Just scanning and backing-up logbook entries into electronic images is not as simple as it sounds. To have an electronic back-up of a FAR Part 43 Logbook entry requires a licensed A&P to certify that the copy is the same as the original. And, a complete back-up of an entire aircraft record requires special handling to be compliant with current FARs and FAA legal if it is to be considered as a real logbook. It’s a complicated process! Let’s look at the different approaches we commonly use in business aviation, and which ones really provide the electronic back-up we think we have.
THE ONE PHONE CALL THAT CHANGES EVERYTHING
You’re the Director of Maintenance for a certain company’s flight operations. Yesterday, you were involved with a problem with one of the aircraft you operate. Fortunately, you fixed the problem, allowing the aircraft to make the flight it had scheduled this morning.
Suddenly the phone rings. Upon answering, you get the worst news a Director of Maintenance will ever get. This same aircraft has been involved in a serious accident during landing at its intended destination. Upon touchdown, the right tire blew sending the aircraft careening off the right side of the runway, collapsing the right gear as it left the pavement. There was a fire. The good news is everyone on board got out safely. The bad news – the aircraft is a total loss.
As an experienced DOM, you know that things are about to get really busy, and you mentally go through a checklist of items you will need to provide if there is an accident investigation. And, sure enough, there is. As a result of its investigation, the NTSB determined that the right brake caught on fire, causing the tire to blow and the aircraft to exit the runway and experience the fire that ultimately consumed it.
SHOW ME THE 8130
Since the brakes on this aircraft are listed as Time-Controlled-Items, the investigator sent by the NTSB to audit the aircraft’s logbooks wants to see the 8130 Airworthiness Tag associated with this brake. A thorough search through the records finds the 8130 to be missing. Since the brake was changed several months before you took over the maintenance of the aircraft, you don’t know the reason why the 8130 is missing. However, you are aware that an electronic back-up comprising the aircraft’s logbooks was made several months before you came on board. Looking through the 8130s in the electronic
back-up on the maintenance computer you discover the 8130 that is missing and believe you can use it to restore the paper record. Your home-free right? Wrong!
Let’s examine the three most commonly used methods to develop an electronic back-up of a logbook in more detail:
The aircraft records were backed-up into pdf images using a scanner in the flight department office or with a local scanning company and stored on the computer in the office, and/or on the main computer or server at company headquarters.
THE PROBLEM WITH THIS METHOD
There are several problems with this method: the FAA has gone on record many times stating that FAR 43 documents used to prove the Airworthiness of an aircraft must be “original” documents (checkout legal proceedings involving the FAA). A copy of an original document is not accepted in a court of law. So, how do you make a scanned copy of an original logbook entry so that it is accepted as a legitimate replacement for the original paper record? At a minimum, it requires an A&P to certify that the scanned copy is an exact replica of the original paper document. The second problem is with the storage of the document; for the document to be considered “safe” from modification in violation of FAR43.12, it should be stored in an AC120-78A compliant security system (for example), not just on the office computer or someone’s laptop.
I give you an envelope and tell you that in it is a $100 bill. You place the envelope in a desk drawer in the office. Several months later you decide you need the $100. So, you retrieve the envelope only to find that there is not $100 in it, but only $1. What happened to the rest of the money? You can’t be certain. Did I deceive you in the beginning? Was the money removed at some point by someone who had access to the desk drawer? No one will ever really know. And that’s the point. The money was neither verified in the beginning nor secure.
Many of the aircraft records have been personally backed-up by you, one event at a time, as the Director of Maintenance (a licensed A&P Technician), and sent to the Maintenance Tracking Company for storage in e-log. And, many of the aircraft’s older records were also diligently sent to file in e-log by your predecessor. You are certain of their authenticity. The remaining (oldest) documents have not ever been scanned.
THE PROBLEM WITH THIS METHOD
Since it was an A&P Technician that did the initial scanning, another A&P would probably be willing to verify that the documents were an exact replica of the original paper documents going in. That takes care of the first concern (especially for documents you were responsible for sending to the maintenance tracking company). The Maintenance Tracking Company states that it will store the documents in an AC120-78A compliant security environment. The problem lies in both the time the documents were exposed in a non-secure environment and any documents that were not part of the data package sent by you or the other DOM (who is presumably an A&P Technician).
I give you an envelope and tell you that there is a total of one hundred $1 bills inside. You verify that there are a lot of bills, but don’t count them. You then ask a friend to store them in their personal safe in the office next door to yours. Several months later you decide you need the $100. So, you retrieve the envelope only to find that there are not a hundred $1 bills inside, but only sixty (remember, you did verify that there were a lot of bills inside). So, what happened to the rest of the money? You can’t be certain. Did I deceive you in the beginning? Or was the money removed at some point by someone other than your friend who also had access to the safe? And that’s my second point. The money was neither verified in the beginning nor positively secure.
All the aircraft’s archived records, as well as on-going documents, are backed-up and verified that the scanned copies are the same as originals by a licensed A&P Technician. The records are immediately placed into an AC120-78A Compliant Security System by you or a trusted source and remain stored in this secure environment for the life of the aircraft.
WHY THIS METHOD IS BEST
This method is best for several reasons:
The aircraft’s original records are scanned and certified by an A&P that the scanned copies are an exact replicate of the original records. So, going into the secure system they’re solid.
Next, the scanned copies are immediately placed into an AC120-78A compliant security system for the life of the aircraft avoiding the opportunity for someone to alter the documents.
These records are then available for use as “original” records anytime they are needed in the future, with the assurance that the records have not been altered. That way, if it becomes necessary for another A&P Technician to certify one or all the documents as an exact copy of the original, he/she would be able to do so without concern that they never actually saw the original paper document(s).
I give you an envelope and tell you that there is a $100-dollar bill inside. You verify that; indeed, the envelope contains a $100-dollar bill. Then you take the envelope and place it into your own safe that only you and the safe manufacturer know the combination to. In this way, you and any others that might require the $100 in the future, are reasonably certain that the envelope will still contain the $100-dollar bill.
THE BOTTOM LINE
Whether your scanning your records to get the aircraft’s legacy paper records digital in order to go forward with a modern electronic recordkeeping system or scanning them to have as an electronic back-up to the paper record; scanning and managing the records properly is paramount!
Maintenance tracking companies are guilty of letting you think you have a logbook back- up when you don’t. Not convinced? Do more research for yourself if you need to, but don’t be lulled into the common trap of thinking that because many of your logbook entries have been scanned and sent to your maintenance tracking company, you have a viable back- up. You don’t.
My suggestion: scan your aircraft’s paper records using Method #3. The recorded maintenance history of the aircraft has proven time-and-time again to be a significant contributor to the overall value of the aircraft. You know how seriously the records are taken whenever the aircraft is sold or involved in an incident or accident. So, take them seriously now. Back them up properly like the valuable asset they are. You will never regret this decision. And one day, it may prove to be worth its weight in gold!
See “Scanning and Using Aircraft Maintenance Records” for additional info on backing up your paper aircraft records with a certified electronic aircraft logbook.