How to Keep the Fleet Flying
An Airworthiness Refresher for Flight Instructors
We all want to ensure that every aircraft is safe and airworthy. Whether a pilot, aircraft maintenance engineer, or the flying public, we expect it. One of the most critical tools in ensuring this is the Journey Logbook (JLB). However, despite modified flight test standards we continue to see weaknesses in flight school operations. The anecdotal result we hear from commercial operators is that pilots hired with fresh commercial licenses don’t understand how to “snag” an airplane (record a defect). Why not? We understand that they were not given the opportunity to write in the JLB at their flight school.
Many accidents have been caused by incomplete JLB entries surrounding defects and maintenance actions. One that comes to mind in the flight training world cost the life of a flight instructor in 1998. Remember, if we see a defect it MUST be entered into JLB. Verbal reports, unofficial snag sheets, and the like are NOT replacements for a JLB entry.
The Regulations
Canadian Aviation Regulation 605.94 states:
The particulars set out in column I of an item in Schedule I to this Division shall be recorded in the journey log at the time set out in column II of the item and by the person responsible for making entries set out in column III of that item.
In other words, we need to look at Appendix 1 to find out Which Particular (in our case, defect) shall be entered When and by Who. Let’s look at cases 9 and 10 in Appendix 1:
If the defect is found during flight, the Pilot-In-Command is responsible for making the JLB entry and must do so before the plane goes for its next flight, at the latest. If a defect is found on the ground, say during the pre-flight inspection and the defect is not rectified, the defect must be entered before the next flight by the person who discovered the defect. Therefore, students need training in making JLB entries and if they discover the defect on the ground, or were the PIC for the flight, they are supposed to be making the entry (under supervision, ideally).
The Arguments
“I don’t want students writing defects; they find things that aren’t really defects.” For example, snagging a radio as inoperative when the real cause was the student leaving the volume turned down. This is of course where supervision and guidance come into play. It is recommended that the instructor play a role in identifying if a defect exists, then supervising the entry if one is required.
“Our Maintenance Control Manual (MCM) doesn’t require the defect to be recorded in the JLB.” The MCM is approved by Transport Canada and cannot be less restrictive than the CARs. A review of the actual MCM and above CAR may be warranted – you will mostly likely find that people have been working under a misconception.
“The aircraft will be grounded and unusable if they make the snag in the JLB.” Flight instructors are paid by the hour and when maintenance may not be readily available, they don’t want to miss out on a flight for a seemingly small defect. However, that defect needs to be recorded so that other pilots are aware, and they can decide for themselves if there is a safety implication. Now, let’s look at why the aircraft can actually go flying rather easily with a snag in the JLB – negating this concern.
The Personnel
If the defect does not affect airworthiness, and in the opinion of the pilot-in-command aviation safety is not affected, the defect can be deferred for a period of time. Each MCM will detail the process and who may defer a defect. The Person Responsible for Maintenance (PRM) is sometimes the only person on that list. However, the PRM cannot be on call 24/7/365. This often normalizes people deviating from the process identified in the MCM.
For this reason, many operators allow other delegates to defer items when the PRM is not available. For example, the Chief Instructor, Duty Instructors, and so on. As long as there is a process in the MCM and those people are appropriately trained, this is perfectly acceptable.
The Process
Here is a general outline of what the PRM and their delegates review in determining if a defect may be deferred.
Is the defective equipment or component required by the type certificate or a supplemental type certificate? This generally includes major, obvious, items for safe flight as part of the aircraft’s design approval such as wings, flaps, propeller, etc. These items are covered in Part V of the CARs.
Is the defective equipment or component required elsewhere in the CARs? Equipment requirements (eg day, night, VFR, IFR) can be found in CAR 605.14, but if the aircraft is being used for flight training CAR 425.23 would also apply.
Is the defective equipment or component required by the Pilot Operating Handbook? This could be as a limitation or required equipment (Section 2), or as part of a procedure or checklist. For example, if the first step of “Engine Fire on Ground” is to set the parking brake, the parking brake is required equipment.
Do any Airworthiness Directives (ADs) affect the equipment or operation? ADs are issued where systemic safety concerns are discovered and may involve additional inspections. For example, you discover during the day that the landing light is inoperative. We all “know” that the aircraft would still be legal to fly a Day-VFR training flight so we might be tempted to just ignore it. But what if there was an AD affecting the landing light that requires a wiring harness inspection if the light fails? Only personnel authorized in deferral would have this information readily available.
From my experience in both maintenance and operational roles, I can say with certainly that 90% of the time we were able to safely and legally dispatch an aircraft by deferring a defect (though sometimes with limitations, such as no flight at night) and get the pilot quickly on their way.
Conclusion
Many of us are not as familiar with our operator’s MCM as we should be. I encourage everyone to review theirs. The core document is usually well under 50 pages. You may be surprised that what you have been told all these years may not really be what is written in the MCM.
Finally, please keep in mind that not making JLB entries in accordance with the CARs, because that’s the culture at your flight school, does not absolve you of liability [para 93] if something goes wrong. As licensed pilots, we are expected to know and follow the regulations. As flight instructors, we are obliged to ensure that we fully train our students.
Are you looking for other ways to improve yourself as a flight training educator and professional pilot? Did you know you can renew your fight instructor rating by attending our Flight Instructor Refresher Course instead of doing a flight test? We discuss many ways to improve your operation and the quality of flight training delivered to students.