Tc Logbook Reviews.

[jb88ci]

I recently had my logbook reviewed and the assessment came back as incomplete. One reason was not enough tasks. The inspector determined that because an aircraft, by type certificate, could have a system installed, I should have experience there. Example, the aircraft type could have oxygen. Ours doesnt, the CASI says that the reg shoudl be interpreted as all systems/structures that could be installed on the aircraft, not all systems/structures installed on the aircraft.

 

A second point was exclusion of experience and skill on an aircraft we worked on to import and recieve a C of A. The CASI says that the aircraft has no flight authority therefore no valid standard of airworthiness and therefore no requirement for maintenance releases, therefore doesn't count. I figure if we hadn't done the maintenance and signed the releases, the boss would have been fined and would never get the CofA.

 

Anybody with experience here or idea's??

[Skywrench]

To quote from the instructions for use in the AME personal logbook:

 

"Licence applicants will be required to demonstrate experience in a number of different tasks under each applicable ATA chaper. To a limited extent, shortage of tasks in some areas may be compensated for by additional experience in others, but the applicant's overall experience must encompass the entire range of systems, structures, and maintenance activities applicable to the ratings requested."

 

"When certifying the completion of specific tasks, the supervising AME or other individual acceptable to the Minister should ensure that the logbook holder has completed a significant portion of the task, and is competent to: 1)Identify the correct standards (2)Select the proper tools (3)Perform the task correctly without supervision, and (4)Complete the necessary documentation."

 

Welcome to the world of TC Inspectors. Everything is open to that particular inspectors interpretation, and the inspector holds the liability of approving you for your licence. I don't agree with the inspector on the fact that by type certificate you should have experience with every system that COULD be installed simply because you are not dealing with a type rating here, but rather a licence approval for what I am assuming is M1 category. On a similar note, I do know of guys that have spent thier own time in other hangars working with engineers just to get a couple of entries in thier logbooks that thier employer could not provide them with (hot section inspections for example, or in your case, go and fill an oxygen bottle with an engineer's supervision).

 

The second point you make is interesting as well with no requirement for maintenance release due to no flight authority. This could conflict with the requirement for you to be able to complete the necessary documentation, but again this is interpretation. Your licence gives you the right to make a maintenance release within limits (ratings, etc.), so the inspector may see the lack of flight authority as a reason to not allow the log entries. But, the fact is the releases were made, so I would then assume that you had met all 4 of the above points of competency.

 

Now what I would do in your shoes is discuss with the CASI what he would like to see as a minimum in the log to get it through the approval process, and start working at meeting that requirement. I am sure the engineers you work with will be able to help you work towards completing the requirements, but if in your opinion the inspector is being unjust, you do have the right to ask for a second opinion from another inspector. Of course, if the other inspector works in the same office they may have the same ideas...

[jb88ci]

There is a staff instruction (msi 18) on the interpretation and evaluation of logbooks.

 

It states "Tasks may have been obtained on a single aircraft type/group (e.g. small piston aircraft, fixed wing only) or systems type (e.g. navigation systems only). The tasks must be representative of the eligible maintenance tasks listed in STD 566, Appendix B, applicable to the aircraft, systems or structures on which the experience (to include total, specialty and civil) was obtained. "

 

To me, "the aircraft" would mean the one that you worked on by mark, not the entire type certificated fleet.

 

Also, TC recognizes experience and skill on military aircraft, pre and post test flight manufacturing, component shop. None of which have flight authority. It's a bit of a pickle. To sign a statement of conformity means the aircraft meets it's type design and is safe for flight. If its not safe for flight, even if it has a c of a, means the flight authority is not valid. It's a circular argument.

 

I did talk to the CASI, he said he'd exclude ATA's from the 'full range' concept as they weren't installed. But I'd need to get 70% of the 'eligible' tasks, from his perception. I counted tasks in my logbook, anything that I could possibly complete. Essentially, they want me to perform 90% of possible tasks to get the 70% of what they think applies.