Tech Log Paranoia
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Tech Log Paranoia
Since crossing over from Airline to the private Biz Jet world I have become even more acutely aware of the commercial pressure to only snag an aircraft by making the dreaded entry in the tech log if no other options are available.
It is self evident that, without the well established support infrastructure of a major, the consequences of a grounding in SomethingStan is horrendous both in terms of cost and consequences to the client.
The result is that things generally only get written up when miraculously they all occur during a short sector to our engineering facility.
The result of this culture is of course that often a significant number of defects are carried on an airframe that, whilst not critical, are nevertheless something that any crew taking over certainly ought to know about.
So My question is ...how does one disseminate this information without upsetting our engineers whose edict is "Dont put it in writing anywhere because, on any audit, that would be deemed the same as snagging the aircraft by a tech log defect entry"
In my previous life we did for a while put a tech log entry "for information purposes only" but this was frowned on and abolished for the above reason.
So the result is that quite often I take over an aircraft and have to rediscover afresh some quirk or idiosyncracy which a colleague who previously flew it knew all about and came up with a solution as to how to deal with it....
The issue is fresh in my mind because I recently could not refuel my aircraft because the refuelling panel would not work with the APU running......only on battery power! It took me 15 minutes of panic as the clients were arriving to troubleshoot the problem afresh.
How simple would it have been for there to be a pilot information log or handover sheet waiting for me in the cockpit alerting me to this problem and the solution (just as our girls do in the cabin hand over notes)
BUT the very fact of such a written memo would apparently have the same effect as a tech log entry that could only be then cleared by an engineer....so we are not allowed to do it.
Is this unnecessary paranoia or a valid concern?
What does any one else do?
It is self evident that, without the well established support infrastructure of a major, the consequences of a grounding in SomethingStan is horrendous both in terms of cost and consequences to the client.
The result is that things generally only get written up when miraculously they all occur during a short sector to our engineering facility.
The result of this culture is of course that often a significant number of defects are carried on an airframe that, whilst not critical, are nevertheless something that any crew taking over certainly ought to know about.
So My question is ...how does one disseminate this information without upsetting our engineers whose edict is "Dont put it in writing anywhere because, on any audit, that would be deemed the same as snagging the aircraft by a tech log defect entry"
In my previous life we did for a while put a tech log entry "for information purposes only" but this was frowned on and abolished for the above reason.
So the result is that quite often I take over an aircraft and have to rediscover afresh some quirk or idiosyncracy which a colleague who previously flew it knew all about and came up with a solution as to how to deal with it....
The issue is fresh in my mind because I recently could not refuel my aircraft because the refuelling panel would not work with the APU running......only on battery power! It took me 15 minutes of panic as the clients were arriving to troubleshoot the problem afresh.
How simple would it have been for there to be a pilot information log or handover sheet waiting for me in the cockpit alerting me to this problem and the solution (just as our girls do in the cabin hand over notes)
BUT the very fact of such a written memo would apparently have the same effect as a tech log entry that could only be then cleared by an engineer....so we are not allowed to do it.
Is this unnecessary paranoia or a valid concern?
What does any one else do?
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Yes see your point. A good maintenance contractor is a big plus. You need to be able to speak to someone licenced on your type directly and quickly.
However a good operations inspector will pickup on the fact there is a load of defects on the flight to base or maintenance.. He/she wont be happy and they will be right not to be. A defect needs to be written up, as the paper trail must start at the tech log. IMHO.
However a good operations inspector will pickup on the fact there is a load of defects on the flight to base or maintenance.. He/she wont be happy and they will be right not to be. A defect needs to be written up, as the paper trail must start at the tech log. IMHO.
There was a good thread recently here: http://www.pprune.org/biz-jets-ag-fl...nical-log.html
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These two threads could easily be merged into "when is a defect not a defect"?
An aircraft cannot legally fly with an open defect in the tech log. It has either got to be cleared by a suitable engineer fixing it and signing it off or defered as per the MEL. As I have mentioned before it is impossible for MEL's to cater for every conceivable little niggle that an aircraft developes. Your instance of pressure refueling not working with the APU on. I'll bet that was not mentioned in the MEL. Probably best to write it up as totally U/S, defer it and in the defered defect sheet make a note that it does in fact work on batery power.
One thing your company must do is give Captains the legal right to transfer defects from the sector record page to the defered defect sheet. Under EASA regulations this is legal but some companies are not keen to issue this approval to Captains. Some countries (Switzerland I think) do not give this right to crew at all. It is very necessary and with CAA approval even non MEL items can be deferred if the SMS issue has been addressed. I am not advocating that every loose knob must be writen up but with crews knowing the system and having the correct authority it does help.
Best solution is probably to buy an old Hawker and if anything goes wrong wack it with a 5 lb hammer. (I carry a 10 pounder as well just in case something serious goes wrong)
.
An aircraft cannot legally fly with an open defect in the tech log. It has either got to be cleared by a suitable engineer fixing it and signing it off or defered as per the MEL. As I have mentioned before it is impossible for MEL's to cater for every conceivable little niggle that an aircraft developes. Your instance of pressure refueling not working with the APU on. I'll bet that was not mentioned in the MEL. Probably best to write it up as totally U/S, defer it and in the defered defect sheet make a note that it does in fact work on batery power.
One thing your company must do is give Captains the legal right to transfer defects from the sector record page to the defered defect sheet. Under EASA regulations this is legal but some companies are not keen to issue this approval to Captains. Some countries (Switzerland I think) do not give this right to crew at all. It is very necessary and with CAA approval even non MEL items can be deferred if the SMS issue has been addressed. I am not advocating that every loose knob must be writen up but with crews knowing the system and having the correct authority it does help.
Best solution is probably to buy an old Hawker and if anything goes wrong wack it with a 5 lb hammer. (I carry a 10 pounder as well just in case something serious goes wrong)
.
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Deferred Defect / MEL
Before posing my question / admitting my ignorance, I should confess that this is a pilott (aka 'seat-stick sloppy link') asking:
My belief is that the Deferred Defects list is an operations controlled document, rather than engineering, and that a primary use is to allow the continued operation of an aircraft, in accordance with the MEL, in the absence of the ability of engineering to clear a defect - for whatever reason.
I also understand that it is important for a oompany to approve their flight crew to be able to raise a defect, and then transfer it to the DDL (again iaw MEL).
Question is, am I correct in this belief? The information I am hearing is that, under EASA regs., any tech log entry beyond a pre-flight inspection requires a CRS, and a suitably qualified engineer to sign off - or defer ... so flight crew cannot defer a defect in any case?
It seems that this would tend to lead to the situation mentioned elsewhere, where defects are carried and not written up, since the aircraft will otherwise be grounded until an engineer can get to it!
Thanks for any advice...
My belief is that the Deferred Defects list is an operations controlled document, rather than engineering, and that a primary use is to allow the continued operation of an aircraft, in accordance with the MEL, in the absence of the ability of engineering to clear a defect - for whatever reason.
I also understand that it is important for a oompany to approve their flight crew to be able to raise a defect, and then transfer it to the DDL (again iaw MEL).
Question is, am I correct in this belief? The information I am hearing is that, under EASA regs., any tech log entry beyond a pre-flight inspection requires a CRS, and a suitably qualified engineer to sign off - or defer ... so flight crew cannot defer a defect in any case?
It seems that this would tend to lead to the situation mentioned elsewhere, where defects are carried and not written up, since the aircraft will otherwise be grounded until an engineer can get to it!
Thanks for any advice...
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For info only !
EASA rules prohibit tech log entry's under the heading FAO because under EASA each tech log entry has to have an appropriate defect removal reply.
Who makes the reply is down to how well your EASA 145 maintenance exposition is written most airlines have a part of the exposition that permits the captain to move a tech log defect from the defects page to the Deferred defect pages provided it is within the aircraft MEL.
It is for your company to negotiate with your maintenance provider to get the approval for the crew to do this, while you are about it you might like the maintenance company to give the crew some "simple & limited task" maintenance approval to carry out and certify minor items of maintenance such as changing lamps, topping up fluids and the like. ( there will be an element of crew training involved)
A lot of maintenance company's are stuck in a bit of a rut and don't like issuing such approvals, this is usualy because they don't know the rules very well themselves and/or the national authorities know even less about the rules and the easiest option of those with little knowlage who you are taking outside their comfort zone is to say it is not allowed.
In my view the EASA prohibition of FIO tech log entry's is a step backward in flight safety as it allowed feed back on things that are not necessarily defects but are of interest of a new crew.
Who makes the reply is down to how well your EASA 145 maintenance exposition is written most airlines have a part of the exposition that permits the captain to move a tech log defect from the defects page to the Deferred defect pages provided it is within the aircraft MEL.
It is for your company to negotiate with your maintenance provider to get the approval for the crew to do this, while you are about it you might like the maintenance company to give the crew some "simple & limited task" maintenance approval to carry out and certify minor items of maintenance such as changing lamps, topping up fluids and the like. ( there will be an element of crew training involved)
A lot of maintenance company's are stuck in a bit of a rut and don't like issuing such approvals, this is usualy because they don't know the rules very well themselves and/or the national authorities know even less about the rules and the easiest option of those with little knowlage who you are taking outside their comfort zone is to say it is not allowed.
In my view the EASA prohibition of FIO tech log entry's is a step backward in flight safety as it allowed feed back on things that are not necessarily defects but are of interest of a new crew.
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Re: MEL and Outside the Comfort Zone
Many thanks 'A and C' for your reply. That makes complete sense to me, and seems to be exactly the stonewall we are experiencing. The worry is that it leads to unseviceabilities being carried until the last sector before arrival at home base and / or a surprising number of problems being 'discovered' by the engineer carrying the next maintenance intervention.
Next job - assemble the incontrovertable case to get the Maintenance Exposition changed, and then persuade the 145 provider(s) to authorise as you explain. Actually, probably need to get everyone onside and in agreement first..
Do you know anywhere I could find appropriate wordage to be included in the Maintenance Exposition?
Next job - assemble the incontrovertable case to get the Maintenance Exposition changed, and then persuade the 145 provider(s) to authorise as you explain. Actually, probably need to get everyone onside and in agreement first..
Do you know anywhere I could find appropriate wordage to be included in the Maintenance Exposition?
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The wording of a maintenance exposition is usualy negotiated between the regulatory authority and the maintenance company.
It is usualy the quality manager who gets involved with this sort of thing, what you can get written into the exposition is entirely down to how well your quality manager knows the regulations.
For instance most EASA 145 companies can only do work within their own hangars or pre defined areas, due to he type of work we do we have approval to use any place that the quality manager or chief engineer deem suitable. This unusualy wide approval had to be justified to the regulating authority and we only got this because our quality manager knows the rules better than the authority !
My advice to you is to read the EASA 145 rules until you know what you want to do ( tediousness defined !) and then use this Knowlage to push your maintenance provider in the right direction, unfortunately I can't help you further than that as I don't know exactly what you are looking for in terms of pilot simple and limited maintenance tasks or just how much scope you wish to give the captain to move defects from the defects to the Defered defect section of the tech log.
I also suspect that your maintenance provider may be using the manipulation of restrictive rules to their financal advantage.
It is usualy the quality manager who gets involved with this sort of thing, what you can get written into the exposition is entirely down to how well your quality manager knows the regulations.
For instance most EASA 145 companies can only do work within their own hangars or pre defined areas, due to he type of work we do we have approval to use any place that the quality manager or chief engineer deem suitable. This unusualy wide approval had to be justified to the regulating authority and we only got this because our quality manager knows the rules better than the authority !
My advice to you is to read the EASA 145 rules until you know what you want to do ( tediousness defined !) and then use this Knowlage to push your maintenance provider in the right direction, unfortunately I can't help you further than that as I don't know exactly what you are looking for in terms of pilot simple and limited maintenance tasks or just how much scope you wish to give the captain to move defects from the defects to the Defered defect section of the tech log.
I also suspect that your maintenance provider may be using the manipulation of restrictive rules to their financal advantage.
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A lot of pressure could be relieved if ANY certified mx facility could do the work. The paperwork involved to get things going if one wants another mx company to refill the O2 or the like is ridiculous ... at least in Germany.
EASA is in the business of making perfectly simple matters highly complicated and then sticks the head in the sand when operators do "their own regs".
Another point is what is put in the MMEL. In our type we have switches with an "On" and a "Off" indication. They are either flush (when pushed "On") or elevated from the panel if "Off". The manufacturer put that in as a 12 days item - does not make sense and is NOT dangerous in any way, shape or from to fly with one indication u/s... These are going awol on our airplane regularly.
A pain in the butt.
EASA is in the business of making perfectly simple matters highly complicated and then sticks the head in the sand when operators do "their own regs".
Another point is what is put in the MMEL. In our type we have switches with an "On" and a "Off" indication. They are either flush (when pushed "On") or elevated from the panel if "Off". The manufacturer put that in as a 12 days item - does not make sense and is NOT dangerous in any way, shape or from to fly with one indication u/s... These are going awol on our airplane regularly.
A pain in the butt.
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The essence of the question is acute and true. Whatever the snag, in the biz world, unless a real no-go item it is very likely to be written up only enroute to a maintenance capable airport.
The ( used to be) very BIG FRACTIONal operating in europe, even had a "handover form" where the unwritten defects were written, in order to be passed on the next crew without any fuss. Since then, i believe that they have more concerns on busting the 60 hours limit on day 6 coming back to base than to snag an emergency light on the entrance door..
But indeed, wanting charter of small airplanes ( FAR 135 like) to operate like a schedule airline ( FAR 121 like) is a true non-sense, leading only to undercover/untold procedures and behaviors , being discovered mostly when it is too late.
The ( used to be) very BIG FRACTIONal operating in europe, even had a "handover form" where the unwritten defects were written, in order to be passed on the next crew without any fuss. Since then, i believe that they have more concerns on busting the 60 hours limit on day 6 coming back to base than to snag an emergency light on the entrance door..
But indeed, wanting charter of small airplanes ( FAR 135 like) to operate like a schedule airline ( FAR 121 like) is a true non-sense, leading only to undercover/untold procedures and behaviors , being discovered mostly when it is too late.
Last edited by CL300; 3rd Jan 2015 at 15:39. Reason: spelling
Defects
This issue is as old a the aircraft themselves.
One good way around the problem is to establish a culture where your maintenance organisation are prepared to state whether the defect seriously hazards the safety of the flight. If it does not then it can be transferred to the Defered Defects log without being covered by the MEL. See below but check the latest version of Part M as the copy I have to hand is old.
M.A.403 Aircraft defects
(a) Any aircraft defect that hazards seriously the flight safety shall be rectified before further flight.
(b) Only the authorised certifying staff, according to M.A.801(b)1, M.A.801(b)2 or Part-145 can decide, using M.A.401
maintenance data, whether an aircraft defect hazards seriously the flight safety and therefore decide when and which
rectification action shall be taken before further flight and which defect rectification can be deferred. However, this
does not apply when:
1. the approved minimum equipment list as mandated by the competent authority is used by the pilot; or,
2. aircraft defects are defined as being acceptable by the competent authority.
(c) Any aircraft defect that would not hazard seriously the flight safety shall be rectified as soon as practicable, after the
date the aircraft defect was first identified and within any limits specified in the maintenance data.
(d) Any defect not rectified before flight shall be recorded in the M.A.305 aircraft maintenance record system or
M.A.306 operator's technical log system as applicable.
Also the MEL does not have to follow the manufacturer's MMEL, although most authorities like it to. The Operator's MEL is the Operator's MEL and you can write whatever you want in it provided you can get it approved by your authority. You can quite reasonably add a section which covers minor defects not covered in the MMEL. Note the introduction to all MMELs.
Whatever you do just stay pragmatic but safe.
MM
One good way around the problem is to establish a culture where your maintenance organisation are prepared to state whether the defect seriously hazards the safety of the flight. If it does not then it can be transferred to the Defered Defects log without being covered by the MEL. See below but check the latest version of Part M as the copy I have to hand is old.
M.A.403 Aircraft defects
(a) Any aircraft defect that hazards seriously the flight safety shall be rectified before further flight.
(b) Only the authorised certifying staff, according to M.A.801(b)1, M.A.801(b)2 or Part-145 can decide, using M.A.401
maintenance data, whether an aircraft defect hazards seriously the flight safety and therefore decide when and which
rectification action shall be taken before further flight and which defect rectification can be deferred. However, this
does not apply when:
1. the approved minimum equipment list as mandated by the competent authority is used by the pilot; or,
2. aircraft defects are defined as being acceptable by the competent authority.
(c) Any aircraft defect that would not hazard seriously the flight safety shall be rectified as soon as practicable, after the
date the aircraft defect was first identified and within any limits specified in the maintenance data.
(d) Any defect not rectified before flight shall be recorded in the M.A.305 aircraft maintenance record system or
M.A.306 operator's technical log system as applicable.
Also the MEL does not have to follow the manufacturer's MMEL, although most authorities like it to. The Operator's MEL is the Operator's MEL and you can write whatever you want in it provided you can get it approved by your authority. You can quite reasonably add a section which covers minor defects not covered in the MMEL. Note the introduction to all MMELs.
Whatever you do just stay pragmatic but safe.
MM
