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Re: Operation Logs
To: CRTech <crtech@crtech.org>
Subject: Re: Operation Logs
From: Mark Croom <markc@newmail.kinshipradio.org>
Date: Sat, 7 Jul 2018 13:50:35 -0500
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In my role as ABIP inspector in South Dakota, I tell my Chief Operator clients that *if* they can show me that they are truly reviewing and approving the logs weekly, they can keep them in any accessible format they want. The trick is that the logs are still required to have a date and signature when reviewed.

Nobody who was claiming to store records electronically was actually reviewing the logs (this requirement is unchanged over many long decades).

So I always recommend they keep a weekly printed log with their signature and date (as those are required to prove the review occurred), on file and retained for two years.

For reference, the rule segment in question is 73.1870(c)(3):

(3) Review of the station records at least once each week to determine if required entries are being made correctly. Additionally, verification must be made that the station has been operated as required by the rules or the station authorization. Upon completion of the review, the chief operator or his designee must date and sign the log, initiate any corrective action which may be necessary, and advise the station licensee of any condition which is repetitive. 

I think the best way to fulfil this requirement is to use a printed log which you review weekly. For most stations, one page per week is adequate. Most of my South Dakota stations print the weekly log from their EAS box, and attach that to any other log form they use. As long as it's reviewed weekly, the review is DATED, and issues are noted and taken care of I am fine with that. Obviously the are required to be legible so that's important to me as well but I don't try to tell anybody what their log should look like as long as the required information is present, and the review is being done and recorded.

That's my nickels' worth of contribution to your consideration.

On Fri, Jul 6, 2018 at 4:26 PM, Tom Van Gorkom <tomvangorkom@gmail.com> wrote:
I'm wondering what other stations are doing with their operation logs.... more specifically, do you still print, sign, and put them in a paper file in case the FCC wants to inspect them or do you keep them on a computer somewhere handy?

We use Davicom site monitors and I set them up to email me the custom logs every week but I am tired of printing and filing them - seems like a waste and I recall that the FCC doesn't give a lot of specifics as to the format or storage. You thoughts and practices?

Tom Van Gorkom
Follow-Ups: RE: Operation Logs
(Mike Shane <mshane@salemomaha.com>, 7 Jul 2018 20:19:26 -0000)
References: Operation Logs
(Tom Van Gorkom <tomvangorkom@gmail.com>, 6 Jul 2018 21:26:34 -0000)
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