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 Post subject: It's Not Just Paperwork
PostPosted: Mon Mar 09, 2009 4:30 pm 
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Don't know how many actually read the TC Aviation Safety Letters, but thought this was a great article in light of recent events/media related articles.

Quote:
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.

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.


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PostPosted: Mon Mar 09, 2009 7:21 pm 
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I read this article too and agree with many points of it. Paperwork is of course the only way of ensuring work has been done since many tasks (take a 500hr magneto inspection for example) cannot be visually confirmed. This is especially important for me when doing private annuals, where I don't have a data base like I do for my own planes (and being the nice AME that I am, I like to help the private guy understand the maintenance requirements for his aircraft, even though it is no longer my responsibility).

However TC is so obsessed with paperwork that they will ignore deficient aircraft provided that 'the paperwork is in order' when auditing or inspecting.

I don't know how many times both TC and QA (under the influence of potential TC wrath) has told me to change the paperwork because 'the wording wasn't right' or some other BS. Many times nothing was done to the aircraft and it continued to operate as before. It occurred to me then that paperwork isn't just a way of ensuring an aircraft is airworthy, but also a way of channeling accountability and blame.

For example, we as AMEs are required to put a phrase in the release that says 'The described maintenance has been performed in accordance with the applicable standards of airworthiness'. Many mechanics don't realize what this means when they sign out their work. It means that you are declaring that you used approved, traceable parts and performed the work to the latest standards available from the manufacturer or other approved source. I've seen many instances where it is simply not possible for this to be the case yet there is the statement in black and white.

That segways into to the whole issue of 'pencil whipping'. I've seen my fair share of this in aviation and confess to a bit of it myself. This is the whole 'looked a million times and never found anything wrong' type of attitude that justifies not opening that difficult to access area or not freezing your ass off any more than you have to on the ramp at -40. Here again, the paperwork doesn't match the condition of the aircraft and there isn't really a way of proving otherwise. Of course it can catch up to you, as what happened to Aloha 243, where the aircraft was not inspected to the degree the paperwork led the FAA to initially believe.

Paperwork is necessary for safety, but it isn't the Word of God. Sometimes there is a different story behind what is written in the log book.


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PostPosted: Mon Mar 09, 2009 7:32 pm 
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Wow, well said iflyforpie.

One of the things that surprised me, is that when a Canadian "Certificate of Airworthiness" is signed, it doesn't mean the aircraft has been inspected and is found to be in airworthy condition (except on import). In the US, it's different isn't it? Their C of A, or equivalent, does mean the aircraft has been inspected and is found to be in airworthy condition - or at least someone is putting their name to it.

Why the difference, and what do you see as being the pros and cons of each side?


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PostPosted: Mon Mar 09, 2009 8:56 pm 
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Quote:
Don't know how many actually read the TC Aviation Safety Letters


Have not read anything from them in over 4 years, usually goes straight to recycling, as I have no interest in anything work related on my own time. If they showed up at work, probably.

Bigest problem facing with paperwork is that it is usually being done in the middle of the night, or early in the morning after being up all night. Not really the best times to expect much from anyone, except that they are super tired, and want to go home. Basically, CYA and go home.

seen this almost everywhere i worked.



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PostPosted: Wed Mar 11, 2009 4:50 am 
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I agree with the statements and understand the importance of aircraft records, but perhaps Mr Whitehead would write an article and name it for instance:

"Its not ONLY paperwork" (that deems an aircraft airworthy.)

For distribution to his peers at T.C.

As many of us dirty faced guys on the hangar floor see each and every day.

PITA



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PostPosted: Wed Mar 11, 2009 6:16 am 
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Widow - The signature on the C of A does mean the aircraft has been inspected. This is based on the fact that the AME who submitted the application for the C of A has made a statement that the aircraft has been inspected and it conforms to the type certificate. The application is submitted whenever the C of A needs to be issued, maybe during import or re-issue after it was suspended.
The C of A will remain in force as long as the aircraft is maintained and operated in accordance with the required regulations. From a maintenance standpoint this means it needs to be maintained in accordance with an approved maintenance schedule or something similiar depending on the catagory of the aircraft.
By default, the aircraft has to be inspected for the C of A to remain valid.



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