U.S.

Department Advisory
Circular
of Transportation
Federal Aviation
Administration
Subject: Service Difficulty Reporting System Date: 11/1/23 AC No: 20-109B
(Air Operator/Air Agency/General Initiated by: AFS-300 Change:
Aviation/Unmanned Aircraft
Systems)

1 PURPOSE OF THIS ADVISORY CIRCULAR (AC). This AC describes methods the

Administrator prescribes per Title 14 of the Code of Federal Regulations (14 CFR)
part 91, § 91.1415; part 125, § 125.409; and part 135, § 135.415; and accepts per
part 121, § 121.703 and part 145, § 145.221 for reporting in-service product and article
failures, malfunctions, and defects. The Federal Aviation Administration (FAA) also
encourages Service Difficulty Reporting by the General Aviation (GA) community. The
contents of this document do not have the force and effect of law and are not meant to
bind the public in any way, and the document is intended only to provide information to
the public regarding existing requirements under the law or agency policies.

2 AUDIENCE. This AC solicits Service Difficulty Reporting participation from all

segments of the aviation communities that operate and maintain aircraft in the U.S.
National Airspace System (NAS). This AC promotes use of the Administrator’s Service
Difficulty Reporting System (SDRS) database accessed at https://sdrs.faa.gov. The
overarching purpose of Service Difficulty Reporting is to promote safe operations and
improve the operational performance and reliability of products and articles produced
under 14 CFR part 21.

2.1 GA Community. The SDRS database is available to GA owners, operators, and

maintainers. GA Service Difficulty Reporting adds value and improves the overall safety
of the entire NAS. This AC encourages the GA community to participate in this reporting
process. Submitters may remain anonymous.

2.2 Small Unmanned Aircraft System (UAS) Aircraft. Service Difficulty Reporting does
not apply to small UAS operated under 14 CFR part 107. However, if a small UAS
operator is conducting a part 135 operation, they are required to submit a Service
Difficulty Report (SDR) per § 135.415. In addition, a small UAS that operates over
human beings must, per § 107.140(b), have an Airworthiness Certificate (AWC) issued
under part 21. The Production Approval Holder (PAH) of this type small UAS would
benefit from SDR data and information that shows a failure, malfunction, or defect
caused or could have caused an unsafe condition in the NAS.

3 WHERE YOU CAN FIND THIS AC. You can find this AC on the FAA website at
https://www.faa.gov/regulations_policies/advisory_circulars and the Dynamic Regulatory
System (DRS) at https://drs.faa.gov.
11/1/23 AC 20-109B

4 EFFECTIVE DATE. The effective date of this AC is November 1, 2023.

5 EXPLANATION OF CHANGES. This revision emphasizes the use of the SDRS

web-based database as the Administrator’s prescribed and acceptable method of Service
Difficulty Reporting for all operations including GA (as discussed in paragraph 1). The
SDRS web-based database includes UAS operator reporting guidance.

6 WHAT THIS AC CANCELS. AC 20-109A, Service Difficulty Program (General

Aviation), dated April 8, 1993, is canceled.

7 SAFETY MANAGEMENT SYSTEM (SMS). A certificate holder (CH) under 14 CFR

part 119 authorized to conduct operations in accordance with the requirements of
part 121 must (per 14 CFR part 5, § 5.1) have an SMS that meets part 5 requirements and
is acceptable to the Administrator. Section 5.71(a)(5) requires investigations of incidents
and accidents.

7.1 AC 120-92, Safety Management Systems for Aviation Service Providers. AC 120-92
promotes the FAA view that each person who participates within the NAS, including
part 145 repair stations, should develop, implement, and apply SMS constructs that
govern their operations.

7.2 FAA SMS. FAA Order 8000.369, Safety Management System, requires Aviation Safety
(AVS) to have an SMS, and FAA Order 8040.4, Safety Risk Management Policy,
requires AVS to exercise Safety Risk Management (SRM) as it performs its safety duties
and responsibilities.

8 THE FAA’s SDRS DATABASE. The FAA’s SDRS database (https://sdrs.faa.gov)

receives SDR data and information in a centralized location that PAHs, CHs, operators,
maintainers, and the FAA use to improve product and article safety and reliability.
Preservation of sterile SDR safety data and information in the SDRS database permits
authorized persons to access and collate it, to apply SMS and SRM principles, and to act
proactively to mitigate safety risks associated with product and article failures,
malfunctions, or defects.

8.1 Event Details. Service difficulty events require operators and maintainers to identify and
report timely, accurate, and complete data and information that §§ 91.1415(e),
121.703(e), 135.415(e), and 145.221(b) specify. In the interest of safety, part 125 CHs (as
they comply with § 125.409(a)) and part 91 GA operators should submit as much
information as possible (or as much as they are capable of) into the SDRS database.

8.2 Benefits to Sharing Operational Safety Data and Information. A service difficulty
can occur due to a flaw within a product or article manufactured under part 21 caused by
a manufacturing process or design data error. They can also occur due to deficient or
misapplied maintenance/inspection programs and/or procedures used to maintain a
product or article. The goal of Service Difficulty Reporting is to promote safe operations
by identifying these deficiencies and acting proactively to eliminate them.

2
11/1/23 AC 20-109B

8.2.1 PAH Review and Investigation of Service Difficulty Reporting. Manufacturers required
by part 21, § 21.3 do not use the SDRS database to report failures, malfunctions, and
defects. Rather, AC 21-9, Manufacturers Reporting Failures, Malfunctions, or Defects,
covers such reporting. However, per § 21.3(f), upon request by the FAA, the PAH must
report to the FAA the results of its investigation and any action taken or proposed to
correct a defect when an SDR shows that a product or article manufactured under part 21
is unsafe because of a manufacturing or design data defect. If action is required to correct
the defect in an existing product or article, the holder of that production approval must
send the data necessary for issuing an appropriate Airworthiness Directive (AD) to
the FAA.

8.2.2 Continuous Airworthiness Maintenance Programs (CAMP). A person issued an FAA

Operations Specification (OpSpec)/Management Specification (MSpec) D072, Aircraft
Maintenance – Continuous Airworthiness Maintenance Program (CAMP) Authorization,
as well as the Administrator, have the responsibility per § 91.1431, 121.373, or 135.431
to continuously analyze and assess the performance and effectiveness of their CAMP.
Service Difficulty Reporting is often the output of these assessments and in addition,
reviewing data and information within the SDRS database can help them improve their
CAMP.

8.2.3 Repair Station Self-Evaluation. A repair station may want to include in its self-evaluation
procedures required by § 145.211, a review of SDR data and information. Service
Difficulty Reporting provides operational performance data and information concerning
articles.

8.2.4 Administrator Oversite of GA Programs. Service Difficulty Reporting provides the

Administrator with data and information it uses per § 91.215(a) to determine if revisions
to an approved aircraft inspection program under § 91.409(f)(4) or § 91.1109 are
necessary for the continued adequacy of the program.

9 METHODS OF SUBMITTING SDRs.

1. Preferred method: SDRS website at https://sdrs.faa.gov. Access to computers and the

internet is now widely available to the public. Places such as libraries enable a person
to use this prescribed and acceptable method. This website greatly reduces the filing
burden on both the filer and the FAA. To access this site, see paragraph 11.1 of
this AC.
2. Backup method: While not preferred, FAA Forms 8010-4, Malfunction or Defect
Report, and 8070-1, Service Difficulty Report, are available for use. This type of
submission should be rare (e.g., related to system outages, internet issues, or lack of
computer access). These submissions can be sent by email to 9-AMC-AFS-
[email protected], transmitted by fax at 405-954-4655, or sent by U.S. mail to:
Manager, Aviation Data Systems Branch
P.O. Box 25082
Oklahoma City, OK 73125

3
 11/1/23 AC 20-109B

10 SERVICE DIFFICULTY REPORTING.

10.1 Objective. The objective of Service Difficulty Reporting is to collect and consolidate
reported data and information into a common data bank, allowing it to be distributed
amongst the aviation community, including the FAA’s AVS organization. Various
divisions, sections, groups, and offices within AVS collate the data and information and
use it to analyze and assess operational reliability of aeronautical products and articles.
AVS has the responsibility to identify and react proactively to in-service trends,
reliability issues, or unsafe conditions. When analysis of data and information
substantiate reliability issues or unsafe conditions, AVS can often preclude their negative
effects and/or reoccurrence elsewhere by taking proactive mitigating actions.

10.1.1 Service Difficulty Reporting Evaluations. Evaluating service difficulties helps AVS
Aircraft Certification Service (AIR) branches and Certificate Management Sections, as
well as Flight Standards (FS) Air Carrier Safety Assurance (ACSA) offices and General
Aviation Safety Assurance (GASA) offices, determine what (if any) corrective action is
required to remedy an unsafe condition in a product or article. In addition, reporting
service difficulties provides valuable statistical data that manufacturers, air carriers, air
agencies, operators, and maintainers can all use to evaluate their inspection and
maintenance programs’ performance and effectiveness, as well as measure how reliable a
product and article is under their specific operating conditions.

10.1.2 Reporting Performance Issues. Instructions for continued airworthiness that are
inaccurate should be reported. Human error is not reportable. An organization’s SMS or
other Quality Management System/Risk Management System should discern whether to
report instructions for continued airworthiness in SDRS or not. The organization has the
responsibility to address their manuals when their instructions and procedures are
deficient and to report the deficiency to the PAH when it is derived from a PAH
instruction.

10.2 SDR Title and Terminology Clarifications. Section 91.1415, applicable to part 91
subpart K (part 91K) operations, is titled “CAMP: Mechanical reliability reports.”
Mechanical Reliability Reports (MRR) is an older term that is synonymous with “Service
Difficulty Report.” The regulation in part 91K was ongoing at the time of the title
change, and as a result, it still carries the old title. The SDRS website
(https://sdrs.faa.gov) directs GA reporting to create a Malfunction or Defect (M or D)
Report and fill out FAA Form 8010-4. SDR regulations in parts 121, 125, 135, and 145,
and FAA Form 8070-1 are all titled “Service Difficulty Reports.” The stated objective
above is the same regardless of the title and terminology. The data and information in
MRRs, M or D Reports, or, as they are commonly called, SDRs, is collected and stored in
the SDRS database by the Aviation Data Systems Branch in Oklahoma City, Oklahoma.

10.3 Benefits of Reporting. Such reporting serves the public in several ways. First, the
statistical record of all such reports provides the FAA with the knowledge of the
effectiveness of current airworthiness (AW) certification and maintenance program
standards. Second, the record of such reports provides knowledge of the effectiveness of
the CH’s maintenance programs. Third, the knowledge of these reports prompts other

4
11/1/23 AC 20-109B

CHs to take appropriate action, as necessary, to prevent similar mechanical or structural

problems in their aircraft fleet. Fourth, the record promotes the open sharing of safety
data and information with the FAA and allows it and all users and maintainers of a
product or article to trend the frequency of mechanical or structural problems. This
trending can provide knowledge that gives warning of present or imminent unsafe
operating conditions.

Note: The number of SDRs submitted is not an indicator of the mechanical

reliability or fitness of an aircraft fleet. Inquiries that make this connection are
inappropriate; rather, it indicates participation and a positive safety culture. AVS
internal divisions and offices have the primary responsibility for planning,
programming evaluations, and assessing the performance of manufacturers and
operators. Entities should direct questions regarding fleet performance to the
appropriate AVS oversight office.

10.4 Reporting Sources.

10.4.1 CH and Program Manager Reporting. The primary sources of SDRs are parts 121, 125,
135, and 145 CHs and part 91K program managers.

10.4.2 FS Office Reporting. FAA aviation safety inspectors may also report service difficulty
data and information when an FS office receives a report per § 121.374(h) or part 135
appendix G, § G135.2.8(h), conducts routine surveillance, or investigates an accident,
incident, occurrence, or event.

10.4.3 GA Community and Foreign Reporting Sources. Voluntary reports from the GA
community and foreign regulatory authorities enable the FAA to become more proactive
in mitigating safety risks from all segments of the aviation community.

10.4.4 UAS Part 135 Service Difficulty Reporting. UAS operators subject to § 135.415 should
access the Service Difficulty Reporting site at https://sdrs.faa.gov and select UAS
Part 135 Holders (see Figure 4).

11 AVIATION DATA SYSTEMS BRANCH. Regulatory Support Division, Aviation Data

Systems Branch is responsible for:

• The management of the SDRS database,

• The SDRS website, and
• The instructions and information posted on this website.

11.1 View and Access to the SDRS Website.

11.1.1 View and Access to SDRS. To gain access to the SDRS website, or if you have questions
concerning this website, contact the Aviation Data Systems Branch by email at 9-AMC-
[email protected], or by U.S. mail at this address:

5
11/1/23 AC 20-109B

Manager, Aviation Data Systems Branch

P.O. Box 25082
Oklahoma City, OK 73125

11.1.2 Instruction Aids. SDRS resource links, field instructions, single/batch instructions,
look-up tables, and an SDRS quick reference guide can be found at https://sdrs.faa.gov
(see Figures 1, 2, and 3 below).

12 INVESTIGATING SERVICE DIFFICULTIES. As discussed in paragraph 7 above,

exercising SMS constructs that include safety risk analysis and assessment enable a
person to determine what should (and should not) be reported. Those who are required to
submit SDRs should have manual procedures that explain how the operator will exercise
logical, safety-centric approach when making these decisions. The FAA’s regulatory
safety expectations are that SDRs reflect diligence, attention to detail, and proactive
efforts by those required (or if not required, those who choose) to report them. It is the
responsibility of product and article manufacturers, operators, maintainers, and the FAA
to apply systematic safety risk analysis and assessment in order to make informed safety
decisions and report very accurate and timely safety data and information. Once all facts
are gathered and the safety risk is established, a person is able to determine if a report is
required and what (if any) corrective action is necessary. Corrective action within an
SDR could require coordination between manufacturers and service providers. Corrective
actions should be sophisticated, well thought out, communicated to employees, and
shared with their industry stakeholders as much as possible.

12.1 AVS Review and Analysis of SDR Data and Information. AVS has the responsibility
and authority of the Administrator to react proactively to in-service trends, reliability
issues, or unsafe conditions as it realizes them. Concerning SDRS, AVS offices review
SDR data and information routinely and apply Order 8040.4 to determine what action
(if any) AVS needs to take to correct an unsafe condition.

12.1.1 AIR SDR Reviews. Within AIR, AIR branches and Certificate Management Sections
review SDRs per § 21.3(f) to identify potential unsafe conditions.

12.1.2 FS Review. Reviews by FS Safety Assurance (SA) AW principal inspectors (PI) may
lead to actions that are necessary to address immediate safety concerns. However, before
acting, or shortly thereafter, the AW PI should discuss the matter and confirm the
appropriateness of their actions with the following AVS organizations, as necessary:

• FS Aircraft Evaluation Division (AED).

• AIR branches and Certificate Management Sections.

12.2 Timely Reporting. It is important, for those who are required, to report the occurrence or
detection of failures, malfunctions, or defects within the time required by the regulations,
even if all the information is not available at the time the initial report is due. When
additional information, including information from the manufacturer or other agency,
becomes available, submit a supplement to the first report and reference the date and
place of submission of the first report as soon as possible.

6
 11/1/23 AC 20-109B

12.2.1 When an aircraft is out-of-service for more than 72 hours due to scheduled maintenance,
preventive maintenance, or alteration activity, and discoveries of service difficulty issues
are identified, the reporting time requirement (within 96 hours) begins after the work on
the aircraft is approved for return to service (refer to InFO 12005, Title 14 of the Code of
Federal Regulations (14 CFR) Part 121, § 121.703 “Service Difficulty Reports”).

13 REPORTING INSTRUCTIONS.

13.1 Required and Shared Information. Not all data fields in the SDRS or on an SDR form
are required by the regulations. The goal is to acquire as much data and detailed
information as possible so that the FAA, manufacturers, and safety conscious operators
can use it to assess fully the risks and conditions that may affect public safety.

13.2 SDRS Reporting Instructions. When you access the SDRS site at https://sdrs.faa.gov,
you will find on the right-hand side a list of “Resources.” Selecting the “View reference
documents” link will take you to “SDRS Field Instructions” that will lead you through
the data necessary for submission. (See Figures 1 and 2 below.)

Figure 1. SDRS Resource Links

7
11/1/23 AC 20-109B

Figure 2. SDRS Field Instructions

13.2.1 Single and Batch Submission Instructions. Instructions for “Single” and “Batch”
submissions can be accessed by clicking on the appropriate resource link from the SDRS
site. (See Figure 3 below.)

Figure 3. Single and Batch Submission Instructions

8
11/1/23 AC 20-109B

13.3 UAS Part 135 Service Difficulty Reporting Instructions. UAS operators subject to
§ 135.415 should access the SDRS site at https://sdrs.faa.gov and select UAS Part 135
Holders (faa.gov) (see Figure 4 below).

Figure 4. UAS – Part 135 Holders (faa.gov)

9
11/1/23 AC 20-109B

13.3.1 On the left-hand side of the UAS home page (titled UAS Part 135 SDR), you will see a
link titled “Reference Documents” (see Figure 5). Click on it, and it will lead you to
reporting instructions (see Figure 6 below).

Figure 5. UAS Part 135 SDR Home Page

Figure 6. Reporting Instructions

10
11/1/23 AC 20-109B

13.4 FAA Forms 8010-4 and 8070-1. The FAA forms are available for use if you do not have
a computer or access to the internet. If you do not have access to a computer and the
internet, you will need to visit your responsible Flight Standards office to acquire these
forms and answer questions. Instructions are included with FAA Form 8070-1. Your
responsible Flight Standards office has access to the SDRS site at https://sdrs.faa.gov.
Using this site is the preferred method of reporting. The FS office can assist you with
reporting using this preferred method, or can assist you with FAA Forms 8010-4
and 8070-1.

14 AC FEEDBACK FORM. For your convenience, the AC Feedback Form is the last page
of this AC. Note any deficiencies found, clarifications needed, or suggested
improvements regarding the contents of this AC on the Feedback Form.

Wesley L. Mooty
Acting Deputy Executive Director, Flight Standards Service

11
 Advisory Circular Feedback Form

If you find an error in this AC, have recommendations for improving it, or have suggestions
for new items/subjects to be added, you may let us know by contacting the Flight Standards
Directives Management Officer at [email protected].

Subject: AC 20-109B, Service Difficulty Reporting System (Air Operator/Air Agency/General

Aviation/Unmanned Aircraft Systems)

Date: _____________________

Please check all appropriate line items:

An error (procedural or typographical) has been noted in paragraph ____________

on page _______.

Recommend paragraph _____________ on page __________ be changed as follows:

______________________________________________________________________

______________________________________________________________________

In a future change to this AC, please cover the following subject:

(Briefly describe what you want added.)

______________________________________________________________________

______________________________________________________________________

Other comments:

______________________________________________________________________

______________________________________________________________________

I would like to discuss the above. Please contact me.

Submitted by: Date: ______________________