Paperless Digital Maintenance Tracking program

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photofly
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Re: Paperless Digital Maintenance Tracking program

Post by photofly »

There is some published guidance on relevant subjects: AC 571-006 from TC, which also refers to AC120-78A from the FAA.

This is what it says about electronic signatures:
5.2 Description of an Electronic Signature
An electronic signature should have the same qualities and attributes that guarantee a handwritten signature’s authenticity and should be traceable to the person signing. The electronic signature should be:

Uniquely linked to the signatory;
Capable of identifying the signatory;
Created using means solely controlled by the signatory;
Appended to the data being signed in a way to enable the verification of the data’s source and integrity.

An electronic signature may be in the following forms:
Digital image of a paper signature;
Typed notation;
Electronic code;
Equivalent security designator for individual identification that can be used as a means of authenticating the individual signing the electronic document.
Pretty sure writing your name in a spreadsheet doesn't meet these requirements.

Are you aware of any operators using a Google spreadsheet with the approval of Transport Canada, or are you just arguing that it would be fine if they did?
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AirFrame
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Re: Paperless Digital Maintenance Tracking program

Post by AirFrame »

5.2 Description of an Electronic Signature
An electronic signature should have the same qualities and attributes that guarantee a handwritten signature’s authenticity and should be traceable to the person signing. The electronic signature should be:

Uniquely linked to the signatory;
Capable of identifying the signatory;
Created using means solely controlled by the signatory;
Appended to the data being signed in a way to enable the verification of the data’s source and integrity.
A penned signature meets none of these requirements in any secure way.
An electronic signature may be in the following forms:
Digital image of a paper signature;
Well that's just patently ridiculous. Remind me to take a cell-phone image of my next maintenance release and crop out the signature for future use.
Are you aware of any operators using a Google spreadsheet with the approval of Transport Canada, or are you just arguing that it would be fine if they did?
What do you think? I'm an armchair expert spitballing on the internet, just like you. There's no electronic signature confirming the authenticity of either of our points of view on this.
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photofly
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Re: Paperless Digital Maintenance Tracking program

Post by photofly »

There's no electronic signature confirming the authenticity of either of our points of view on this.
Lol.

What I think, is that if you said to your PMI that you were moving your maintenance records to Google Docs, he or she would laugh in your face, and if you persisted, would issue a letter saying your aircraft was grounded!
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Re: Paperless Digital Maintenance Tracking program

Post by AirFrame »

Maybe it would depend more on how old your PMI is.
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Re: Paperless Digital Maintenance Tracking program

Post by Scuderia »

Electronic signatures have been around for decades, and legislation developed in parallel.

Unified application is not in place but it is trending that way. TC is (unsurprisingly) far behind.

I suspect that when rules for electronic maintenance records are made, a secure electronic signature will be required.

https://www.canada.ca/en/government/sys ... tures.html
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Re: Paperless Digital Maintenance Tracking program

Post by photofly »

AirFrame wrote: Fri Jan 08, 2021 2:12 pm Maybe it would depend more on how old your PMI is.
I don't think it's a decision made by individual inspectors; I think there's policy in Ottawa, and it's a fairly conservative policy.
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Re: Paperless Digital Maintenance Tracking program

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One other over-riding consideration here, perhaps... I wasn't thinking about Commercial operations here. I was thinking about private owners. I've got an amateur-built myself, that allows much more flexibility, but I still think a private operator could easily maintain a digital maintenance log without resorting to a massive software cost for one of the commercial packages.
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Re: Paperless Digital Maintenance Tracking program

Post by plhought »

Someone mentioned AC earlier.

When I was still there - we were moving to a paperless system for maintenance releases - although it was limited.

From what I hear now scheduled maintenance tasks and packages (A & B checks) are now being assigned and signed for on issued iPads.

Defects found during flight are still thrown in a physical defect log along with reams of carbon paper. They are entered manually in the system after rectification.

Journey Log is still physical.

How it worked for a true paperless release was you would create the snag (Maintenance snags - not ones found by flight crew) and rectify it in the iPad. It prompts you for your unique PIN - which constitutes as your digital signature and the 571.10 release.

If you ever see the technical records operation in YUL it was an eye opener. Literally bags of paper and records being dumped on tables and sorted. Hundreds of bankers boxes going out to a secure site every week.

We are a long ways away from true paperless aircraft records.
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Re: Paperless Digital Maintenance Tracking program

Post by Heliian »

AirFrame wrote: Fri Jan 08, 2021 10:09 pm One other over-riding consideration here, perhaps... I wasn't thinking about Commercial operations here. I was thinking about private owners. I've got an amateur-built myself, that allows much more flexibility, but I still think a private operator could easily maintain a digital maintenance log without resorting to a massive software cost for one of the commercial packages.
Why tho? If you're a private operator then you don't have a need to digitize your logs, you'd save very little paper and would spend more in basic digital backup services then an old paper log.
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photofly
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Re: Paperless Digital Maintenance Tracking program

Post by photofly »

Private operators are subject to the same record-keeping rules as commercial ones. They have less oversight, but if it won’t pass for a commercial operator, it won’t pass for a private one.
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Re: Paperless Digital Maintenance Tracking program

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Heliian wrote: Mon Jan 11, 2021 6:12 amWhy tho? If you're a private operator then you don't have a need to digitize your logs, you'd save very little paper and would spend more in basic digital backup services then an old paper log.
For the same reasons a commercial operator might want to digitize. Having a backup. Not having to carry a paper copy with you. Have you ever seen a paper log for a 30 year old airplane that flies 50 hours a year? A lot of them look like a paperback novel that's been dropped in a bathtub and dried in the sun. I keep a paper copy, but I also keep a digital copy. The digital copy flies "with" me. The paper one lives in my heated home office.

Spending for basic backup services? Nonsense. OneDrive, Google Drive, Dropbox, Github, etc. all provide free online syncable storage.
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Re: Paperless Digital Maintenance Tracking program

Post by photofly »

You don't have to (and arguably shouldn't) carry maintenance logs with you at all, ever. You do have to carry the Journey Log (one volume) though. Scans of paper records are great online backups.

Which brings up an interesting issue: when you want to sell your plane, and you explain that the maintenance records are all online on some system with which the purchaser isn't interested to continue, or doesn't trust, what then?
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Re: Paperless Digital Maintenance Tracking program

Post by Heliian »

AirFrame wrote: Mon Jan 11, 2021 7:37 am For the same reasons a commercial operator might want to digitize. Having a backup. Not having to carry a paper copy with you. Have you ever seen a paper log for a 30 year old airplane that flies 50 hours a year? A lot of them look like a paperback novel that's been dropped in a bathtub and dried in the sun. I keep a paper copy, but I also keep a digital copy. The digital copy flies "with" me. The paper one lives in my heated home office.

Spending for basic backup services? Nonsense. OneDrive, Google Drive, Dropbox, Github, etc. all provide free online syncable storage.
A journey log doesn't need to be a 30 year old book. You can buy or make a new one and throw the old ones in storage. Not a huge cost but involves storing a box.

I have yet to see a system with free cloud storage be approved. We are using dedicated servers and offline backups are produced on a schedule.
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Re: Paperless Digital Maintenance Tracking program

Post by AirFrame »

photofly wrote: Mon Jan 11, 2021 8:04 amYou don't have to (and arguably shouldn't) carry maintenance logs with you at all, ever. You do have to carry the Journey Log (one volume) though. Scans of paper records are great online backups.
I use a combined Journey/Maintenance log, so if one comes along, they both do.
Which brings up an interesting issue: when you want to sell your plane, and you explain that the maintenance records are all online on some system with which the purchaser isn't interested to continue, or doesn't trust, what then?
Well, the easy answer is to print a hardcopy, start a paper log from then on, and abandon or delete the electronic copy. As for trusting it, there's no reason to assume a paper log will be any less falsified than an electronic one. It'll come down to, do you trust the person you're buying from?
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Re: Paperless Digital Maintenance Tracking program

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AirFrame wrote: Tue Jan 12, 2021 7:40 am
photofly wrote: Mon Jan 11, 2021 8:04 amYou don't have to (and arguably shouldn't) carry maintenance logs with you at all, ever. You do have to carry the Journey Log (one volume) though. Scans of paper records are great online backups.
I use a combined Journey/Maintenance log, so if one comes along, they both do.
That's not a lawful way of keeping technical records for an aircraft with a standard certificate of airworthiness. This thread isn't really about OM, experimental or amateur-built aircraft.
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Re: Paperless Digital Maintenance Tracking program

Post by Bede »

Here's one that I used for an airplane I used to own.
https://docs.google.com/spreadsheets/d/ ... sp=sharing

I used conditional formatting to warn me once maintenance was coming due (yellow) and red if overdue. All you had to do was update the TTSN every day and when maintenance was completed.

I used the same spreadsheet (with added tasks) as a maintenance tracker when I was PRM at an FTU years ago when Google Drive was somewhat new. TC approved. We gave them the link and they could track us without leaving the comfort of their desks. No surprise inspections for us.
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Re: Paperless Digital Maintenance Tracking program

Post by AirFrame »

photofly wrote: Tue Jan 12, 2021 8:13 amThat's not a lawful way of keeping technical records for an aircraft with a standard certificate of airworthiness. This thread isn't really about OM, experimental or amateur-built aircraft.
No? I pointed out a while back that I was in the Amateur-Built camp. I didn't think it mattered, doesn't the digital log section of the CARs apply to Amateur-Built as well? The fact that we can combine our Journey and Maintenance logs is a secondary issue.
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Re: Paperless Digital Maintenance Tracking program

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AirFrame wrote: Wed Jan 13, 2021 7:49 am
photofly wrote: Tue Jan 12, 2021 8:13 amThat's not a lawful way of keeping technical records for an aircraft with a standard certificate of airworthiness. This thread isn't really about OM, experimental or amateur-built aircraft.
No? I pointed out a while back that I was in the Amateur-Built camp. I didn't think it mattered, doesn't the digital log section of the CARs apply to Amateur-Built as well? The fact that we can combine our Journey and Maintenance logs is a secondary issue.
Amateur-built aircraft only need a Journey Log. Aircraft with a normal CofA need a Journey log and "separate technical record for the airframe, each installed engine and each variable-pitch propeller;" It's not that your maintenance logs are combined; you are simply excused from three quarters of the records that owners of a certified aircraft have to keep.

The practical difference, and the position from which I was (and am) asking, is for commercial operators, I specifically wanted to hear from a commercial operator who (quite clearly, with the approval of TC) was keeping an electronic JL. The OP, likewise. I respect your opinions on the subject but they're not backed by the experiences of someone whose records are inspected by TC on a regular basis.
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