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Testimony of Caroline Daniels
Chief Executive Officer
Aircraft Technical Publishers
101 South Hill Drive Brisbane, CA
94405-12034
before the
National Civil Aviation Review Commission
October 8, 1997
Table of Contents
Caroline Daniels, Chief Executive Officer, Aircraft Technical Publishers
I welcome this opportunity to discuss with the Commission a subject which our company
has focused on for a number of years, namely, the critical need in our industry for
electronic maintenance record keeping. The FAA must take a leadership role on this subject
and failure to do so will compromise aviation safety. Furthermore, the aviation industry
is not taking advantage of proven technological solutions which will benefit us all.
Aircraft Technical Publishers was founded 25 years ago with a mission to enhance safety
by providing "single source" aircraft maintenance and regulatory library
services to the aviation industry. Our primary emphasis had been in the general aviation
marketplace. For the past five years, our company (with 150 employees) has become a
leading electronic publisher for the aviation community servicing over 9,000 customers
worldwide. We understand electronic technology, and we appreciate what it can do to
enhance safety in this industry.
About five years ago, ATP was approached by a leading aircraft engine manufacturer to
develop an electronic logbook system which could alleviate their burdensome paper-based
record keeping system. We have continued to find an intense desire by manufacturers to
have a system whereby electronic records could accompany parts and components throughout
their lifetime. Manufacturers also see tremendous benefit to having the ability to
electronically monitor maintenance-related activities in order to enhance parts ordering
and maintenance scheduling systems.
In addition, FBOs and other maintenance providers enthusiastically support the concept
of an electronic logbook system which would save them money and increase efficiency. ATP
staff members chair committees at GAMA and NATA which have worked for a number of years to
promote electronic record keeping initiatives, and we know that the need is there.
However, despite this demand, there has been a roadblock to effective deployment of
electronic record keeping systems. The problem is that the FAA currently does not
recognize electronic records, and there have been no standards established to govern their
structure and use. In essence, the FAA is mandating that paper maintenance records be
utilized.
Since the late 1980s, the FAA has granted exceptions and authorized use of maintenance
electronic record keeping systems to scheduled air carriers on a case-by-case basis. But
for the remainder of the aviation community, electronic record keeping is still not
accepted.
Six years ago, a draft NPRM on this issue was prepared through the ARAC (Aviation
Rule-Making Advisory Committee) and there has been continued work on it since then. But
the NPRM has never been released for comment. Unfortunately, many who worked on this
effort within the FAA have retired or otherwise left the agency, and momentum appears to
have been lost.
I'd like to take a few moments to discuss the proposed NPRM and the implications of
electronic record keeping. The NPRM would amend the FAR that prescribes requirements for
maintenance records. As currently written, the FAR does not reflect technology advances
which can impact maintenance record keeping and aviation safety.
The proposal would authorize and encourage, but not mandate, the use of electronic
record keeping systems. It would standardize maintenance requirements related to the
transfer of information and retention requirements, and would permit the use of electronic
signatures to satisfy maintenance and certain operational record retention requirements.
The benefits of electronic record keeping are many:
I believe that we all recognize that eventually the FAA will authorize (and finally
mandate) the use of electronic record keeping. It would be irresponsible not to do so now.
Unfortunately, there are serious consequences if action is delayed further:
What should be done? Please urge the FAA to immediately release the NPRM and begin the
arduous task of collecting industry comments. The aviation community has waited too long,
and it will jump at the opportunity to provide input on this very important subject. ATP
would be pleased to offer our assistance in this process.
Thank you very much for giving me this opportunity to discuss this issue with the
Commission. I know that you have devoted a great deal of your personal time as Commission
members, and you all are to be commended for your contributions.
Following is a more detailed discussion of the issues
surrounding electronic maintenance record keeping.
ELECTRONIC MAINTENANCE RECORD KEEPING
Extensive electronic maintenance record keeping recommendations have been incorporated into a Notice of Proposed Rule Making (NPRM), which was first drafted in 1991 by an FAA aviation rule making advisory committee (ARAC), and has never been released for industry comment.
Specifically, these recommendations seek to eliminate any requirement that maintenance records for aircraft be kept in paper form, although the use of paper will remain as an option. All regulations, including FAR part 43--the basic aircraft maintenance rules--as well as parts 91, 121, 135, 145, 21, and 183 are proposed to change to facilitate the use of electronic maintenance data storage. Part 65 which is the certification basis for those who maintain the aircraft is also being changed. A key component of the proposed new rules which will apply to any party carrying out aircraft maintenance (such as a mechanic, a Part 121 or 135 certificate holder) is based on the substitution of a single word. At this time, the regulations mandate that maintenance records be kept in a "form" and manner acceptable to the administrator of the FAA. Now, they will state that the records will be kept in a "format" and manner acceptable to the administrator of the FAA. That use of the word "format" will allow (but not mandate) electronic record keeping, and even open the door to future technologies that differ from current data storage/retrieval systems. By offering maintenance shops the option to create electronic aircraft maintenance logbooks, the NPRM has recognized that the technology is in place to eliminate paper-based record-keeping, which has always been a cumbersome, error-prone process.
The application of electronic data systems to aircraft maintenance is not a new
concept, but it has been limited mostly to the tracking of projected or scheduled
maintenance events, such as major inspections. That, however, is changing. Even now, new
electronic data systems are being developed which will take on additional functions. If
the proposed rules go into effect, they will permit the use of data systems which will
show an aircraft's entire maintenance history, preserved in digital format. That history
will include not only those repairs that apply to a specific maintenance schedule, but the
unanticipated minor, or unscheduled major repair, as well.
The advantage of electronic logbooks is to eliminate the major drawbacks of paper-based maintenance records. Those drawbacks are easy to identify. For example, a typical business aircraft's maintenance logbooks could be hundreds or even thousands of pages long. The logbooks must incorporate all of the maintenance events that took place on the aircraft, including inspections of major systems and life-limited components; modifications, and any work related to service bulletins or airworthiness directives.
When that aircraft is sent to a maintenance facility for repairs, modifications, or for a pre-purchase inspection, a careful examination of all pages of the maintenance records--as they exist up to that time--must be made. Culling through a paper maintenance log can be a formidable task. In fact, it is not uncommon for that process to consume three to five days in order for the shop to determine the current maintenance status of the aircraft..
As a rule, the larger, or more complex the aircraft, the greater the library of historical maintenance data. This makes it even harder to locate a specific item of information, as, for instance, when a landing gear component was last serviced.
Other disadvantages of paper-based maintenance logbooks, in addition to their obvious weight and bulk, include illegibility, (since many are filled out by hand) or incomplete and inconsistent entry of data. This is especially true if more than one person or facility is involved with updating the records. In addition, pages tend to become detached and disorganized, or even lost.
Paper maintenance logs also normally lack suitable indexes for researching specific information. And, because they are paper, the only way to create a "back-up" record is to photocopy each page individually. Many maintenance departments will not do this because of time constraints or because the facility does not have sufficient space to store redundant records.
The ability to electronically store maintenance records virtually eliminates all of
these problems, while providing countless advantages.
First of all, information pertaining to a specific aircraft or maintenance event can easily be accessed through use of a simple search engine. And, along with the obvious reduction in the amount of space required to store a few disks, vis a vis stacks of paper logs, the maintenance data can easily be electronically transmitted to other facilities through the use of computer networks--either from a PC or mainframe. At the same time, repair information can be more detailed in format, and more standardized; and therefore, more comprehensive.
Electronic record keeping software, in fact, can be designed with built in checks and balances ensuring that all data entered is done in a standard format by constantly comparing what is being entered to a minimum standard list of requirements, not only for entry, but for overall system maintenance. The mechanic can also be sure that he correctly follows all procedures pertaining to the repair of the aircraft, through the use of a "completeness screen" which will trigger an alert if a necessary procedure has not been recorded in the maintenance log.
With electronic records, making back-up copies is as easy as making a backup of any computer file. Along with this, electronic record keeping will expedite the research process pertaining to a specific aircraft's maintenance history. Mechanics will have the capability to access, instantly data about every part or component that has been changed or serviced throughout the life of the aircraft. Along with this information, an up to the minute status report can be provided on each aircraft system including information pertaining to service bulletins, or airworthiness directives. Data concerning recurring maintenance, likewise, will be instantly accessible.
Because maintenance data can be so easily retrieved, parts tracking capabilities will be greatly enhanced. This means that a complete history of any given part will be instantly available including origin, place of installation, the time on the airframe, and the time remaining, if it is a life-limited component. As a further benefit, the system could be used to alert the mechanic to the existence of suspect or bogus parts, since parts can be tracked by serial number.
The ultimate benefit will be a total, unobscured picture of the maintenance history of
the aircraft at a substantial cost savings, not only for the maintenance facility, but for
any authorized inspector of maintenance records. In many cases, third parties, including
repair stations, charge for their time when carrying out inspections of logbooks.
Ultimately, this cost savings benefits the aircraft owner.
Once electronic maintenance record keeping is authorized, and its use becomes more commonplace, more software products will be become available. Many repair stations, today, have multiple tracking systems for different parts and system maintenance schedules. New software will allow the capability not only to standardize the way such schedules are tracked, but the maintenance record keeping process, itself.
In fact, current trends in rule-making are moving the FAA, itself, toward standardized regulations for all maintenance record keeping requirements. The new rules will be based on the premise that whether an aircraft has been operated under Part 91, 121 or 135, maintenance of some kind has been performed and recorded. Under the suggested rules for changes in FAR part 43, the new rules would mandate that all known information pertaining to the aircraft's maintenance status be transferred with the aircraft any time it changes ownership or its operation changes.
As Fred Workley, president of the Washington D.C.-based consulting firm Workley Aircraft Maintenance explained, the proposed rules stipulate that this information, known as the aircraft data frame set, must encompass all of the maintenance performed. This includes all airworthiness directives, the status of life limited components; as well as the present configuration of all hardware and software systems.
Because total disclosure will be required by the new rules, Workley believes that the time has come to move away from all paper-based maintenance record keeping. Still, he noted that, in doing so, some concerns will still have to be addressed.
"For instance, how will a digital record be updated as entries (transactions) take place? How can we assure that all records are maintained and updated in a format that is easily retrievable? Validation of any electronic records will mean replacing a hand-written signature with an individual pass code or some other type of identifier."
According to Workley, moving to an electronic data storage system will require shops to devise such a validation method, which would have to be articulated in the repair station's manual.
"This is one example of the standardization that the proposed rules would assure. In that way, no matter who does the record keeping, the requirements are going to be the same and will be spelled out under FAR part 43." Workley stated that, as its ultimate objective, electronic record keeping will address the human factors that lead to errors in maintenance logs.
"Anything that can be done through technology and procedures to eliminate error in record keeping will go a long way to assure airworthiness," he said.
In the view of Mike Mertens, chief inspector and manager of quality assurance at Duncan Aviation in Lincoln, Nebraska, the scope of the rule changes will virtually mandate the use of electronic maintenance logs, especially for operators of more than one aircraft.
Mertens, in fact, has already developed a maintenance database that tracks, by make, model and serial number, his customers' aircraft. In addition, the required maintenance and inspection recommendations of the manufacturer are noted. Those recommendations, he pointed out, are the basis for most aircraft maintenance programs in the United States.
"Using the manufacturer's recommendations, the database pulls up a list of maintenance tasks that could be done on the aircraft at the time it is brought in for other work, such as a 300 hour inspection," said Mertens. "Interestingly enough, most aircraft operators are aware of the major mandated maintenance events, but often are not aware of other work and inspections that should be done at the same time. What we are keeping, then, is an electronic snap shot of the logbooks showing what was actually repaired, and what other tasks could have been done. It's an electronic check and balance system."
Mertens said that by getting rid of paper maintenance records and putting everything into an electronic medium, the chances are better that maintenance tasks which are often overlooked will be performed.
But he cautioned that in order for it to be effective, electronic record keeping formats will have to be standardized.
"A standardized format will allow everybody's computer to talk to the other. This means that whatever system is developed will have to be extremely user friendly. Once this is done, researching the database could be a lot easier."
As Mertens explained, an electronic record keeping system must answer two basic questions concerning aircraft maintenance: Is the aircraft owner conforming to the maintenance requirements by calendar date, flight hours or cycles; and has everything been done that really has to be done?
"In our experience, few owners really know what they have to do to put their
aircraft in complete compliance with the manufacturer's recommendations There are many
inspections, replacements and even airworthiness directives that they do not know about.
With paper logbooks, it is very difficult to track this, unless you have an extremely good
check list."
Mertens predicted that an electronic maintenance program could save anywhere between eight and ten hours of research in a paper logbook per airplane. There are, however, older aircraft, that come in with as much as 4-6 paper maintenance logbooks of 50-60 pages each, which would take far more research time. But he cautioned, "if electronic record keeping means putting a lot of data into an electronic form, that, in and of itself, won't save time. The time savings potential of electronic maintenance records can only come about if the data is presented in a standard order and classification--and if it can easily interface with other programs. Then, you need to add a list of what the manufacturer requires, so you can see what you have complied with, and what still needs to be done."
He added that electronic logbooks will also facilitate quick changes in maintenance procedures, as manufacturers put revisions into effect. Mertens said that the new FAA rules will more clearly spell out the basic premise of aircraft maintenance.
"In the United States, the aircraft owner bares the responsibility of knowing the complete maintenance status or condition of his aircraft. The new rules will make that clear. Today, the rules can be interpreted more toward the premise that the owner is simply responsible for maintaining the aircraft.
An interesting benefit of electronic maintenance records will be the issue of fraud, as Mertens explained. "Today, there are aircraft sold without full disclosure of accident-related damage. The proposed rules (with respect to maintenance status) will not only require the logbooks to show what maintenance was performed, but why. Electronic logbooks have the potential to keep the industry honest."
While there is no question that converting to an electronic system of maintenance
record keeping will require some investment in time and money, the end result will be a
constant payoff in faster, more efficient data retrieval, and enhanced safety of flight.
New rules allowing digital maintenance record keeping will be finalized soon. With the
software tools now available, now is the perfect time to formulate a game plan to convert
volumes of paper based maintenance documents to easily accessible--and readable--digital
records.
| Some of these comments are excerpts from an article by Paul Seidenman which appeared in Aircraft Maintenance June 1997. |