An FCC Inspector Helps You Avoid the Record-Keeping Problems He Has Seen at Other Stations
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.
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!
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 firstname.lastname@example.org. The FCC broadcast self-inspection checklists can be found at www.fcc.gov/eb/broadcast/.
An FCC Inspector Helps You Avoid the Record-Keeping Problems He Has Seen at Other Stations