Appendix VIII to AMC M.A.616 — Organisational Review    

CAA ORS9 Decision No. 1

This is only applicable to organisations with less than 10 maintenance staff members. For larger organisations, the principles and practices of an independent quality system should be used.

Depending on the complexity of the small organisation (number and type of aircraft, number of different fleets, subcontracting of specialised services, etc.), the organisational review system may vary from a system using the principles and practices of a quality system (except for the requirement of independence) to a simplified system adapted to the low complexity of the organisation and the aircraft managed.

As a core minimum, the organisational review system should have the following features, which should be described in the Maintenance Organisation Manual (MOM):

a. Identification of the person responsible for the organisational review programme.

By default, this person should be the accountable manager, unless he delegates this responsibility to (one of) the M.A.606(b) person(s).

b. Identification and qualification criteria for the person(s) responsible for performing the organisational reviews.

These persons should have a thorough knowledge of the regulations and of the maintenance organisation procedures. They should also have knowledge of audits, acquired through training or through experience (preferably as an auditor, but also possibly because they actively participated in several audits conducted by the CAA).

c. Elaboration of the organisational review programme:

— Checklist(s) covering all items necessary to be satisfied that the organisation delivers a safe product and complies with the regulation. All procedures described in the MOM should be addressed.

— A schedule for the accomplishment of the checklist items. Each item should be checked at least every 12 months. The organisation may choose to conduct one full review annually or to conduct several partial reviews.

d. Performance of organisational reviews

Each checklist item should be answered using an appropriate combination of:

— review of records, documentation, etc;

— sample check of aircraft under contract or being maintained under a work order;

— interview of personnel involved;

— review of discrepancies and difficulty internal reports (e.g. notified difficulties in using current procedures and tools, systematic deviations from procedures, etc.);

— review of complaints filed by customers after delivery.

e. Management of findings and occurrence reports.

— All findings should be recorded and notified to the affected persons.

— All level 1 findings, in the sense of M.A.619(a), should be immediately notified to the CAA and all necessary actions on aircraft in service should be immediately taken.

— All occurrence reports should be reviewed with the aim for continuous improvement of the system by identifying possible corrective and preventive actions. This should be done in order to find prior indicators (e.g., notified difficulties in using current procedures and tools, systematic deviations from procedures, unsafe behaviours, etc.), and dismissed alerts that, had they been recognised and appropriately managed before the event, could have resulted in the undesired event being prevented.

— Corrective and preventive actions should be approved by the person responsible for the organisational review programme and implemented within a specified time frame.

— Once the person responsible for the organisational review programme is satisfied that the corrective action is effective, closure of the finding should be recorded along with a summary of the corrective action.

— The accountable manager should be notified of all significant findings and, on a regular basis, of the global results of the organisational review programme.

 

Following is a typical example of a simplified organisational review checklist, to be adapted as necessary to cover the MOM procedures:

1 – Scope of work

Check that:

— All aircraft and components under maintenance or under contract are covered in CAA Form 3.

— The scope of work in the MOM does not disagree with CAA Form 3.

— No work has been performed outside the scope of CAA Form 3 and the MOM.

2 – Maintenance data

— Check that maintenance data to cover the aircraft in the scope of work of the MOM are present and up-to-date.

— Check that no change has been made to the maintenance data from the TC holder without being notified.

3 – Equipment and Tools

— Check the equipment and tools against the lists in the MOM and check if still appropriate to the TC holder’s instructions.

— Check tools for proper calibration (sample check).

4 – Stores

— Do the stores meet the criteria in the procedures of the MOM?

— Check by sampling some items in the store for presence of proper documentation and any overdue items.

5 – Certification of maintenance and airworthiness review

— Has maintenance on products and components been properly certified?

— Have implementation of modifications/repairs been carried out with appropriate approval of such modifications/repairs (sample check)?

— Have airworthiness reviews been properly performed and the airworthiness review certificate properly been issued?

6 – Relations with the owners/operators

— Has maintenance been carried out with suitable work orders?

— When a contract has been signed with an owner/operator, has the obligations of the contracts been respected on each side?

7 – Personnel

— Check that the current accountable manager and other nominated persons are correctly identified in the approved MOM.

— If the number of personnel has decreased or if the activity has increased, check that the staff are still adequate to ensure a safe product.

— Check that the qualification of all new personnel (or personnel with new functions) has been appropriately assessed.

— Check that the staff have been trained, as necessary, to cover changes in:

— regulations,

— CAA publications,

— the MOM and associated procedures,

— the products in the scope of work,

— maintenance data (significant ADs, SBs, etc.).

8 – Maintenance contracted

— Sample check of maintenance records:

— Existence and adequacy of the work order,

— Data received from the maintenance organisation:

— Valid CRS including any deferred maintenance,

— List of removed and installed equipment and copy of the associated CAA Form 1 or equivalent.

— Obtain a copy of the current approval certificate (CAA Form 3) of the maintenance organisations contracted.

9 – Maintenance subcontracted

Check that subcontractors for specialised services are properly controlled by the organisation.

10 – Technical records and record-keeping

— Have the maintenance actions been properly recorded?

— Have the certificates (CAA Form 1 and Conformity certificates) been properly collected and recorded?

— Perform a sample check of technical records to ensure completeness and storage during the appropriate periods.

— Is storage of computerised data properly ensured?

11 – Occurrence reporting procedures

— Check that reporting is properly performed.

— Actions taken and recorded.