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Storing Program Logs

Folks,

I have an AM that has been storing and keeping paper program logs. They have moved to a system that will allow them to store the logs electronically (no paper). Management has stated that the regs require the station to maintain the paper logs.

I'm sure he's wrong and can dump the paper and keep the logs electronically. I've even looked at the regs and can't locate any requirement to keep PAPER (even though he insists).

Before I tell him to dump the paper, I just want to make sure that I'm not missing anything. Dump the paper, right?

THANKS!
 
I believe that it's legal to scan the logs and keep them electronically as a .gif or, perhaps as a .jpg or some other compressed format (to save disk space).
A couple of words of caution. Do not archive them on CD or DVD. One scratch on the disk can render months of logs unreadable.
Keep them on external hard drives. Keep duplicate copies of the logs on more than one external drive so that a hard drive failure won't leave you "logless" (is that a word?).
 
Back in the '80's, when the FCC began "deregulation", along with removing the requirement for the Third Class Radiotelephone Operator Permit, they also removed almost all logkeeping requirements. One of those requirements eliminated was the Program Log. Also eliminated, unless specifically required in the license, is the Transmitter Log, although that one, if kept, can be used to show compliance in the event of a complaint. The only log mentioned in the Rules is the "Station Log" and the requirements there are tower light extinguishment and restoration (reporting by exception), EAS operation (receiving RWT, receiving and transmitting RMT, and any other activity, DA AM's without approved sampling systems must make entries. Monitor points are now done "as often as necessary" to insure compliance, and if the station is allowed to use computer modeling of the antenna system, almost never. Also, calibration of remote monitoring devices must have entries when such calibration is performed (as often as necessary to insure...). See FCC Rule 73.1820 for the full details. http://louise.hallikainen.org/FCC/FccRules/2009/73/1820/
 
Bill-

Thanks for the info. I looked at the rules and, you're right, there is nothing that states program logs must be retained. It's interesting because I'm looking at SBE's Certification Handbook for Radio Operators and it specifically states that program logs must be retained for two years (page 53, published 2003). There is a newer version of the book, but I don't know what it says...

States: "Every radio station maintains its program logs for two years as required by the FCC."

Thanks!
 
ChiefOperator said:
Folks,

I have an AM that has been storing and keeping paper program logs. They have moved to a system that will allow them to store the logs electronically (no paper). Management has stated that the regs require the station to maintain the paper logs.

I'm sure he's wrong and can dump the paper and keep the logs electronically. I've even looked at the regs and can't locate any requirement to keep PAPER (even though he insists).

Before I tell him to dump the paper, I just want to make sure that I'm not missing anything. Dump the paper, right?

THANKS!


Bill gave a great answer. Program logs are no longer required, HOWEVER... some form of log may be a good idea in the event of a payment dispute with a client. It's good to be able to show the spots ran.

Not that any of our current systems actually do that. The electronic logging systems in place only show that the automation system believes it played the McDonald's spot at 9:21am. It can't tell if the transmitter was off the air at the time, or the pot on the board was down, or the network pot up causing two programs at once, or the studio patched out of the program line, or the STL signal down, or a malfunction in the automation system that showed McDonald's played but it was actually Burger King.

And I suspect that your client would like to manually copy from the electronic record to a paper log in order to "satisfy the FCC", which wouldn't prove a darn thing if you ask me. But managers and traffic directors don't really want to think about those things. They get real uncomfortable whenever I bring it up. :)
 
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