Airworthiness

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Audit Procedures
Airworthiness
Presented by COSCAP SA
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Outline
We will cover

• Introductions
• Course Objective
• Course Administration and Outline

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Objective
ONE

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

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Objective
TWO

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

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Overview of the Audit Process
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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

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Aim

• To give a description of the audit process.

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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.

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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.

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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.
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The 4 basic activities during an audit

• Pre-audit
• Physical audit
• Post audit

• Audit follow-up

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Audit Program
Purpose

• To ensure that a satisfactory level of
• aviation safety is maintained, and
• that the governments Civil Aviations audit
• policies and procedures are applied
• nationally in a uniform manner.

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Audit Types
Initial Certification Audit

• Approximately six months after the issuance of
  an Air Operating Certificate or Approved
  Maintenance Organization Certificate

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Audit Types
Additional Authority Audit

• Prior to granting additional authorities an
  audit may be conducted.

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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.

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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".

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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.

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Classes of Audits

• Large Combined Audit
• Small Combined Audit
• Specialist Audit Airworthiness Operations

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Outputs of an Audit

• Audit Report
• Parallel Report

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The Audit Team
Team Leader A/W
Team Member A/W
Team Member Ops
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Convening Authority

• The person responsible for authorizing and
• overseeing a regulatory audit

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Audit Manager

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

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Team Leaders

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

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Team Members

• Conduct the audit field work
• Document findings
• Generally on every audit

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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.

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STEPS IN THE AUDIT PROCESS
CONVENING AUTHORITY

• Sets the Audit Schedule
• Appoints the Audit Manager

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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)

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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.

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PLANNING
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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

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Initial Audit Procedures Course
OUTLINE

• 1. AN OVERVIEW OF PLANNING
• 2. SCOPE AND DEPTH OF AN AUDIT
• 3. AUDIT PLAN

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Initial Audit Procedures Course
AUDIT PLAN
Purpose

• To ensure that the objectives of the audit are
  met.

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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

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The Mind Map
Initial Audit Procedures Course
Schedule
Team Selection
Scope Depth
Audit of Acme Aero
Objective
Preps
Budget

• Company File Review
• Previous Audit Report
• Company Manuals
• Principal Insp Briefing

• Travel
• Accommodation
• Per Diems
• Land transport
• Budget Contingencies

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Initial Audit Procedures Course
PLANNING
WHY

• Ensures efficiency and economics

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Initial Audit Procedures Course
PLANNING
Purpose/Function

• Identifies functions
• Shows areas where flexibility is possible
• Shows areas where there is no margin for
  error

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Initial Audit Procedures Course
Critical Path Planning
Pre-Audit
Post-Audit
Follow-Up
Audit
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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.

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Initial Audit Procedures Course
SCOPE
Determined by the class or type of audit to be
conducted

• Combined
• Specialist
• Special Purpose

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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/Overhau
l Shops A-6 Aircraft Maintenance Records, etc
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Initial Audit Procedures Course
SCOPE
Functional Areas

• Determined by
• Review OC OPS Specs to determine size of
  auditee
• Review AMOs, Distributors and Manufacturers
• Review Certificates of Approval, A/C
  limitations, Maintenance and/or Quality
  Control Manuals for Airworthiness

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Initial Audit Procedures Course
DEPTH

• The period of time over which a companys
  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.

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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 (AOCs etc.)
• Review Manuals (MCM, Ops, Training, Cabin
  Attendant as applicable)

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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

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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.

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Sampling Rates for 95 Confidence
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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?

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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.

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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?

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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.)

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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

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Initial Audit Procedures Course
Audit Planning
Rule of Thumb

• Small 1 - 5 days
• Medium 5 - 15 days
• Large 15 days

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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.

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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

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Lucky Airlines AMO 58/0100, AOC/40-001
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AIRWORTHINESSShowing Functional areas to be
audited
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Initial Audit Procedures Course
Audit Plan
Purpose

• To ensure audit goals and objectives are
  effectively and efficiently achieved.

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Communication
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Aim

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

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Outline
We will cover

• Lines of communication

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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.

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Audit Team
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Internal Communications
Overview
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Internal Communications Overview
Convening Authority
Audit Manager
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Internal Communication
Audit Manager with

• The Convening Authority
• Team Leaders
• Team Members
• Observers

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External Communications
CAA Members

• Observers
• Team Members
• Team Leaders
• Audit Manager

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External Communications
Audit Manager with

• Auditee
• Airport Manager
• Foreign Affairs
• Media

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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.

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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

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Communications
The Process cont'd

• Audit Manager should complete planning
• Audit Manager should meet with the team

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Pre-Audit
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Initial Audit Procedures Course
Aim

• To describe the activitiesthat take place during
  the pre-audit.

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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

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Initial Audit Procedures Course
Pre-Audit Activities

• Audit planning
• Team assembly
• Pre-audit team meeting
• Final preparations
• including document review

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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

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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

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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 etc.

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Initial Audit Procedures Course
Pre-Audit Review
Inspection Reports

• In-flight inspection reports
• Ramp checks

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Initial Audit Procedures Course
Pre-Audit Review
Previous Audit Reports

• Previous history
• Review findings

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Initial Audit Procedures Course
Pre-Audit Review
All Company manuals

• Maintenance/Operations manuals
• Aircraft flight manual
• Procedures/Training manuals
• Dispatch manual
• MELs

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Initial Audit Procedures Course
Pre-Audit Review
Review Documents

• Flight Permit
• ETOPS
• Fuel policy
• Authorities held (CAT II, RVR600, etc.)
• Exemptions/Concessions
• Approvals/Modifications
• Aircraft Type Approvals
• Manufacturing Limitations, etc.

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Entry Meeting
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Aim

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

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Outline
We will cover

• Communication Rules
• Topics covered at Entry Meeting

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ENTRY MEETING
Factors that shape outlook

• YOU
• 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

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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

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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

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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

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ENTRY MEETING
Setting the stage

• Held on companys 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

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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

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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

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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

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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

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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

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Physical Inspections
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Aim

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

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Outline
We will cover

• Overview
• checklists
• Interviewing
• Documenting evidence
• Audit forms
• Corrective action

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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.

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Steps in Conducting a Physical Inspection
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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

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Audit
Airworthiness

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

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Interviewing People
Why?

• To determine if the system documented in
  the approved manuals is the system in use
• To assess the knowledge of the operators
  personnel. To review their duties and
  responsibilities
• To determine if any other areas need be audited
• To tell people what is going on

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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

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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

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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

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After Interview

• Make extra notes as necessary
• Tell Team Leader if necessary

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Do Not

• Play I have you now
• Intimidate
• Allow yourself to be intimidated
• Allow yourself to be drawn into fight

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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

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Evidence
What is it?

• Anything which supports or shows a
  non-conformance.

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Immediate Threat to Safety

• Inform Team Leader

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Not an Immediate Threat to safety

• What do you do?

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Audit Findings Confirmation requests
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Aim

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

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Outline

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

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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.

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Steps in Conducting a Physical Inspection
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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

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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)

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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

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AUDIT FINDING FORM
Area of Audit
Finding No.
Non-Conformance With
EXAMPLES
Company Corrective Action
Immediate, Short and/or Long Term
Civil Aviation Response
Audit Follow up
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AUDIT FINDING FORM
Area of Audit A1 Maintenance Control Manual
Finding NoA1-1
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 A14 Certification of Components
Finding NoA14-2
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.
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AUDIT FINDING FORM
Area of Audit A21 Test Measuring Equipment
Finding NoA21-1
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 A21 Test Measuring Equipment
Finding NoA21-2
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 ...
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AUDIT FINDING FORM
Area of Audit A21 Test Measuring Equipment
Finding NoA21-3
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.
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AUDIT FINDING FORM
Area of Audit O15 Flt Duty Time Records
Finding NoO15-1
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 O2 OPS SPECIFICATIONS Finding
NoO2-1
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.
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AUDIT FINDING FORM
Area of Audit O16 Flight Inspections
Finding NoO16-1
Non Conformance with SAR705.29 (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.. .
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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.
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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.
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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

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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.

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

• To be able to conduct daily meetings with the
  team and the company.

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Initial Audit Procedures Course
Outline
We will cover

• 1. Daily Team Meetings
• 2. Daily Company Meetings

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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

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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

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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

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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)

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Post Audit(Exit) Meeting
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Aim

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

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Outline
We will cover

• Communication Rules
• Topics covered at an Exit Meeting

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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.
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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

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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 companys obligations regarding
  the corrective action plan
• state how the response system works and
• discuss follow-up action.

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Audit Report
145
Initial Audit Procedures Course
Audit Report
Format

• Part I
• 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

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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

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• 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.

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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.
149

• (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.

150
(EXAMPLE) AIRWORTHINESS Summaries A1 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.
151
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.
152
A2 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. A3 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.
153
(EXAMPLE) A4 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
operators 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.
154
A6 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.
155
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 authoritys 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.
156
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.
157
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.
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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

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Auditee Corrective Action
160
Initial Audit Procedures Course
Corrective Action
TYPES

• Auditee Corrective Action Proposals.
• Before the Team can make a final recommendation
  as a conclusion of the audit the auditees
  proposals for corrective actions must be
  received, reviewed and accepted.
• Depending on the nature of the audit findings,
  the companys corrective action should involve

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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
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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
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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.
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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.
• NoteIt is important to verify as much supporting
  documentation as possible during subsequent
  surveillance.

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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
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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.

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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.
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Initial Audit Procedures Course
Audit Follow-up
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.
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Completingthe Audit
170
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

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Audit Completed