AMC 145.A.65(c)(1) Safety and quality policy, maintenance procedures and quality system    

CAA ORS9 Decision No. 1

This will be removed from 1 July 2024

1. The primary objectives of the quality system are to enable the organisation to ensure that it can deliver a safe product and that organisation remains in compliance with the requirements.

2. An essential element of the quality system is the independent audit.

3. The independent audit is an objective process of routine sample checks of all aspects of the organisation’s ability to carry out all maintenance to the required standards and includes some product sampling as this is the end result of the maintenance process. It represents an objective overview of the complete maintenance related activities and is intended to complement the 145.A.50(a) requirement for certifying staff to be satisfied that all required maintenance has been properly carried out before issue of the certificate of release to service. Independent audits should include a percentage of random audits carried out on a sample basis when maintenance is being carried out. This means some audits during the night for those organisations that work at night.

4. Except as specified in sub-paragraphs 7 and 9, the independent audit should ensure that all aspects of Part-145 compliance are checked every 12 months and may be carried out as a complete single exercise or subdivided over the 12 month period in accordance with a scheduled plan. The independent audit does not require each procedure to be checked against each product line when it can be shown that the particular procedure is common to more than one product line and the procedure has been checked every 12 months without resultant findings. Where findings have been identified, the particular procedure should be rechecked against other product lines until the findings have been rectified after which the independent audit procedure may revert back to 12 monthly for the particular procedure.

5. Except as specified otherwise in subparagraphs 7, the independent audit should sample check one product on each product line every 12 months as a demonstration of the effectiveness of maintenance procedures compliance. It is recommended that procedures and product audits be combined by selecting a specific product example, such as an aircraft or engine or instrument and sample checking all the procedures and requirements associated with the specific product example to ensure that the end result should be an airworthy product.

For the purpose of the independent audit, a product line includes any product under an Appendix II approval class rating as specified in the approval schedule issued to the particular organisation.

It therefore follows for example that a maintenance organisation approved under Part-145 with a capability to maintain aircraft, repair engines, brakes and autopilots would need to carry out four complete audit sample checks each year except as specified otherwise in subparagraphs 5, 7 or 9.

6. The sample check of a product means to witness any relevant testing and visually inspect the product and associated documentation. The sample check should not involve repeat disassembly or testing unless the sample check identifies findings requiring such action.

7. Except as specified otherwise in sub-paragraph 9, where the smallest organisation, that is an organisation with a maximum of 10 personnel actively engaged in maintenance, chooses to contract the independent audit element of the quality system in accordance with 145.A.65(c)(1) it is conditional on the audit being carried out twice in every 12 month period.

8. Except as specified otherwise in sub-paragraph 9, where the organisation has line stations listed as per 145.A.75(d) the quality system should describe how these are integrated into the system and include a plan to audit each listed line station at a frequency consistent with the extent of flight activity at the particular line station. Except as specified otherwise in sub-paragraph 9 the maximum period between audits of a particular line station should not exceed 24 months.

9. Except as specified otherwise in sub-paragraph 5, the CAA may agree to increase any of the audit time periods specified in this AMC 145.A.65(c)(1) by up to 100% provided that there are no safety related findings and subject to being satisfied that the organisation has a good record of rectifying findings in a timely manner.

10. A report should be raised each time an audit is carried out describing what was checked and the resulting findings against applicable requirements, procedures and products.

11. The independence of the audit should be established by always ensuring that audits are carried out by personnel not responsible for the function, procedure or products being checked. It therefore follows that a large maintenance organisation approved under Part-145, being an organisation with more than about 500 maintenance staff should have a dedicated quality audit group whose sole function is to conduct audits, raise finding reports and follow up to check that findings are being rectified. For the medium sized maintenance organisation approved under Part-145, being an organisation with less than about 500 maintenance staff, it is acceptable to use competent personnel from one section/department not responsible for the production function, procedure or product to audit the section/department that is responsible subject to the overall planning and implementation being under the control of the quality manager. Organisations with a maximum of 10 maintenance staff actively engaged in carrying out maintenance may contract the independent audit element of the quality system to another organisation or a qualified and competent person approved by the CAA.