Friday, October 20, 2017
Transport Canada - Aviation Safety Letter It’s Not Just Paperwork

It’s Not Just Paperwork

by Brian Whitehead, Chief, Policy Development, Standards, Civil Aviation, Transport Canada

Every now and again, an air operator has to be suspended for failure to comply with requirements. Almost inevitably, a representative of the operator will then be quoted in the press, saying something along the lines of: “The aircraft are all perfectly airworthy; it’s only a paperwork problem.” Now, saying that it’s “only” a paperwork problem, is a bit like a bank manager saying that he can’t balance the books, but there’s a lot of money in the vault! The fact is, that without the paperwork, there’s no way to know if the aircraft are airworthy. With the complexity of modern aircraft, the days when we could rely on a visual inspection alone are long gone. Accurate record keeping is now essential.

Record keeping covers a lot of territory. For example, it can include the records that an approved maintenance organization (AMO) keeps to show compliance with approved procedures. Some of those records, such as the so-called “dirty fingerprint” records contained on job cards, etc., may relate to specific aircraft. Others may be more general, covering personnel training, tool calibration, ground equipment, quality audit reports, and so on. The AMO retains those kinds of records to support its own operations.

This article will concentrate on another kind of record—the aircraft technical records required by Canadian Aviation Regulations (CARs) 605.92 through 605.97. In this context, the term “technical record” is not restricted to information written on the pages of a logbook. It also includes x-rays, drawings, flight test reports, etc. In short, any information that has direct bearing on the physical state of the aircraft, or its compliance with standards, is part of the aircraft technical records. The aircraft operator retains these records, which must accompany the aircraft throughout its working life. Their purpose is to establish the aircraft’s condition and compliance with its type design. Transport Canada publishes logbooks that are suitable for many small aircraft, but no one document can cover all circumstances, so operators of more complex aircraft are encouraged to develop their own systems.

For the purposes of CAR 605, aircraft technical records consist of: a journey log; separate records for the airframe, each installed engine and each variable-pitch propeller (often known collectively as the “technical log”); and a weight and balance report. The airframe, engine and propeller records may be further subdivided into separate records for each of the main components involved. This usually applies to engine modules, for example, or to the main transmission components of helicopters. The technical records as a whole are transferred, along with the aircraft, when the latter is sold or leased. They must include the minimum information specified in Schedules I and II of CAR 605.

The journey log is a day-to-day working document. It serves as the formal means of communication between successive pilots, and between pilots and maintenance personnel. As the name implies, the journey log travels with the aircraft, and provides an up-to-date “snapshot” of the aircraft’s condition at any given point in time. It contains a record of each flight, including details of any problems that occurred, as well as any other information needed by the pilot, such as any outstanding defects, the current empty weight and centre of gravity, and the details of the next scheduled maintenance action. Journey logs need only be retained for one year after the last entry.

Journey Log

The journey log serves as the formal means
of communication between successive pilots,
and between pilots and maintenance personnel

The airframe, engine, propeller, and weight and balance records must be retained for the life of the aircraft (i.e. until it is removed from the civil register). The only exceptions are the records of repetitive inspections. They can be discarded whenever the inspection is repeated. Note that this exception only applies to the inspections themselves, and not to the rectification of any defects found during the inspections—that information must also be retained for the life of the aircraft.

All maintenance recorded in a journey log must be transcribed to the applicable airframe, engine or propeller record (and, where applicable, to the weight and balance report) within 30 days of the events concerned. Where practical (during a major check, for example), maintenance entries can be made directly in the permanent record, bypassing the journey log altogether. This option is only available provided the entire job is completed, and the entries made, before the next flight. Snags that can’t be fixed before the next flight must be entered in the journey log, so that the pilot has an on-board record of the aircraft’s condition. Temporary changes to the aircraft weight and balance (such as when non-essential equipment is removed for maintenance) should also be recorded in the journey log, and the necessary amendment should be made to the permanent weight and balance record within 30 days. If the aircraft is restored to its original empty weight and centre of gravity within 30 days, there is no need to amend the weight and balance report, although the details of the maintenance done (i.e. the equipment removed and replaced) will still have to be transcribed.

When a component with its own permanent record (an engine, for instance) is removed from one aircraft and installed on another, the record is also transferred, and becomes a part of the record for the new aircraft. The transfer is recorded in the engine record, so it should be possible to retrace every aircraft on which the engine has been installed. The transfer is entered in the airframe record as well, so it should also be possible to identify every engine (and other major component) that has ever been installed on that airframe.

Smaller parts have technical records as well, but they are not as obvious, because the entire record doesn’t travel with the parts. When a component is installed, its release tag is incorporated into the records of the higher assembly. When it is removed, the identity of that higher assembly is entered on a new tag, along with details of the part’s condition. After repair, the item may be installed on another higher assembly, and the process is repeated. Hence, the technical record for the part is distributed among the records of every aircraft on which it has ever been installed. Provided everyone did their job properly, the record can be reassembled by following the trail.

Badly maintained records can cost the operator thousands of dollars. At worst, they can expose the aircraft to serious risk. Record keeping isn’t fun, and most aircraft maintenance engineers (AME) don’t take kindly to it. Once a job is done, our natural instinct is to close up and move on to the next one. But technical records are just too important to give them anything less than our full attention. It’s not “just” paperwork.

 

This article was published by Transport Canada in TP 185E -. Reprinted with permission

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