Audit Procedures Airworthiness Presented by COSCAP SA Outline

Audit Procedures Airworthiness Presented by COSCAP SA

Outline We will cover : • Introductions • Course Objective • Course Administration and Outline 4

Objective ONE • To provide Inspectors with the basic skills and knowledge required to participate as a Team Member in any audit. 5

Objective TWO • To be able to write an audit finding accurately, and in accordance with the applicable Civil Aviation standard and the course material. 6

Overview of the Audit Process

Inspectors Handbooks Note: The procedures outlined in this presentation are detailed in Chapter 17 of the Airworthiness Inspectors handbook: 1 Audit Procedures 2 Policy and Procedures 3 Check Lists 4

Aim • To give a description of the audit process. 2

Outline We will cover: • An overview of Audits • Definition of an Audit • Reasons for Conducting an Audit (Types) • Classes of Audits • Team Composition and Roles of Members • Frequency • Steps in the audit process. 3

What is an audit? An audit is an in-depth review of the activities of an organization to verify conformance to applicable Civil Aviation regulations and standards. 5

Auditing The auditing process places the relationship between the regulated organisation and its regulator into the proper context. It reinforces that essential requirement that the responsibility for safety rests with the regulated organisation. If the organisation has effective systematic arrangements for managing safety, it will have little difficulty in responding immediately and thoroughly to an audit. The organisation will be more open about incidents and its failures because its safety management procedures will enforce visibility and due process. It will also want to explain what went wrong and how the matter was dealt with to reassure the regulator. 5

The 4 basic activities during an audit: • Pre-audit • Physical audit • Post audit • Audit follow-up 6

Audit Program Purpose: To ensure that a satisfactory level of aviation safety is maintained, and that the governments Civil Aviation’s audit policies and procedures are applied nationally in a uniform manner. 7

Audit Types: Initial Certification Audit Approximately six months after the issuance of an Air Operating Certificate or Approved Maintenance Organization Certificate 8

Audit Types: Additional Authority Audit • Prior to granting additional authorities an audit may be conducted. 9

Audit Types: Routine Conformance Audit Every holder of an Air Operating Certificate, Approved Maintenance Organization Certificate, or any other type of aviation organization certificate, should be audited on a periodic cycle ranging from six to 60 months. 10

Audit Types: Special Purpose Audits Called due to special circumstances, i. e. . an accident, safety concerns etc. These audits are sometimes referred to as "No notice Audits". 11

Initial Audit Procedures Course Audit Classes • Combined Operations and Airworthiness conduct audits of their specialties simultaneously under the direction of one Audit Manager. • Specialist Airworthiness and Operations audit their specialties separately. 12

Classes of Audits • Large Combined Audit • Small Combined Audit • Specialist Audit • Airworthiness • Operations 13

Outputs of an Audit • Audit Report • Parallel Report 14

The Audit Team Convening Authority Audit Manager Team Leader Ops Team Leader A/W Team Member Ops Team Member A/W Others* 15

Convening Authority The person responsible for authorizing and overseeing a regulatory audit 16

Audit Manager • Plans, organizes, directs, and controls the audit process. • Required on every audit. 17

Team Leaders • Support and assist the Audit Manager. • Not necessarily required on every audit. 18

Team Members • Conduct the audit field work • Document findings • Generally on every audit 19

Observers • Accompany the audit team during the audit. • Do not participate in the physical inspection unless specifically directed to do so. • Not necessarily on every audit. 20

STEPS IN THE AUDIT PROCESS CONVENING AUTHORITY • Sets the Audit Schedule • Appoints the Audit Manager 21

STEPS IN THE AUDIT PROCESS AUDIT MANAGER • Selects the team • Communicates internally and externally • Prepares the audit plan • Establishes contact with the Auditee • Sets the audit date(s) 22

STEPS IN THE AUDIT PROCESS AUDIT MANAGER (con't) • Initiates the Audit Plan • Reviews outputs from the audit • Formulates the Audit Report and Parallel Findings • Presents report(s) to the Convening Authority • Ensures that the Audit Report is forwarded to the Auditee. 23

PLANNING

Initial Audit Procedures Course AIM • To describe the various parts involved in the planning of an audit in accordance with the applicable Civil Aviation standards 2

Initial Audit Procedures Course OUTLINE 1. 2. 3. AN OVERVIEW OF PLANNING SCOPE AND DEPTH OF AN AUDIT PLAN 3

Initial Audit Procedures Course AUDIT PLAN Purpose • To ensure that the objectives of the audit are met. 4

Initial Audit Procedures Course AUDIT PLAN • MAIN USERS - Plan Audit Manager and Team will work from • Logistical details • SECONDARY USERS - To Convening Authority for Approval • Who, When, How Long and Costs – To Auditee • When, Areas to be audited and Special Requests 5

The Mind Map Initial Audit Procedures Course Schedule Team Selection Scope & Depth Audit of Acme Aero Objective Budget • Travel • Accommodation • Per Diems • Land transport • Budget Contingencies Preps • Company File Review • Previous Audit Report • Company Manuals • Principal Insp Briefing

Initial Audit Procedures Course PLANNING WHY • Ensures efficiency and economics 8

Initial Audit Procedures Course PLANNING Purpose/Function • Identifies functions - Shows areas where flexibility is possible - Shows areas where there is no margin for error 9

Initial Audit Procedures Course Critical Path Planning Entry Meeting Company De-brief Scope & Depth Team Selection Physical Insp. Audit Report Budget Functional Areas Wrap-up Activities Team Meeting Findings Daily Meetings Preps Documents Pre-Audit Start Audit Post-Audit Follow-Up Finish

Initial Audit Procedures Course SCOPE What is it? ‘SCOPE’ is defined as the number of functional areas within a company's operation that will be audited. 11

Initial Audit Procedures Course SCOPE Determined by the class or type of audit to be conducted • Combined • Specialist • Special Purpose 12

Initial Audit Procedures Course SCOPE Functional Areas Defined as 28 discrete areas or departments within an organization e. g. : Code Topic A-1 Maintenance Control Manual A-2 Technical Publications A-3 Company Quality Audits A-4 Engineering A-5 Support/Overhaul Shops A-6 Aircraft Maintenance Records, etc 13

Initial Audit Procedures Course SCOPE Functional Areas • Determined by - Review OC & OPS Specs to determine size of auditee - Review AMO’s, Distributors and Manufacturers - Review Certificates of Approval, A/C limitations, Maintenance and/or Quality Control Manuals for Airworthiness 13

Initial Audit Procedures Course DEPTH • The period of time over which a company’s operations will be audited, normally from the last audit until present day. • It could also be thought of as the extent or the size of the audit. 16

Initial Audit Procedures Course Planning Factors Company • Discuss company history with appropriate CAA Inspectors • Obtain and review previous audit report and follow-up action. • Review company files (Looking for exemptions and special authorities) • Obtain and review certificates of approval and limitations (AOC’s etc. ) • Review Manuals (MCM, Ops, Training, Cabin Attendant as applicable) 17

Initial Audit Procedures Course Planning Factors Company • Review accident reports • Review company changes (personnel, aircraft, facilities, equipment, management, etc. ) • Bases • Size of company for sampling rationale 18

Initial Audit Procedures Course SAMPLING RATIONALE MRA set out a table for sampling to 95% confidence level • Confidence level of 95% is identified in the MRA. • In practical terms it may not be realistic to review all aircraft in the fleet. Significant findings against one type of aircraft may require additional review against other types. You must be realistic when conducting the review and look at each audit situation independently. S C I E N C E 19

Sampling Rates for 95% Confidence

Initial Audit Procedures Course Planning Factors Bases • When was the last audit? • Review the company and compliance history. • What was found at the bases during the last audit? • Was there a follow-up? How did it go? 20

Initial Audit Procedures Course Planning Factors Bases • How accessible are the bases and is it worthwhile to visit? • Can we find the information elsewhere? • What manpower is required? • Determine risk management. 21

Initial Audit Procedures Course Planning Factors Manpower • Team Members. Are the right people available? • Will Subject Matter Experts be required? • Will all Specialties be covered? • Do I need Support Staff? • How can I get the best utilization of team members? 22

Initial Audit Procedures Course Planning Factors Duration • Size of Company • Record of Company • Capabilities/diversification of A/C, etc. • Scope and function of work carried out • Distance, location and company scope of work • Unforeseen circumstances (weather, travel etc. ) 23

Initial Audit Procedures Course Planning Factors Duration • Significant areas of concern will increase sampling & duration. • Availability of team members • Loss of a team member (illness, accident etc) • Experience level of auditors 24

Initial Audit Procedures Course Audit Planning Rule of Thumb • Small 1 - 5 days • Medium 5 - 15 days • Large 15 + days 25

Initial Audit Procedures Course Funding Consider: • Class of Audit • The number of people on the team • The scope of the audit • Accommodation, meals, etc. • Foreign travel, Air and ground transportation, • Equipment/conference room, rentals. 26

Initial Audit Procedures Course Staffing Considerations • Make an Organization Chart • Select Team Leaders • Select Subject Matter Experts • Select Advisors (if required) • Determine support personnel requirements 28

Lucky Airlines AMO 58/0100, AOC/40 -001

AIRWORTHINESS Showing Functional areas to be audited

Initial Audit Procedures Course Audit Plan Purpose • To ensure audit goals and objectives are effectively and efficiently achieved. 29

Communication

Aim • To describe the lines of communication which must be established in order to conduct an effective audit. 2

Outline We will cover: • Lines of communication 3

Lines of Communication Purpose • To ensure the audit plan is followed; • To ensure all team members understand with whom they will communicate; • To ensure unforeseen problems are dealt with in a timely manner. 4

Convening Authority Audit Team Leader A/W Team Members Company DFO C/P Chief Cabin Attendant CCP Pilots Team Leader Ops *Others Team Members President Director of Maint. CASO Dispatch Audit Manager Main Base AME Apprentice Sub-Base AME Apprentice Quality Assurance Manager Sub-Base AME Apprentice Store Keeper Technical Records Clerk 5

Internal Communications Overview 6

Internal Communications Overview Convening Authority Audit Manager Team Leader(A) Team Leader(O) Team Member(s) Observer(s) 7

Internal Communication Audit Manager with: • The Convening Authority • Team Leaders • Team Members • Observers 8

External Communications CAA Members: • Observers • Team Members • Team Leaders • Audit Manager 11

External Communications Audit Manager with: • Auditee • Airport Manager • Foreign Affairs • Media 12

External Communications Contact with Company • Typically by phone, then in writing; • Establish a good relationship; • Use a non threatening manner; • Gain acceptance of your audit plan; • Ask for a contact/liaison person; • Set meeting dates and times; • Request facilities for the audit team. 13

Initial Audit Procedures Course Communications The Process • AM should begin planning • AM should establish internal contacts as applicable ie. Inspectors etc. • AM should establish external contacts if necessary • AM should establish the audit team (team leader. assist. ) • AM should contact auditee by phone and in writing 15

Communications The Process cont'd • Audit Manager should complete planning • Audit Manager should meet with the team 16

Pre-Audit

Initial Audit Procedures Course Aim To describe the activities that take place during the pre-audit. 2

Initial Audit Procedures Course Outline • Review of Pre-Audit activities • Topics to be covered during the Pre-audit meeting • Material to be reviewed during the pre-audit activities 3

Initial Audit Procedures Course Pre-Audit Activities • Audit planning • Team assembly • Pre-audit team meeting • Final preparations including document review 4

Initial Audit Procedures Course Pre-Audit Team Meeting Topics to be covered • Materials presented to members • Duties and Responsibilities • Specific audit area • Checklists • Observer position • Team plan 5

Initial Audit Procedures Course Pre-Audit Team Meeting Other considerations • Conflict of Interest • Confidentiality • Access to Information • Schedules and Arrangements • Forms Administration • Parallel Report • Budget 6

Initial Audit Procedures Course Pre-Audit Review Files held by the Authority • Company Files • Aircraft Files by Registration number • Concession File • Aircraft Type File • Company Approvals File etc. 7

Initial Audit Procedures Course Pre-Audit Review Inspection Reports • In-flight inspection reports • Ramp checks 8

Initial Audit Procedures Course Pre-Audit Review Previous Audit Reports • Previous history • Review findings 9

Initial Audit Procedures Course Pre-Audit Review All Company manuals • Maintenance/Operations manuals • Aircraft flight manual • Procedures/Training manuals • Dispatch manual • MELs 10

Initial Audit Procedures Course Pre-Audit Review Documents • Flight Permit • ETOPS • Fuel policy • Authorities held (CAT II, RVR 600, etc. ) • Exemptions/Concessions • Approvals/Modifications • Aircraft Type Approvals • Manufacturing Limitations, etc. 11

Entry Meeting

Aim • To describe the activities involved in the entry meeting with the company and to better appreciate the climate it may be given in. 2

Outline We will cover: • Communication Rules • Topics covered at Entry Meeting 3

ENTRY MEETING • YOU Factors that shape outlook - Your task is to provide a service - Your Authority is often not well understood by industry • THE OPERATOR - Often very clever at conducting commercial ventures - Some view regulations and standards as barriers to expansion and have little time for those tasked with monitoring and enforcing them 4

ENTRY MEETING Factors (Con't) • OPERATOR'S PERSONNEL -View themselves as very good in their job -They do not want to look bad • OWNERS -Have a lot invested in terms of time and money -Audit may make findings that will be costly to fix -Many do not like being under government observation 5

ENTRY MEETING Factors (Con't) • GOVERNMENT -Has a lot of say in the company's affairs -Operator may view your presence as interference -Time spent during an audit is non-profitable • CREDIBILITY -Your reputation may have preceded you -Don't play games 6

ENTRY MEETING Strategy • Imagine yourself in Operator's shoes • Plan and prepare for the audit as much as possible • Identify issues that could prove difficult and develop a plan to deal with them should they arise 7

ENTRY MEETING Setting the stage • Held on company’s premises • Dress neatly • Be on time • Be open and friendly prior to and during the meeting • Ensure your team is properly briefed • Ensure operator is properly represented 8

Initial Audit Procedures Course ENTRY MEETING Setting the stage cont'd • Ask Operator to hold questions till the end of your address • One person speaks at a time • Speak clearly and be brief • Try to convey your message in a non-adversarial way • Do not compare one operator to another • Maintain control of the meeting 9

ENTRY MEETING Topics to be covered • Thank You's • Explain the purpose of the meeting • Introduction of Audit Team and Company Representatives • Discuss audit objective • Discuss scope and depth 10

ENTRY MEETING Topics to be covered cont'd • Discuss communications between the Audit Team and the company, including Daily Meetings • Discuss way audit is conducted • Discuss the means of handling non-conformances including immediate threat to safety. • Introduce forms that the operator may see over the course of the audit 11

ENTRY MEETING Topics to be covered cont'd • Arrange tour of facilities • Discuss Exit Meeting date and time • Discuss efforts that will be made to make sure disruption to the operator is very small 12

ENTRY MEETING Topics to be covered (Con't) • Confirm -Working Space -Photocopier, telephones, facsimile machine, etc. -Measuring or test equipment -Admission to facilities and files • ask questions • Conclude the meeting in a friendly way 13

Physical Inspections

Aim • To describe the activities and procedures that are carried out during physical inspections. 2

Outline We will cover: • Overview • checklists • Interviewing • Documenting evidence • Audit forms • Corrective action 3

What is Auditing? • Examining the operator's system, in your assigned area, to determine if it meets the applicable Civil Aviation regulations and company procedures as published in the CAA approved Maintenance Procedures Manual. 5

Steps in Conducting a Physical Inspection Review CAA standards Obtain checklists Review and “test” Does it meet the standards Does not OK Write Notes Proceed with next inspection Write down audit finding(s) 6

Initial Audit Procedures Course Checklists • Use as directed • Ensure that no area is overlooked • Write down information • Check company against applicable Civil Aviation regulation requirements 7

Audit Airworthiness • Maintenance Control/Policy Manual • Civil Aviation Regulation • Aviation Act • MPD/MRB • Approved maintenance programs 9

Interviewing People Why? • To determine if the system documented in the approved manuals is the system in use • To assess the knowledge of the operator’s personnel. To review their duties and responsibilities • To determine if any other areas need be audited • To tell people what is going on 10

Basics of Interviewing • Ensure no other Inspector has talked to the person about the same thing. • Where necessary, determine which Team Member will talk to whom • Be organized • Be polite • Do not interrupt auditee. If necessary make an appointment 11

Basics of Interviewing Continued • Do not threatening • Explain to Person what you are doing and why • Check whether it is ok to take notes • Ask questions carefully • Listen carefully to the response 12

Basic Do's of Interviewing Continued • Ask questions another way if necessary • Ensure you understand the answers • Ask extra questions as necessary • Try to discuss • Remain on track • End the interview in a friendly manner 13

After Interview • Make extra notes as necessary • Tell Team Leader if necessary 14

Do Not • Play ‘I have you now’ • Intimidate • Allow yourself to be intimidated • Allow yourself to be drawn into fight 15

What if? • The person refuses to speak to you • The person wants to say tell you a secret • The person wants to fight • The person wants to make a speech 16

Evidence What is it? • Anything which supports or shows a non-conformance. 17

Immediate Threat to Safety • Inform Team Leader 18

Not an Immediate Threat to safety • What do you do? 19

Audit Findings & Confirmation requests

Aim • To describe how to complete the Audit Finding and Confirmation request forms. 2

Outline • Overview • Writing Audit Findings correctly • Practice exercises • Test on writing an Audit Finding • The Confirmation request Form 3

Initial Audit Procedures Course Audit Finding Definition • "audit finding" means the determination of non-conformance of a product, process, practice or procedure or a characteristic thereof to a specified regulation or standard. This will be documented in the Audit Finding Form. 4

Steps in Conducting a Physical Inspection Review standards Obtain checklists Review and “test” Does it meet standard Does not Does Prepare the paper work Proceed with next task Write the audit finding(s) 5

Writing Audit Findings Problems • The Regulatory requirement has been written incorrectly • The standard and the example(s) do not match • The example(s) would support more than one Audit Finding 6

Quoting the CASR Standard Exactly • Write the regulatory requirement in terms of chapter, section, paragraph etc. • Then incorporate the phrase "Which states" • Then write enough of the regulation to clearly illustrate the meaning of it. • Tie one part to another by using …. . … (dots) 7

Writing Examples • Ensure that the example matches the Regulatory requirement • Include a lead-in statement such as "The following are examples of. . . " where possible • Write a statement of how the situation was (past tense) • Make reference to supporting evidence 9

Area of Audit: Non-Conformance With: AUDIT FINDING FORM Finding No. EXAMPLES Company Corrective Action Immediate, Short and/or Long Term Civil Aviation Response Audit Follow up

AUDIT FINDING FORM Area of Audit: A 1 Maintenance Control Manual Finding No: A 1 -1 Non Conformance with: SAR 121. 137 (a) (1) which states in part - Each certificate holder shall furnish copies of the manual ………. . to - its appropriate…. . . maintenance personnel. Area of Audit: A 14 Certification of Components Finding No: A 14 -2 Non Conformance with: SAR 145. 39 (d) which states in part - Each person who is directly in charge of the maintenance functions……. . . must ………. have had at least 18 months of practical experience………. in the work for which the certificate holder is authorised.

AUDIT FINDING FORM Area of Audit: A 21 Test & Measuring Equipment Finding No: A 21 -1 Non Conformance with: SAR 145. 47(a) which states - A certificate holder must have equipment and materials necessary to efficiently perform the functions listed on their certificate Area of Audit: A 21 Test & Measuring Equipment Finding No: A 21 -2 Non Conformance with: SAR 145. 47(b) which states in part - The organization shall ensure that all inspection tools and test equipment are tested at regular intervals to ensure correct calibration …………. . .

AUDIT FINDING FORM Area of Audit: A 21 Test & Measuring Equipment Finding No: A 21 -3 Non Conformance with: SAR 145. 47(b) which states in part - The organization shall ensure that all test equipment are tested ………. to ensure correct calibration to a standard derived from the National Standards or to a standard provided by the equipment manufacturer.

AUDIT FINDING FORM Area of Audit: O 15 Flt & Duty Time Records Finding No: O 15 -1 Non Conformance with: SAR 700. 14 (1) which states in part - ‘Every air operator shall establish a system that monitors the flight time, flight duty time and rest periods of each of its flight crew members…. . . Area of Audit: O 2 OPS SPECIFICATIONS Finding No: O 2 -1 Non Conformance with: SAR 705. 26 (1) Which states in part - Subject to subsection (2), no air operator shall operate a twin‑ engined aeroplane on a route containing a point that is farther from an adequate aerodrome than the distance that can be flown in 60 minutes at the one‑engine‑inoperative cruise speed.

AUDIT FINDING FORM Area of Audit: O 16 Flight Inspections Finding No: O 16 -1 Non Conformance with: SAR 705. 29 (1) which states in part ……. flight crew members who are on flight deck duty shall remain at their duty stations with their safety belts fastened. . .

Confirmation Request Form Purpose To Reduce Inspector workload during the Initiation and audit phases by requiring the Auditee to prove compliance when non conformance is indicated. The CRF reduces time consuming document searching, and places the onus on the company to prove conformance. 6

Confirmation Request Form Advantages The auditee is afforded the opportunity to prevent aircraft ‘grounding’, and it also ensures that the auditor is possession of all the facts before proceeding with further action. In addition the auditor receives a signed document from the auditee to use as part of the supportive evidence package. 6

Confirmation Request Form Advantages (cont. ) • where initial evidence indicates a non conformance, the burden is on the company to show otherwise; · the auditor makes the final determination based on auditee produced facts as to which direction to proceed; 6

Confirmation Request Form Advantages (Cont. ) • elimination of arbitrary findings based on subjective examples; · the auditee is not faced with major surprises at the end of the audit because all contentious issues have been dealt with in an open manner; and · the auditor has more time to devote to the business of auditing rather than chasing a paper trail. 6

Confirmation Request Form CRF Number Auditors name Company rep. Area of audit Subject matter Company response required by: Company response

Daily Meetings

Initial Audit Procedures Course Aim • To be able to conduct daily meetings with the team and the company. 2

Initial Audit Procedures Course Outline We will cover: 1. Daily Team Meetings 2. Daily Company Meetings 3

Initial Audit Procedures Course Daily Team Meeting So Team Leader can: • Exchange, discuss and validate the day's findings and Confirmation Requests • Reach agreement on certain items • Be informed and measure the progress of the audit • Plan the strategies and take decisions necessary in terms of directing and re-directing personnel 4

Initial Audit Procedures Course Daily Team Meeting So Team Leader can: • Be provided the information that will form the content of the comments he will make during the daily meeting with the operator • Be provided the information to report the progress of the audit to the AM as necessary 5

Initial Audit Procedures Course Daily Team Meetings Team Members should brief TL on • The area(s) they are examining • A brief summary of what they are finding • Identify any difficulties they are having • Offer possible solutions 6

Initial Audit Procedures Course Daily Team Meetings TMs should brief TL on cont'd • A date/time for completion of any phase of their assignments, (e. g. The technical library review will be completed by this afternoon) 7

Post Audit (Exit) Meeting

Aim • To describe the activities involved in the exit meeting with the company and to better appreciate the climate it may be given in. 2

Outline We will cover: • Communication Rules • Topics covered at an Exit Meeting 3

Initial Audit Procedures Course Exit Meeting General This meeting must not come up with any surprises to the auditee, it will be a summary of the briefing sessions held throughout the course of the audit. If this meeting is a shock to the management it is evidence of procedures not being followed during the course of the audit. 7

Initial Audit Procedures Course Exit Meeting Content The speakers must present their findings in a clear and concise manner. The meeting should: · be chaired by the audit Manager; · be cordial, diplomatic, clear, and polite; ·take into account the personalities and background of the company representatives; · thank the auditee for their co-operation; · summarise audit findings; 7

Initial Audit Procedures Course Exit Meeting Contents (Cont. ) · state the areas of strength as well as the areas that are deficient; · outline the progression of the report following the meeting; · explain the company’s obligations regarding the corrective action plan; · state how the response system works; and · discuss follow-up action. 7

Audit Report

Initial Audit Procedures Course Audit Report • Part I Format -Overview of the Auditee -Names and Positions of Management -Date Audit Completed and Auditee's Name and Address -Purpose and Scope of the Audit -Criteria Used -Audit Team Composition 5

Initial Audit Procedures Course Audit Report (Con't) • Part II -Executive Summary (which includes a statement of Overall Conformance) • Parts III and IV -Functional Summaries (A/W and OPs) • Appendices -OPs and A/W Audit Findings 6

FLYRIGHT AUDIT EXECUTIVE SUMMARY (EXAMPLE) Airworthiness The Airworthiness section of this report indicates that, with the exception of ‘Test & Measuring Equipment’, all audited areas revealed non conformance findings demonstrating: ·Failure to fully comply with all applicable regulatory requirements. ·Ineffective management control of the ‘Maintenance Organisation’. ·Ineffective system control through the company maintenance control manuals. ·A lack of effective quality control to ensure satisfactory standards.

As a result, aircraft were operated with: a) inspections and components that had overrun maintenance specification requirements, b) non-approved parts installed, c) defect control and release certifications that did not meet regulatory requirements. Flyright has therefore operated aircraft in commercial service with Certificates of Airworthiness not in force.

(EXAMPLE) Operations The Operations section of this report indicates that audited areas revealed non-conformance findings demonstrating: ·Failure to fully comply with all applicable regulatory requirements. ·Ineffective management control of ‘Training/Check Programs’ to ensure satisfactory safety and regulatory standards. ·Failure to ensure that the company operations manuals provided effective system control. ·Failure to maintain adequate control of records.

(EXAMPLE) AIRWORTHINESS Summaries A 1 Maintenance Control Manuals The hierarchy of the maintenance control manuals approved under the Air Carrier Operating Certificate (AOC) and Approved Maintenance Organization (AMO), requires restructuring. The Certificate Holder utilizes the Aircraft Maintenance Specifications document as the CAA approved, controlling manual. Sub tier manuals include the Technical Procedures Manual, Technical Quality Manual, Quality Assurance Regulations, Reliability Control Program Manual and the Weight and Balance Manual. In practical application the Technical Procedures Manual is the controlling manual, however, this manual has not been approved by CAA.

The Inspection Procedures Manual, utilized by the Approved Maintenance Organization, as with the AOC Technical Procedures Manual, Reliability Control Program Manual, Technical Quality Manual, Quality Assurance Regulations and Weight and Balance Manual, do not meet regulatory requirements. Numerous ‘controlling’ manuals were found in the system that were not reflected in the IPM or TPM, e. g. Maintenance and Engineering Technical Form Manual, Quality Assurance Regulations, and the Technical Quality Manual.

A 2 Technical Publications Numerous Manuals in the Main Technical Library are not being maintained to a current status. A review of the document control, for the user departments revealed a serious lack of control. Numerous technical forms were found to be uncontrolled and in one case three different forms had been assigned the same control number. A 3 Company Quality Audits Quality audits were not being consistently carried out of a number of areas, e. g. sub-contractors, out stations, and Engineering Quality Assurance. Staff were unable to provide details of the procedural control of the audit process. A review of the yearly audit plan for 1997/98 indicated that the schedule was not being met. It was noted that the Quality Audit department, encountered difficulty in getting responses to their audit findings.

(EXAMPLE) A 4 Engineering Numerous examples of components manufactured by outside agencies to non-approved data were found. Some of these parts may have been installed on Flyright, and other operator’s aircraft. Examples of non-approved engineering modification drawings and non-approved aircraft modification approvals were found. The Technical Procedures Manual lacked procedures for the approval process of repair data by CAA. Numerous forms were being used in the field; however, these forms were not referenced in the Technical Forms Manual.

A 6 Aircraft Maintenance Records Numerous examples of inadequate defect rectification data have been documented. Release certifications by unqualified persons, missing certifications, missing required inspection items (RII, s), lack of reference to standards, missing component information, missing ATA references and missing employee information was evident.

OPERATIONS (EXAMPLES) O-13 Minimum Equipment List (MEL) All of the MELs have been approved by CAA. Not all MELs reflect the latest revision of the manufacturing authority’s approved MMEL. Evidence was seen of an item exceeding the MEL time category. Evidence was seen of an aircraft operating outside of the MEL performance limitations. One aircraft did not have an approved MEL on board.

O-14 Dangerous Goods Operations did not have a copy of the IATA Dangerous Goods Manual and one could not be produced when requested. Notices to travellers, required by carry-on baggage dangerous goods regulations, were not in evidence at ticket counters, security clearance areas or holding rooms. O-15 Flight and Duty Time Limitations Flight Crew flight and duty time limitations and rest requirements were not in accordance with regulation 121. Flight Attendant duty period limitations and rest requirements were not in accordance with regulation 121 requirements. Flight Operations Officers duty time limitations were found not to exist. Evidence existed of pilots exceeding regulatory flight time limitations.

O-16 Flight and Ground Inspection Numerous cases were found of AFMs on board aircraft not reflecting CAA approval. Numerous cases were found of AOMs on board aircraft not reflecting CAA approval. Several instances were noted of aircraft not having the current approach plate. Several instances were noted of Flight Attendants not having the appropriate manuals in their possession.

Initial Audit Procedures Course Summaries Be Professional • Ensure the Functional Summaries are supported with Audit Findings • Use the same format throughout • Write the Summaries in the third person • Follow the same order as the Audit Findings • You may consider identifying any repeat non-conformances 7

Auditee Corrective Action

Initial Audit Procedures Course Corrective Action TYPES • Auditee Corrective Action Proposals. – Before the Team can make a final recommendation as a conclusion of the auditee’s proposals for corrective actions must be received, reviewed and accepted. – Depending on the nature of the audit findings, the company’s corrective action should involve: 7

Initial Audit Procedures Course Corrective Action Immediate Corrective Action This is action taken immediately upon identification of the audit finding to remove the immediate threat to aviation safety; 7

Initial Audit Procedures Course Corrective Action Short-term Corrective Action This action should correct a non‑conformance that does not pose an immediate threat to aviation safety, which ensures that conformance is established quickly until long‑term action is completed to prevent recurrence of the problem. Short‑term corrective action will normally take place within 30 days; and 7

Initial Audit Procedures Course Corrective Action Long term Corrective Action This longer‑term action has two components: 1. Identifying the cause of the problem and indicating the measures the company will take to prevent a recurrence. These measures should focus on a system change. 2. A timetable for company implementation of the long‑term corrective action. Long‑term corrective action will normally take place within twelve months. 7

Initial Audit Procedures Course Corrective Action Supporting Documents Long and short term corrective action should be accompanied by supporting documents for review eg: • logbook entries, • purchase orders, • memoranda or revised inspection procedure cards. Note; It is important to verify as much supporting documentation as possible during subsequent surveillance. 7

Initial Audit Procedures Course Audit Follow-up Purpose When the Team Leaders are satisfied that all corrective action proposals have been received a full team meeting will be convened to formulate and agree the final recommendations. These recommendations will form a supplement to the Audit Report and should include: 7

Initial Audit Procedures Course Audit Follow-up Recommendations • an overall recommendation based on the particular objectives of the audit; ·acceptance or otherwise of the scheduled compliance time for corrective actions; ·frequency of follow-up to the findings; and ·period and extent of future surveillance. 7

Initial Audit Procedures Course Audit Follow-up Recommendations The Audit Manager will present the final recommendations to the Director (for Approval). Subject to approval by the Director the final result of the audit can then be forwarded to the company. 7

Initial Audit Procedures Course Audit Follow-up The Team Leader(s) will control and monitor the follow-up to all corrective actions, using the applicable team member for the corrective action to the Audit Finding that he/she raised. When the necessary follow-up has been completed and is satisfactory the result will be notified to the Director. 7

Completing the Audit

Initial Audit Procedures Course Administration • Submit expenses as applicable, • Ensure follow-up inspection is scheduled • Schedule next audit • Place all information on the audit file • Return any borrowed equipment 4

Audit Completed