Maintenance and Certification

Maintenance and Certificaiton

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, thedays 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.

For the purposes of CAR605, 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 CAR605.

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 30days 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 30days. If the aircraft is restored to its original empty weight and centre of gravity within 30days, 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.

Fatigue Risk Management System for the Canadian Aviation Industry: An Introduction to Managing Fatigue(TP14572E)

This is the first of a seven-part series to highlight the work done by the Fatigue Risk Management System(FRMS)Working Group, and also to highlight the various elements of the FRMS Toolbox. This first part refers to TP14572E. We encourage our readers to consult the complete documentation by visiting www.tc.gc.ca/eng/civilaviation/standards/sms-frms-menu-634.htm. -Ed.

Being tired at work can be just as dangerous as taking alcohol or drugs. You can lose concentration, misjudge speed and distance, react more slowly-you might even fall asleep. Being tired can also make you moody and irritable, and can cause you to take risks. Any one of these problems could put you and other people in danger.

When you work shifts, you're bound to feel tired sometimes. You're out of step with your body's natural sleeping and waking rhythms. TP14572E gives you an overview of the risks associated with fatigue, and offers some strategies to help you manage the effects of fatigue at work and make sure you get the rest you need to be fit for duty.

Fatigue is widely recognized as a significant safety hazard, not just to you and your co-workers, but to the general public. That's why Transport Canada commissioned a set of tools and guidelines to help the Canadian aviation industry set up FRMSs.

FRMSs recognize that it's everyone's responsibility to manage fatigue risk. Employers should make sure that work schedules give employees adequate opportunities for rest between shifts. In turn, employees are responsible for making sure they use those opportunities to get the sleep they need to be fit for work.

An important part of any FRMS involves teaching employees and managers about fatigue as a safety hazard and how to better manage their own fatigue.

Causes and consequences of fatigue
What causes fatigue?
How much sleep we need varies from person to person, but most people need an average of seven to nine hours of sleep a night. If you get less than you need over severaldays, that lack of sleep will build up into a sleep "debt." Losing two hours of sleep a night for fourdays can make you as tired as though you lost a whole night's sleep. The only way to pay back your sleep debt is by getting some additional "recovery" sleep.

The human body runs on a 24-hr clock, programmed to sleep at night and be awake during the day. Working when your body is supposed to be sleeping can make it hard to get good quality sleep. Not only do you not sleep as well, some research suggests that night-shift workers can lose one to three hours of sleep per day compared to day-shift workers. Six hours of sleep during the day is not the same as six hours of night sleep.

Your body clock also controls your body's daily cycles, such as hormone production, digestion, temperature, and sleepiness. There are two times during the day when you're more likely to feel drowsy:in the early morning between midnight and 6 a.m., and in the mid-afternoon.

Your sleep, too, runs in cycles. Over the course of the night, you move several times from a light sleep to a deep dreaming sleep and back to a light sleep. How long each cycle runs varies from person to person, but it's usually somewhere from 60 to 90 min. It's the deepest sleep that you need to recover best from fatigue.

It is not true that we need less sleep as we get older-we simply have more trouble getting what we need.

Beyond not getting enough sleep, feelings of fatigue can also be brought on or made worse by conditions in your workplace. High-pressure demands, long shifts, stress, and even things like poor lighting, constant noise, and poor weather can make you feel more tired. Not taking breaks during your shift will also increase your feelings of fatigue.

Balancing the demands of shift work with your family and social life can also be stressful and make it hard to get the sleep you need to be fit for duty.

Consequences of fatigue
Being fatigued can have an effect on many aspects of your life. Many people suffer from mood swings, which can hurt your relationships at work and at home. Some people gain weight. Others find it harder to get motivated at work or at home. You can become frustrated trying to balance the need for more sleep with the need to spend time with friends and family.

Many people who work shifts feel socially isolated, which only adds to the stress and overall feeling of fatigue. In the long term, shiftwork can lead to more serious health problems, such as heart disease or gastrointestinal problems such as ulcers.

On the job, fatigue can be a serious safety hazard. Research has found that losing just one night of sleep can impair your performance almost as much as having too much alcohol to legally drive. Your reaction time is slower, you have trouble concentrating or remembering things-you may even fall asleep on the job. There's a much greater risk that you'll make a safety-critical mistake. Being fatigued can make you a risk to yourself, your co-workers, and even the public. It's not just at work that being fatigued can be dangerous. There's a real risk that you'll fall asleep at the wheel while driving home after a long shift.

Consequences of fatigue
Individuals
  • Increased sleepiness
  • Increased risk of accident
  • Increased stomach upsets
  • Decreased motivation
  • Mood swings or depression
Organizations
  • Increased safety risk
  • Increased sick leave
  • Increased staff turnover
  • Decreased productivity
  • Decreased morale
Communities
  • Increased safety risk for general public
  • Increased use of medical services
  • Decreased community participation

For more, including strategies to manage fatigue, visit http://www.tc.gc.ca/media/documents/ca-standards/14572e.pdf.

National Aircraft Certification Hosts 5th Delegates Conference in May2009

The 2009 National Aircraft Certification Delegates Conference will be held at the Crowne Plaza Hotel in Ottawa,Ont., from May25–27. The previous conference-held in2006-attracted over 500participants, and a similar turnout is predicted for 2009. All Aircraft Certification delegates are invited to attend. To date, registration has been very successful:the conference is already over 75percent sold out!

The first objective of the conference is to educate delegates and Transport Canada personnel on regulatory developments, policy initiatives, and new technology. The second objective is to foster improved communication between industry and Transport Canada National Aircraft Certification, which is essential to meet the challenges facing the industry and maintain Canada's leading role in aviation.

We encourage you to take this opportunity to strengthen your working relationship with Transport Canada and Aircraft Certification delegates. Invitations to the conference have been sent to all delegates. If you have not yet received an invitation, please register electronically via www.tc.gc.ca/aviation/activepages/DC, or by contacting Glenn Adams at(613)941-6257, or via e-mail at glenn.adams@tc.gc.ca. An electronic confirmation of your registration will be sent to you by e-mail.

The Organizing Committee, which is made up of representatives from industry and Transport Canada, has developed a conference program designed to appeal to all delegates. The program will be available on the Web site listed below in early 2009.

Learning From Our Past Mistakes:A310 Run-up Ends in Collision
A story worth reading again, from Aviation Safety Maintainer 3/1996

The maintenance crew of an Airbus A310 was conducting a normal ground run-up after removing and re-installing both engines. The assigned technicians were qualified and current, and the task routine. But things went suddenly very wrong. As a result, both an expensive aircraft and a building suffered extensive damage.

Both engines were running when the tech-in-charge noted an engine fuel gauge reading high. Suspecting a gauge problem, he requested an observer to pull the landing gear proximity and relay control systems flight/round circuit breakers(CB). He believed(wrongly)that this action would allow him to read and record the correct fuel flow value from the appropriate computer screen. The CBs were pulled, and three seconds later, the aircraft began to move forward and gain speed. All attempts to apply brakes or otherwise stop the aircraft failed and it hit a building.

System deficiencies are evident throughout the lengthy report. The company has a very effective safety program on the operational side, enabling it to respond to safety issues. However, no one in the maintenance organization reports to the safety director. As a result, maintenance cannot be and was not proactive or effective in safety matters, so the tech-in-charge was not trained in run-up breakaway procedures. Furthermore, the maintenance organization did not record or disseminate to all employees information about two previous breakaway occurrences during A310 run-ups.

The report targets the following system deficiencies leading to this accident:

  • The run-up checklist required blocking the mains with large chocks.
  • The only pair of large chocks were at another base and unavailable.
  • The flight/round CBs were pulled without full knowledge of the consequences.
  • Pulling the flight/ground CBs disabled all wheelbrakes, nose steering, and engine thrust reversers.
  • Small chocks did not and could not prevent the aircraft movement.
  • The engine run-up course did not teach breakaway procedures.
  • Neither the procedures nor the run-up check list required the CBs to be pulled.
  • The maintenance personnel involved were not told about two previous occurrences of A310 run-up breakaways.
  • The maintenance organization's safety program did not identify safety deficiencies within the organization.

As a result of this accident, the manufacturer will revise the A310 manual to include a warning that pulling the flight/ground CBs will interrupt the normal operation of the brakes; and the maintenance organization will include breakaway training to all employees involved in engine ground run-ups.

(Ref.:TSB Report A95P0246)


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