The requirements for the Maintenance Controller (MC) to maintain records is outlined in Section 10.07 – RPAS Technical Log. The first requirement for the RPAS Technical Log is to identify the RPAS,
Section 10.07(1)(c) information identifying the RPAS, including:
(i) the type, model and unique identification mark of the RPA; and
(ii) the unique identification mark of the RPA in any previous configuration (if applicable);
Where unique identification mark and configuration means the following from Section 10.01,
configuration of an RPA mentioned in this Chapter is comprised of the particular RPA’s airframe, engines and motors, and all of the flight control system hardware for the RPA.
Note: The configuration of an RPA for its unique identification mark does not include propellers, rotors or batteries.
unique identification mark, for an RPAS for an RPA mentioned in this Chapter, is the number (and letters, if any) that the certified RPA operator or other operator, as the case may be, ascribes to each configuration of the RPA that he or she operates.
The new concept Maintenance Controller’s will need to contend with is around configurations. MC’s will need to ensure their naming scheme for their RPAS will consider the configuration name when a motor or autopilot is changed out.
For example if you had named your fleet of Phantom 4 Pro’s P4P-01, -02. etc. you would need to append an additional identifier such as A, B, C etc. Therefore, the full name would be P4P-01-A as an example. This full unique identification mark would need to be used across all records as well as the physical label on the RPAS.
How this will impact registration is not yet known as a change in unique identification mark may require an update to the RPAS registration. If an update to registration is required one would anticipate that it would make CASA aware of a change has occurred and may trigger a request from CASA to see the RPAS Technical log to understand why the change has occurred. This mechanism is described in Section 10.07(4)
Within the period of 7 years after the last time the RPA is operated by the operator, he or she must, as soon as practicable, provide a copy of the RPA technical log to CASA upon written request.
One would assume this is only likely to occur if a trend emerged for a particular make and model of RPAS and the regulator was concerned about a specific defect. Regardless, Maintenance Controllers should ensure their RPAS Technical Log’s are not only up to date and accurate as the RPAS Technical Log can also be requested at any time under the following Section 10.07(5) by anybody that makes a request,
Within the period of 7 years after the last time the RPA is operated by the operator, he or she must, as soon as practicable, provide a copy of the RPA technical log to a person who:
(a) makes a written request for the log; and
(b) provides reasonable evidence that he or she is the new operator of the RPA; and
(c) provides payment for preparation and provision of the log, based on a reasonable cost recovery for such preparation and provision.
Note: The complete technical history of an RPAS is of vital importance to the safety of future RPA operations by the new operator.
It is clear from the above that the integrity and accuracy of the RPAS Technical Log is very important to the regulator and must survive across owners for the entire lifetime of the RPAS. Therefore, it it imperative for MC’s to be on top of the RPAS Technical Log at all times.
In terms of the specifics required under the RPAS Technical Log they are outlined in the following section,
Section 10.07(1)(d) information relating to the continuing airworthiness of the RPAS, including:
(i) the total flight time the RPA has been operated;
(ii) for an RPA whose gross weight is more than 2 kg — individual in-service times for engines, motors, rotors and propellers;
(iii) the maximum gross weight of the RPA;
(iv) the minimum gross weight or payload required for the RPA to operate (if applicable);
(v) for an RPA whose gross weight is more than 2 kg — the maintenance schedule for the RPAS;
(vi) for an RPA whose gross weight is more than 2 kg — the maintenance carried out on the RPA in accordance with the operator’s documented practices and procedures;
(vii) the date or operational time for the next maintenance action;
(viii) for an RPA whose gross weight is more than 2 kg — the results of any rectification of defective equipment essential to the safety of the RPAS operation;
(ix) if fail-safe equipment that is fitted to the RPA is unserviceable:
(A) a description of each piece of such equipment; and
(B) an explanation for its unserviceability; and
(C) the precautions required, or limitations imposed, when operating the RPA with the unserviceable fail-safe equipment;
(x) certification by the person mentioned in paragraph (1) (a) or (1) (b) (as the case requires) that all maintenance required for the RPAS to be serviceable for operations has been completed.
Note: A requirement to record a certification is met by including a copy of the certificate with the record.
Needless to say the requirements for the RPAS Technical Log are comprehensive and detailed. Maintaining such things are individual in-service times for motors and propellers are challenging to say the least. We should also note while some requirements of this section are not applicable to sub 2kg RPA it would best practice to maintain the same standard across the entire fleet.
We have built the FlyFreely platform to handle these requirements and many more. Maintenance Controllers will have a complete suite of tools that will enable them to meet their obligations while reducing the burden of paperwork.
This and other key features relevant to Maintenance Controllers are detailed in our Part 101 MOS Compliance Guide. Fill in this form to obtain your copy today.