- Records are a nuisance.
- They detract from the time to be spent on the real job, maintaining the aircraft.
- What does silly paper have to do with safety?
- I spend hours writing them and no one ever reads them!
- I’ve got more important things to do than writing down what I just did.
Say the word “records” in a room of Aviation Maintenance Technicians or owners/pilots and the above statements and more will freely flow from the mouths of the experienced MX professionals. The below headline, about a GA aircraft, explains the consequences of intentional, and perhaps flagrant inadvertent, improper entries on the variety of records which the FAA requires.
- Why are these documents so important to the FAA?
- What are the consequences to failing to be accurate on these records?
The safety agency depends on papers to meet its mission—SAFETY. The inspectors RELY on the documents explaining what an AMT or owner/pilot has done. They have neither the time nor perhaps the expertise to examine the actual repairs or other MX procedures; so their focus becomes what was written down. Under SMS (for all certificate holders now and eventually all aircraft) that regulatory construct depends of both volumes of data and their accuracy.
If this positive explanation of the purpose of record-keeping is inadequate motivation, the example of USA v. Morgan and other criminal cases should be an effective deterrence to bad records. Humiliating arrest, an inordinate amount of your time preparing a defense, the cost of lawyers, expert fees, unpleasant time in a court room and the possibilities of jail time, probation and/or payments are potential consequences to sloppy or bad records.
The rules for record keeping are not entirely intuitive. Expertise is a predicate to getting it right and the definition of a correct entry changes over time, particularly as to parts.
Criminal prosecution relates to intentional violations. There is no hard, objective test which differentiates between sloppy entries and those made maliciously. Proof of this criminal activity is usually made by indirect evidence. Mr. Morgan’s downfall was trading a plane in an unairworthy condition with records claiming that all was OK. The prosecutor will look for patterns; lots of bad (sloppy) records mean INTENT to the US attorney. A person or organization, who/which does not implement HIGH STANDARDS to the correctness of records, is an easy target for an indirect proof of intention. “Plausible deniability” is a losing defense.
So when it is the end of a long day spent bending into the powerplant or some structural element, quickly scribbling down what you think that you may have done may result in your becoming familiar with your nearby US Attorney.
- First, you need to be 100% current on what the FAA requires for such entries and
- Second, the care and time needed to make those records right should be
- motivated by the FAA’s regulatory rational for them and
- deterred by Mr. Morgan and others’ example.
Experience teaches you that knowledge and proper technique define the difference between safety and unacceptable MX. Mr. Morgan’s unfortunate, yet deserved, fate should compel the same mental acuity when you sit down to make those record entries!