Electronic Recordkeeping

Q: Do we need operation specification (op spec) paragraph A025 (Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals/Documents)? The school is getting some pushback from the FAA when we say we do not use electronic signatures or electronic recordkeeping.
 
A: There are three tables included op spec A025:

• Table 1: Electronic signatures
• Table 2: Electronic recordkeeping
• Table 3: Electronic manuals/documents

 
For tables 2 and 3, if your program is accredited, they should read “The certificate holder meets the requirements of 147.23 [which requires that the school have a quality system, or be accredited] by being accredited.” Even if your accredited program does not keep electronic versions of records, manuals, and/or documents, it’s still good for this language to be present in your operations specification. Alternatively the paragraph would state that your program does not use electronic records, which is fine, but will require a change to your operations specifications if/when you decide to transition.
 
If your program is not accredited, these tables will include statements that you do not use electronic recordkeeping, or a reference to (or description of) your recordkeeping system.
 
Table 1 (electronic signatures) is only speaking to signatures affixed to A&P student certificate of completions and authenticated documentation—since that’s the only “recordkeeping” required by part 147. All programs, no matter if they are accredited or not, need to provide a description of (or reference to) their electronic signature procedures. For example, what type of electronic signature does the program use, how does it ensure those signatures are kept secure, how will final documents be secured to ensure the signature isn’t removed or copied, etc.?
 
Alternatively, this table can remain blank if electronic signatures will not be used on authenticated documentation or certificates of completion.