Journey Log Defect reporting?

[helicopterray]

I used to make entries stating 'Pilot reported defect..." and rectify it. The company changed it's procedures to state that if the defect was noted in flight, the pilot must make the log book entry.
If the pilot did not in the above example, it was not rectified. A second pilot, or the chief pilot, would make a flight to confirm the defect, and enter it in the log book.

[DonutHole]

We all need to be responsible as well when it comes to quoting regulations. 605 Schedule 1 actually says "Person Responsible for Entry" not "By Who" when describing how the entry gets into the logbook. Certainly directing someone else to make the entry via dictation would satisfy that requirement.

As 5x5 said, the regulations do not say who has to put pen to paper. The way it's written in the CARs, a pilot can legally call in and say "please write this in the book for me...". No need to have a finding as there isn't anything to find.

http://laws-lois.justice.gc.ca/eng/regu ... l#s-605.97

"person responsible for the entry" not by who.

"By who" is specified in the mcm as "the pilot"

If the MCM is written to say the pilot must enter the defect in the log, then the pilot must write the defect in the log. Your mcm is not contradicting the cars in this instance, the car tells you which information must be put in the logbook, the MCM specifies who does it. That is the entire point of maintenance control. The MCM is the system that sets up how these procedures ensure your company is meeting the regulations.

Don't forget, if you do not follow your MCM you WILL be in contravention of the regulations. These are the small procedural errors transport will eat you alive for.

the finding is not that a CAR has been contravened, but that the MCM procedures have not been met.

Even if you feel the MCM does contradict the CAR It doesn't matter in this case because the approved MCM is *MORE* restrictive than the CAR. An example I run into is Service Bulletins, not all are mandatory, but if your mcm says you follow all service bulletins, even though the CARs dont specify them all as mandatory, you've written yourself into complying with all service bulletins.

If you had a pvi, and you've not done a service bulletin because it wasnt marked mandatory by the manufacturer and your case is "the cars dont require it" transport is going to come right back at you with an angry "but your mcm says you do" you have no defense.

If your mcm is set up in such a way that youve imposed tighter limits on your business than the cars do, that is why audit procedures and findings were put in place, so a company can identify these overly onerous parts of their procedures and make a case to have the mcm relaxed to reflect the cars, but until that procedure is modified and signed off on by transport you are obliged to follow it.

[DonutHole]

this entire discussion should have been refaced with talk of the MCM.

Somebody with great wisdom, presumably, created your MCM in such a way that if it is followed you will be in compliance with all of the regulations.

The functional point of this is that, if followed, the people using these procedures do not have to constantly refer back to the CARS to ensure regulatory compliance.

It is important to follow these procedures, essentially through the dir these procedures become your 'operational checklists'

For sure, your aircraft can be maintained to an airworthy status without following your MCM. The problem is, if you show that you are not following your MCM transport will dig for errors that have occurred, and if they find that this was a result of your MCM not being followed then you have a 'can of worms' situation, unless you have made a finding and corrective action plan to address the issue. If you have not done that then you will find yourself at the business end of a federal non-conformance finding, which can be a huge deal.

Legally, the information of the defect in the logbook with it's proper rectification is all that is important. This will keep you safe from lawsuits. Operationally, how the information ended up in the logbook is all that is important, to the regulator.

If you want to know the answer to your question, ask either your PRM, DOM, or QAM, or go directly to the source and read your MCM to see what you need to do to be in compliance with it.

[goingnowherefast]

I'm well aware of that, however we were discussing regulatory requirements, not specific details in your company's MCM. I don't imagine that document is publicly available.

[DonutHole]

The regulatory requirements are a red herring, they have to be met. How the AMO meets those requirements is set up in the MCM.

You could be compliant iaw the requisite cars, but you can be non-compliant under your mcm.

Simply reading the car and coming to the conclusion that anybody can put the defect in the book can be an erroneous conclusion.

There is a CAR that says you have to have an mcm and operate in accordance with it. Defect reporting and recording is the bread and butter of the MCM, the controlled reporting and recording of defects is a big part of the text within the MCM, it establishes the base for the control the manual is intended to implement... you have to do what the MCM says, and if you want to change it, or operate outside of it,there is a process.

By complying with the car in a method that is not put forth in your MCM you are in violation, period end of sentence. You have to operate under the procedures outlined in your MCM, and if it contradicts the CARs the solution isnt to disregard the problem and have somebody put the defect in the log, it is to generate a finding outlining the contradiction and propose an amendment to the text in the MCM.

THe mcms I am familiar with for the most part state that in flight defects are to be entered by the pilot in command immediately, or as soon as practicable but definitely before the next flight. I feel as if this is the standard nomenclature for the procedure.

Your MCM will tell you what to do.

Im not disregarding the CAR and discussion over the semantics is important, but it is equally as important to be operating within the parameters set forth by your MCM. If you want to diverge, or have to diverge, you definitely need to make a finding.

Im not pulling this out of my rear either. Transport Canada is looking specifically for your compliance with your own procedures, that is why quality assurance has become an essential part of the AMO and it is super important to use your quality assurance program to record and monitor these types of happenings, its nothing to be afraid of, it's how the system is supposed to work.

[Heliian]

Private aircraft have defects too ya know.

[DonutHole]

of course private aircraft have snags, and they're to be recorded iaw the cars.

But there are a few private pilots (or at least private owners) on this thread that don't understand that under an AMO (I am assuming widgeonguy is working for a commercial air service) the way we comply with rules is different, so their advice has to be identified as erroneous.

[Avddicted]

We Use propeller/one online based software which takes the thinking out of it! the pilot reports defect on a tablet or cell phone and it records it with a flag for Maintenance control and the next pilot to fly the plane. Internal or external AMO's can see it from anywhere.
It is Car's compliant and has been reviewed by TC and built with Dave Duecks consultation.
https://propeller.one/ Worth looking into, as it was designed for this need.

[torquey401]

What about defects discovered during pre-flight?