Appendix XIII to AMC M.A.712(f) — Organisational review    

CAA ORS9 Decision No. 1

The following text provides relevant information for conducting organisational reviews in accordance with M.A.712 for the particular case of a CAMO working on aircraft subject to Part-M.

Organisational reviews may replace a full quality system in accordance with the provisions of M.A.712(f) and AMC M.A.712(f) and as described in the continuing airworthiness management exposition (CAME)

Depending on the complexity of the small organisation (number and type of aircraft, number of different fleets, privilege to perform airworthiness reviews, 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 CAME:

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.706(c) 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 continuing airworthiness management organisation (CAMO) 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 CAME 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.

    — 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.

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.716(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 CAME procedures:

1 – Scope of work

    — All aircraft under contract are covered in the Form 14.

    — The scope of work in the CAME does not disagree with the Form 14.

    — No work has been performed outside the scope of the Form 14 and the CAME.

    — Is it justified to retain in the approved scope of work aircraft types for which the organisation has no longer aircraft under contract?

2 – Airworthiness situation of the fleet

    — Does the continuing airworthiness status (AD, maintenance programme, life limited components, deferred maintenance, ARC validity) show any expired items? If so, are the aircraft grounded?

3 – Aircraft maintenance programme

    — Check that all revisions to the TC/STC holders Instructions for Continuing Airworthiness, since the last review, have been (or are planned to be) incorporated in the maintenance programme, unless otherwise approved by the CAA.

    — Has the maintenance programme been revised to take into account all modifications or repairs impacting the maintenance programme?

    — Have all maintenance programme amendments been approved at the right level (CAA or indirect approval)?

    — Does the status of compliance with the maintenance programme reflect the latest approved maintenance programme?

    — Has the use of maintenance programme deviations and tolerances been properly managed and approved?

4 – Airworthiness Directives (and other mandatory measures issued by the CAA)

    — Have all ADs issued since the last review been incorporated into the AD status?

    — Does the AD status correctly reflect the AD content: applicability, compliance date, periodicity…? (sample check on ADs)

5 – Modifications/repairs

    — Are all modifications/repairs listed in the corresponding status approved in accordance with M.A.304? (sample check on modifications/repairs)

    — Have all the modifications/repairs which have been installed since the last review been incorporated in the corresponding status? (sample check from the aircraft/component logbooks)

6 – Relations with the owners/operators

    — Has a contract (in accordance with Appendix I to Part-M) been signed with each external owner/operator, covering all the aircraft whose airworthiness is managed by the CAMO?

    — Have the owners/operators under contract fulfilled their obligations identified in the contract? As appropriate:

      — Are the pre-flight checks correctly performed? (interview of pilots)

      — Are the technical log or equivalent correctly used (record of flight hours/cycles, defects reported by the pilot, identification of what maintenance is next due etc.)?

      — Did flights occur with overdue maintenance or with defects not properly rectified or deferred? (sample check from the aircraft records)

      — Has maintenance been performed without notifying the CAMO (sample check from the aircraft records, interview of the owner/operator)?

7 – Personnel

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

    — If the number of personnel has decreased or if the activity has increased, check that the organisation still has sufficient staff.

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

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

      — regulations,

      — CAA publications,

      — the CAME and associated procedures,

      — the approved scope of work,

      — maintenance data (significant ADs, SBs, ICA amendments, 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 Form 1 or equivalent.

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

9 – Technical records and record-keeping

    — Have the certificates (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?

10 – Occurrence reporting procedures

    — Check that reporting is properly performed,

    — Actions taken and recorded.

11 – Airworthiness review