Product Focus: Protecting Your Records Can Save Your Business

Vital Records Protection (VRP) describes the guidelines and best practices whereby an organization will be assured of the protection of its vital records in the event of some form of unplanned or unexpected event.

During the past few years, adequate VRP has become an essential policy in almost all industries and areas of government. The proper securing and protecting of paper and vital digitally based documents has become commonplace and is often a requirement by law. Vital records will document an organization’s legal and financial positions and preserve the rights of employees, customers and stockholders in the event of a disaster. If a vital record is lost, damaged, destroyed or otherwise rendered unavailable, that loss becomes a disaster-within-a-disaster, affecting critical operations needed to recover from the initial disaster.

What is a Vital Record?

Vital records are typically defined as records containing information essential to the survival of an organization in the event of a disaster. Vital records typically make up a small percentage of the vast amounts of the recorded data that is created by a typical organization — normally five percent. However, a legal, medical, accounting and/or governmental entity may have a much higher proportion of active files and/or documents which would be classified as vital records. An FBO, MRO or other aviation maintenance organization would definitely fit into this high-level of active file category. Certain industries and areas of business (i.e. aviation) are held to higher standards for VRP. The market for pre-owned aircraft is booming, and each time there is a transfer of aircraft ownership or operational control, there are literally stacks of boxes of critical documents that accompany the aircraft — along with the bill of sale and registration of aircraft ownership.

Why is VRP an Issue for Aviation Maintenance Professionals?

The reason is that for the entire lifespan of an aircraft, the Federal Aviation Administration (FAA) requires a data archive consisting of records that pertain to all servicing, maintenance, repairs and alterations performed on all systems and parts of the aircraft. Recordkeeping systems and paper/electronic maintenance manuals, including inspection procedures manuals, quality assurance/inspection records, operations manuals and training manuals are required by Title 14 of the Code of Federal Regulations. These documents must be secured from destruction of any kind in order to pass them on to the next owner or operator of the aircraft as applicable for the new owner’s type of operation.

Listen to the Experts!

Fred Workley, an aviation consultant and expert on aircraft regulations, advises that there are several factors that need to be considered when it comes to storing and protecting the documents required for an aircraft transfer."The four most important reasons to secure transfer documents in UL-rated fireproof and water resistant containers are economic, regulatory, practical and airworthiness factors. For example, if an aircraft is missing documentation, then the economic value may be in question, possibly resulting in a reduced purchase price."

"UL" stands for Underwriters Laboratories, an independent, not-for-profit product safety testing and certification organization that tests products for public safety. It is imperative to use fireproof filing cabinets and safes that are tested by Underwriters Laboratories or other nationally known independent testing labs.

According to Workley, regulatory issues clearly stipulate that owners need to maintain documentation, possibly in the form of a paper trail of these documents, outlining, in detail, the description of any work performed on the aircraft, completion dates, name and signature of the person performing the work, and the type of certification held by that person who approves the successful completion of the maintenance or repair to that aircraft.

Practical factors include any documents that will support the configuration of the aircraft as well as the information pertaining to what types of equipment, repairs or alterations have been made to the aircraft and what type of information was used to make such assessments.

The airworthiness factor is used to determine if the aircraft is safe and reliable and that all parts were designed to operate on an aircraft. Aircraft parts are held to a very specific quality standard and parts designed for a different type of vehicle may not be installed on an aircraft.

VRP Basics

To totally assure against any possible destruction or loss of the information contained in the recordkeeping system, aircraft owners or operators and those responsible for maintenance are encouraged to store all originals and backups in a separate offsite location, thus ensuring the vital records are properly protected from fire, water damage, theft or any other disaster. Organizations still have to address how to guarantee vital records are secure and protected while they remain onsite. Also, note that while offsite storage of vital records can be a viable option for archived records, for current information (such as daily backups and transaction records) storing vital records offsite requires such a high degree of discipline and coordination that it becomes extraordinarily expensive and time-consuming to try to move every backup to an offsite location. At the end of the day, it is unfeasible to rely 100 percent on offsite for VRP, especially for smaller airports and aircraft dealers.

Electronic signatures to satisfy maintenance and certain operational record retention requirements are now in use and there is guidance for the use of electronic maintenance recordkeeping systems. But, the reality is that the "paperless office" (a term that has been used for at least 20 years) is far from imminent. In fact, not all vital records are good candidates for digitization. In many cases, it’s cheaper and more efficient to store and protect paper records than to digitize them.

Paper is more durable than other media and withstands a wide range of humidity levels and heat up to approximately 400°F before igniting. They must be stored in an environment that will stay below 125°F and 80 percent humidity in order to be protected.

The Bottom Line

The bottom line is that not being able to produce the proper documentation — paper or digitally stored — could result in delay or even the cancellation of a sale or transfer for that aircraft. The result may be down time or grounding of the aircraft where no money is made from the valuable asset.

Takeaway

The lesson for the entire aviation community is that the only way to ensure a smooth transaction from owner-to-owner or owner-to-operator is to make sure that all of the proper documents are available, complete, accurate and secure from destruction of any kind. Using UL-rated fireproof and water resistant filing cabinets (and media vaults in the case of digitally stored records) is the best option when it comes to storing important and valued aircraft documentation.

Key issue: recovery of the vital records in the event of a disaster

The final key element of the overall vital records approach is the recovery strategy. This should be based, of course, on a thorough and detailed knowledge to include the location of vital records (both onsite and offsite) and the level of information contained in master lists and indexes.

The best practices procedures for the removal of vital records in the event of a disaster should include:

• Prioritization categories of vital records in the event of a recovery mission;

• A tracking plan;

• Designation of one or more secure relocation destinations;

• Primary and backup transportation arrangements;

• The offsite vendor’s 24-hour contact information;

• Necessary clearances and permits; and

• Contact information for internal personal assigned to accompany the records - the responsible party must also be trained on the handling and preservation techniques based on the specific media involved.

Key issue: offsite vs. onsite VRP?

The overwhelming trend is more and more companies are shifting to a combined onsite/offsite approach. Even with this combined approach, the emphasis, however, is on onsite storage, for many reasons, including quicker retrieval, lower cost and increased control. At the end of the day, however, it’s just not feasible to rely 100% on offsite. The question remains: how do you ensure your vital records are secure while they remain onsite? Keep daily backup copies onsite in a secure, fire-protected location, in a fire resistant file or vault, and for archival (such as annual, monthly or even weekly backup) records, supplement that backup with offsite.

CEO, FireKing Security Group