An Inspector’s Perspective on Logs
An FCC Inspector Helps You Avoid the Record-Keeping
Problems He Has Seen at Other Stations
Ronald Ramage
The author is assigned to the FCC Enforcement
Bureau’s Kansas City Office, from which he has conducted
broadcast inspections for more than 17 years.
For most of us, the mere mention of "paperwork"
produces many responses, rarely positive.
Unfortunately, documentation of our activities
is a necessary part of business. Station logs and records are
no exception.
All licensees are required to keep them. But
are the logs kept simply because the FCC requires them, or used
as a helpful and inexpensive tool?
It has been my experience that licensees who
properly maintain logs of FCC required items have significantly
fewer violations, less downtime and better managerial control
of their overall operation.
The reason is fairly simple. With the exception
of Emergency Alert System requirements, logs document observed
problems and corrective actions. When done properly, the logging
of observed technical problems can lead to the detection and correction
of problems before they cause major down time, equipment failures
or fines.
Logging also can provide managers with some
assurance that station personnel are detecting and correcting
problems to their satisfaction and in a timely manner. Best of
all, when done properly, logging costs only a little paper and
a little time.
Required entries
Items that must be in the station’s log
include all EAS activations, sent or received, entries documenting
why an EAS test was not sent or received, and entries documenting
circumstances where a problem with any station equipment or operation
required corrective action to maintain compliance with the rules
and station authorization(s).
In addition, AM directional stations must log
field intensity measurements made at designated monitoring points.
Except for the logging of EAS activations, the
emphasis should be to log observed problems and corrective
actions. For non-EAS equipment, FCC rules require a log entry
whenever a meter, transmitter, antenna or other necessary piece
of equipment is found out of calibration, out of service, repaired
for any reason, replaced, damaged, changed, etc.
If the licensee owns the tower, then he/she
also is required to log any tower light outages, regardless of
the position of the light on the tower.
Note that the FCC does not require licensees
to log routine transmitter readings, time that tower lighting
is checked and many other items that licensees may log on their
own. Licensees check many of those items for operational purposes
and most elect to log the information for their own use, for good
reason.
However, sometimes the non-required logging
becomes routine and the required logging is ignored or neglected.
Monitoring and calibration
How often should station personnel make the
observations that lead to a log entry?
In an effort to allow licensees as much flexibility
in their operation as possible, the rules do not specify a schedule
for monitoring operating parameters, calibrating equipment and
inspecting the transmitting system. The rules do specify that
the licensee is to maintain compliance with his/her station authorization
and the technical rules pertaining to the operation of the station.
Keep in mind that licensees are to correct any
out-of-tolerance conditions that could cause interference, or
go off the air, within the three-hour or three-minute time periods
specified in 47 CFR §73.1350(d).
The three-hour or three-minute time period in
which the station must take corrective action is from the time
the station begins the out-of-tolerance operation and not
from the time station personnel decided to check on the station.
FCC rules require licensees to establish schedules
and procedures for monitoring station operation and for calibrating
required equipment as needed to maintain compliance with the technical
operation of the station. See 47 CFR §73.1350(c).
The rules do not specifically state that these
schedules and procedures be in writing. However, putting the schedules
and procedures in writing provides station personnel with a written
reminder of what is expected of them with regard to making observations
of power, frequency, modulation and, where applicable, tower lighting,
AM directional parameters and AM directional field strength at
designated monitoring points.
The procedures also can instruct personnel on
what, when, where and how to make log entries.
I will request that a licensee submit them in
writing in response to a Notice of Violation, if there is a detected
problem at the station that indicates a lack of such schedules
or procedures.
Also keep in mind that if an out-of-tolerance
condition is detected at the station during an inspection, either
the schedules were not sufficient to catch the problem or the
problem just occurred.
In the latter case, will the stations logs,
schedules and procedures help support a licensee’s contention
that the power, frequency or modulation problem began within the
three hours/three minutes prior to the inspection?
Amount of detail
How much detail should the log include?
Section 73.1800 of the rules states that the
logs should "accurately reflect the station operation,"
that they be kept in "an orderly and legible manner,"
and "in suitable form and in such detail" that they
provide an "accurate representation of what transpired."
It also states that "any employee making
a log entry shall sign the log."
A good example of the type of detail to include
is in Section 17.49, which describes what is to be logged in reference
to an observed tower light outage.
The rules require the tower owner to log, among
other things, what the outage is, the date and time it was observed,
the date and time it was placed back into service and what was
done to bring it back into service.
Do your logs contain this amount of information
for any equipment outage at the station? Can a reasonable person
understand what occurred from the entries made?
I encourage station managers to review their
stations’ logs occasionally to see if they can reconstruct
what the problem was and what was done to correct it. If they
cannot read it or understand what occurred, I probably will not
either.
The log is your record of what you did. It can
be a valuable tool to cover yourself and your efforts.
If the tower light was out and you called the
FAA, but they cannot find any record of your call, do you have
sufficient information to prove you made the call when asked days
or weeks later?
What number did you call? When? Who did you
talk to? Did they give you any tracking numbers? The rules do
not require the logging of these specific items, but think of
the problems such documentation can eliminate.
Chief operator review
In my opinion, the chief operator’s weekly
review of the logs, as required in section 73.1870(c) of the rules,
is one of the most important functions that can be done to maintain
compliance.
With this one review, the operator can detect
a lot of problems. It is a check and balance system. The other
operators making log entries may not realize that, over the course
of the week, no EAS test was received from one of the two (or
more) monitored sources or that the power readings have slowly
drifted indicating a bigger problem.
The chief operator also can make certain that
complete and detailed entries are being made.
When a chief operator does the review, he needs
to make certain he is looking for FCC required entries. In too
many cases, I have found the operator reviewing logs for operator
sign-on times, or to ensure that commercials run on time, or for
other things that have nothing to do with FCC requirements.
When the chief operator does find an item of
concern, the operator needs to follow up and make certain it is
corrected and properly documented. The chief also should provide
feedback to those making log entries as needed to ensure complete
documentation.
An example of logs that are not properly documented
is often found when a station does not receive an EAS test. On
several occasions I have found log entries made by chief operators
that contain nothing more than "called station" and
the call sign of another station. There are no entries explaining
what happened when the chief operator called the other station.
Did the station not send the EAS test? Was it
sent and you did not receive it? What exactly occurred to cause
your station to miss receipt of an EAS test?
Again, this is where station managers should
get involved and do a periodic review themselves to see if they
can understand not only what was wrong, but what it took to correct
the problem.
Also keep in mind that any other stations that
monitor yours for EAS activations, may be calling to ask if you
sent a test that they did not receive. I would recommend you log
this as well, again as a check and balance system. You may not
know you have a problem sending a test until someone calls.
Of course, I have had some chief operators tell
me how they get frequent calls from the same station to find out
when the test was sent so they can log it after the fact!
Potential problems
From my perspective, the main problem with station
logs is the combining of the FCC-required logging with non-required
items added by the licensee.
Because the FCC does not specify how logs are
to be kept, many licensees try to put all of their logging on
one form to make things easier for their operators.
As a result, I often find logs with routine
transmitter readings, duty operator sign on-off times, daily tower
light checks and programming information taking up 95 percent
of the form, with little or no documentation that is actually
required by the rules.
I am in no way trying to discourage any licensee
from logging these other items. But combining these functions
often creates distractions and difficulties.
Again, with the exception of all EAS activations
being logged, the emphasis is to log any item that caused, or
could cause, the licensee to deviate from maintaining compliance
with the rules and station authorizations. If the licensee’s
emphasis is to have operators fill in a small box with names or
figures or a check mark to routinely log transmitter readings,
shift changes, etc., the typical result is that details of an
actual problem are sketchy or left out altogether.
Here is a scenario that is all too familiar:
The operators get accustomed to writing down a transmitter reading
but fail to observe that one or more readings are out of tolerance
even if the tolerances are printed on the top of the form. It
was just a reading that became too routine.
The next operator on duty takes the same out-of-tolerance
reading, but finding a similar reading already logged thinks nothing
of it, logs it and likewise forgets to compare the reading to
the listed tolerances.
Eventually one operator notices and tries to
log the problem. Unfortunately the form has a space just large
enough for a couple of words to document what the problem is,
not enough space to thoroughly document what occurred.
Because the chief operator or engineer is not
around, the operator on duty puts down what she can and it is
soon forgotten. The chief operator, or engineer, is so busy keeping
multiple stations on the air that the weekly review turns into
a once a month review and that is often to see that shift changes
are on time, not to see that all FCC required items are logged.
If, by chance, a problem is observed and corrected,
the form has no room to describe properly what corrective action
was taken, so nothing is written down. The problem is fixed, so
why worry about it?
The manager, who leaves the overview of the
logs to the chief operator or engineer, never bothers to check
them. The problem may or may not have come to the manager’s
attention, but in any case, the station is on the air.
It is human nature to gloss over problems. It
seems easier to log a thousand readings that are within tolerance
and be reluctant to properly log one that is not. Why advertise
that the problem ever existed?
The answer boils down to effort. What effort
is this licensee putting forth to make certain he or she is watchful
over the station and maintaining compliance? Are station personnel
catching and fixing problems in a timely manner on their own,
or simply keeping a signal on the air? Will the logs be evidence
of the efforts made or indicate a lack of effort?
As an inspector and an engineer, I realize that
equipment does not last forever. Parts wear out and break, lightning
strikes occur, water freezes and expands, utility companies dig
trenches through ground systems and rodents like to chew on things.
So when an inspection of two years of station
logs shows no problems at all, then one of two things has happened:
either the station has been in a vacuum for the past two years
or personnel are not logging properly.
Managers, when was the last time you have seen
the logs for your station?
The views expressed in this article are those
of the author and do not necessarily reflect those of the FCC.
RW welcomes other points of view.
Reach the author at (816) 316-1254 or via
e-mail to rramage@fcc.gov.
The FCC broadcast self-inspection checklists can be found at www.fcc.gov/eb/broadcast/.
