Advisory Circular 120-78A (pdf), “Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals,” gives FAA guidance on the use of electronic logbooks. Summary, with added emphasis:
This advisory circular (AC), as any AC, is not mandatory and does not constitute a regulation; rather, it provides standards and guidance for electronic signatures, electronic recordkeeping, and electronic manual systems. Electronic recordkeeping systems/programs are used to generate many types of records (e.g., load manifests, dispatch release, aircraft maintenance records, maintenance task cards, pilot training records, flight release, and/or airworthiness release). This AC describes an acceptable means, but not the only means, for a certificate holder to utilize an electronic signature, electronic recordkeeping, and electronic manual systems.
This guidance does allow for certain certificate holders to proceed in transferring records and even digital images of hardcopy signatures to electronic recordkeeping systems. Read on for details.
Acceptable electronic signatures
Electronic signatures have many acceptable forms, with examples given in 2-1b.
b. Types of Electronic Signatures. Electronic signatures may appear in various formats. No matter the format, they must meet the legal requirements of electronic signing that appear in subparagraph 2-1c. Examples of electronic signature formats include, but are not limited to:
- A digitized image of a handwritten signature that is attached to an electronic record;
- An electronic code (e.g., a secret code, password, or personal identification number (PIN)) used by a person to sign the electronic record;
- A unique biometrics-based identifier, such as a fingerprint, voice print, or a retinal scan; or
- A digital signature.
Transfer of records and signatures
Digitizing or scanning paper logs in terms of the AC is transferring data from a legacy system, covered in 3-3b.8 and 3-3b.9.
(8) Transferring Data. Technological advances may make it desirable or necessary for a certificate holder to update its electronic recordkeeping system or transfer data to a new system. The certificate holder must have policies and procedures that ensure the continued integrity of record data when a certificate holder moves records from one system to another. This could entail running redundant systems for a brief period of time.
(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.
Moving ahead
Subparagraph 1-8e gives broad latitude on moving forward.
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 part 61, 63, 65, 91 (excluding 91K), 137, or 183 does not require formal FAA approval, acceptance, or authorization. OpSpec (including an MSpec/TSpec/LOA) A025 does not apply to operations under these parts. The FAA recommends that all certificate holders adopt the standards for electronic signatures, records, and manuals as set forth in the AC, regardless of whether or not approval, acceptance, or authorization is required. If a required signature, record, or manual is provided in an electronic format or application that does not meet the standards set forth in this AC, the FAA may question its validity. If the FAA determines that an electronic signature, record, or manual does not meet the standards or is otherwise unacceptable, the FAA office with oversight responsibility will notify the certificate holder in writing. Upon receiving notification, it is incumbent upon the certificate holder to make the appropriate corrections.
Complete electronic records
Chapter 3, “Electronic Records,” details the elements that should or must be in an electronic aircraft logbook, pilot logbook, etc.
3-1. ELECTRONIC RECORDS. An electronic record must provide equivalent or better data integrity, accuracy, and accessibility to what would otherwise be provided by a paper record. In general, a record preserves the evidence of an event. It should contain enough information to clearly depict the event that took place. It is the certificate holder’s responsibility to address all 14 CFR requirements for their recordkeeping system(s) applicable to their operation(s).
3-2. FAA STANDARDS FOR ELECTRONIC RECORDS. To be considered complete and
valid, an electronic record should contain at least the following information:
- The type of event that took place (e.g., training, maintenance performed, signing of a release, conduct of a flight, etc.);
- For a training event, information that shows compliance with regulatory requirements, such as the name of the course module or subject, the number of hours of instruction, whether the student passed or failed, etc.;
- When the event took place (e.g., the date and time (where appropriate));
- Where the event took place (e.g., the station, training facility, maintenance facility, etc.);
- Who was involved in the event (e.g., crewmember, dispatcher, instructor,
mechanic, etc.);
- Aircraft type and registration number for pilot logbook records (when required by regulation);
- Certification, verification, or authentication of the event, such as a signature, where required by regulation; and
- Applicable aircraft, airframe, engine, propeller, appliance, component, or part make and model (M/M) for maintenance records, such as life-limited parts and time-in-service records.
Other guidance
AC 120-78A gives additional guidance on elements that electronic recordkeeping systems should provide.
- Security
- Protect confidential information
- Ensure that information is not altered in an unauthorized way
- Secure access and safeguard against unauthorized access
- Procedures
- Making required records available to FAA and NTSB personnel
- Quality Control
- Maintenance Support and Backup Measures
- Record Transfer
- Persons with Authorized Access
- Electronic Authentication, Signature, Validation, or Endorsement
- Training and User Instructions
- Transferring Data
- Continuity of Data Between Legacy and Electronic Systems
- Continuity of Records for Maintenance Providers
- Responsible Personnel
- Description of Electronic Recordkeeping System(s)
- Facilities, hardware, software
- Identify records to be maintained
- Identify records subject to electronic signature
- Changes to the Electronic Recordkeeping System
- Audit Procedures
AC 120-78A Table of Contents
- General Information
- Electronic Signatures
- Electronic Recordkeeping
- Electronic Manual Systems
- Voluntary Discontinuance by the Certificate Holder
- Administrative
Appendix: Sample Letter of Intent
