check Your FAA Readiness Score, FreeThe 2-Year Retention Trap (And Why Most Shops Fall Into It)
§145.219(c)'s 2-year minimum looks like the safe number. It isn't, for most repair stations, it's the wrong number to optimize for.
Trap 1: The operator still needs the records after year 2
Aircraft operators maintain records under 14 CFR §91.417 for different periods, many items for the life of the aircraft. When an aircraft changes hands or goes through a pre-purchase inspection, the buyer's IA or DOM frequently traces work back to the original repair station's records. A repair station that discarded records at the 2-year minimum cannot respond to these requests and loses the ability to defend its own work in any liability scenario.
Trap 2: The clock runs from return-to-service approval, not the work date
§145.219(c) runs 2 years from the date the article was approved for return to service. For work that spans multiple days, or where the article sat before formal release, the approval date lands later than the date the work was physically performed. Shops that purge records based on work date alone risk disposing of records still within the mandatory retention window.
Trap 3: Inspection records sit inside the same retention scope
§145.219(c) covers "the records required by this section", everything retained to demonstrate Part 43 compliance, inspection entries included. Inspection records carry their own content rule at §43.11 (with performance rules at §43.15), separate from the §43.9 maintenance entries. Inspection records that are treated as transient (generated, filed, and discarded separately from work orders) are among the records most commonly missing when an inspector pulls a sample.
The practical answer: keep records for 7+ years
Most aviation attorneys and compliance consultants recommend repair stations keep records for a minimum of 7 years, comfortably beyond the 5-year federal civil-penalty statute of limitations (28 U.S.C. §2462) and aligned with common aircraft resale cycles. Digital storage makes this essentially costless. The risk of premature disposal (losing records an inspector, operator, or insurer needs) far outweighs the storage cost.
How §145.219 connects to the rest of Part 145
§145.219 doesn't operate in isolation. It ties to the Quality Control Manual requirements at §145.211, the training program at §145.163, equipment and calibration at §145.109, and contract maintenance at §145.217. A finding in any of those areas creates a shadow question over §145.219 records: were the people signing off work trained? Were the tools they used calibrated? Were the parts traceable?
For the full regulatory picture, see FileFlo's Part 145 compliance overview, A&P mechanic and IA certification requirements, and §145.211 quality control system breakdown.
Where FileFlo Fits for a Part 135 Operator
FileFlo is the compliance department for small trucking carriers and Part 135 operators. It is a read-only proof layer that sits alongside the maintenance stack and makes the records you already have audit-ready. It doesn't replace your maintenance tracking system, your A&P judgment, or your DOM. It is built for Part 135 operators.
For a Part 135 operator, FileFlo keeps maintenance program records on file with their status, watches the 91.409 annual for each aircraft on a 12-calendar-month cycle with the 100-hour on your meter readings, and opens an item 45 days before an annual comes due. The audit packet carries each document's standing, with an inspector link limited to one aircraft or one crew.
Maintenance program records on file
Maintenance program records are filed and shown as on file with their status.
The 91.409 annual, per aircraft
The annual is watched for each aircraft on a 12-calendar-month cycle; the 100-hour uses your meter readings.
Registry fields from the FAA file
Aircraft registry fields are filled from the FAA releasable aircraft file.
Inspector-format audit packet
An audit packet with each document's standing, and an inspector link limited to one aircraft or one crew.
FileFlo does not provide, run, or replace a Safety Management System (SMS), dispatch/FOS, or your aviation safety program. It keeps the documents that prove those systems exist and are maintained, audit-ready, at the moment the inspector asks.
Aviation starts with the Audit-Ready Crew Records Setup; 16 or more aircraft, air medical and fractional operations are priced by written quote. For the wider regulation, see the Part 145 repair station compliance guide.
Frequently Asked Questions
What does 14 CFR §145.219 actually require repair stations to document?
14 CFR §145.219(a) requires a certificated repair station to retain records in English that demonstrate compliance with the requirements of Part 43, in a format acceptable to the FAA. For maintenance, preventive maintenance, and alterations, the record-content rule is 14 CFR §43.9(a), which requires: (1) a description of the work performed, or a reference to data acceptable to the FAA; (2) the date the work was completed; (3) the name of the person who performed the work, if other than the person who approved it for return to service; and (4) the signature, certificate number, and kind of certificate held by the person approving the work for return to service, under §43.9(a)(4), the signature itself constitutes the return-to-service approval. Identifying the article by part number and serial number is not spelled out in §43.9, but it is the traceability practice an FSDO inspector follows during a surveillance visit, so treat it as part of a defensible work order.
How long must a Part 145 repair station retain maintenance records under §145.219(c)?
14 CFR §145.219(c) requires a certificated repair station to retain the records required by §145.219 for at least 2 years from the date the article was approved for return to service. That is the only clock the rule sets, there is no alternate work-completion trigger. The 2-year minimum is frequently exceeded in practice because aircraft operators must keep §91.417 status records (total time in service, life-limited part status, inspection status, AD compliance status) with the aircraft for as long as they operate it, and repair stations are regularly asked to produce records by operators or insurers well beyond the 2-year window. Digital storage with an auditable access log is the lowest-cost path to meeting both the regulatory floor and operator-driven retention demands.
What is FAA Form 8130-3 and when is it required for Part 145 work?
FAA Form 8130-3 (Airworthiness Approval Tag) is the FAA's authorized release certificate used to document that a part, component, or appliance was inspected and found to conform to approved design data and is in a condition for safe operation. Contrary to common belief, no Part 145 or Part 43 rule requires the 8130-3 for a domestic maintenance release, §145.213(b) requires the repair station to certify on the article's maintenance release that the article is airworthy with respect to the work performed, but it prescribes no specific form, so a §43.9-compliant work order or release document suffices domestically. The 8130-3 is required for export airworthiness approvals and for dual-release work under bilateral agreements (for example, work also released to EASA standards), and many repair stations use it domestically by choice because it creates a clean traceability link between the installed part and the approved data, the link an FSDO inspector cross-checks against the work order during a §145.219 records inspection. Missing or incomplete release documentation is a common surveillance finding.
What does an FSDO inspector actually cross-check during a §145.219 records review?
During a surveillance inspection, an FSDO Principal Maintenance Inspector (PMI) conducting a §145.219 records review will typically: (1) pull a sample of completed work orders and verify each contains the §43.9(a)-required elements (work description or reference to acceptable data, completion date, performer's name where applicable, and the approving signature with certificate number and kind of certificate); (2) trace parts used in those work orders to receiving inspection records and release documents such as FAA Form 8130-3 tags to verify the traceability chain is intact; (3) confirm the work was performed using methods and data acceptable to the FAA under §43.13, citing the specific manual and revision on the work order is not a regulatory requirement, but it pre-answers this check; (4) verify record retention meets the §145.219(c) 2-year minimum; and (5) check that records are actually available for inspection as §145.219(d) requires, not merely claimed to exist. Gaps in any of these areas generate surveillance findings.
Are Part 145 repair station records the same as the aircraft owner's §91.417 records?
No, they are parallel but distinct record sets. The repair station's §145.219 records are the shop's internal documentation of work performed, kept at the repair station for FSDO surveillance purposes. The aircraft owner's §91.417 records are the logbook entries and maintenance records kept with the aircraft. When a Part 145 repair station performs maintenance, the return-to-service entry made in the aircraft logbook (under §43.9, or §43.11 for inspections) satisfies the owner's §91.417 obligation, but the repair station's own work orders and 8130-3 tags are separate documents required under §145.219. An FSDO inspector can pull the repair station's copy of the work order even after the aircraft log has left the shop.
Can a Part 145 repair station use electronic records to meet §145.219?
Yes. The FAA has accepted electronic recordkeeping for Part 145 maintenance records under the general principle that electronic records satisfy the regulatory retention requirement if they are: retrievable in a readable form throughout the retention period, protected from alteration without detection (audit trail), and available to the FAA on request. Advisory Circular AC 120-78B (Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals) provides the FAA's current guidance on acceptable electronic recordkeeping practices. Electronic systems must also maintain the full §43.9 content, scanned handwritten records without digital classification against the correct regulatory element are a common gap that a purpose-built compliance platform addresses.
More Aviation Compliance Resources
FAA Aviation Compliance Hub
Part 91 · Part 135 · Part 145 · SMS · Drug Testing
Part 145 Repair Station Compliance Overview
§145.51 certificate · §145.211 QC manual · §145.163 training
Part 135 On-Demand Charter Compliance
§135.21 GOM · §135.293 pilot currency · §135.63 records
A&P Mechanic + IA Certification Requirements
14 CFR Part 65 · §65.91 IA eligibility · currency rules
Airworthiness Directives (AD) Compliance
14 CFR Part 39 · emergency ADs · recurring vs. one-time
FAA SMS 2027 Compliance Deadline
Part 5 SMS rule · Part 135/121 affected operators
14 CFR §145.211, QC System Requirements
Quality control system · QC manual · inspection procedures
14 CFR §43.13, Performance Rules (Maintenance)
Approved data requirement · workmanship standard
Know where your §145.219 documentation stands before the inspector does
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