GM to 147.B.110 Procedure for approval and changes to the approval
CAA ORS9 Decision No. 1
1. A meeting should be arranged between the applicant and the CAA who issue Part- 147 approvals to determine if the applicant's training activities justify the investigation for issue of Part-147 approval and to ensure that the applicant understands what needs to be done for Part-147 approval. This meeting is not intended to establish compliance but rather to see if the activity is a Part-147 activity.
2. Assuming that the applicant's activities come within the scope of Part-147 approval, instructions should be sent to the CAA staff requesting that an audit of the applicant be carried out and when satisfied that compliance has been established, a recommendation for the issue of approval should be submitted to the CAA staff who grant approval unless these are the same staff. The CAA should determine how and by whom the audit shall be conducted. For example, if the applicant is a large training organisation, it will be necessary to determine whether one large team audit or a short series of small team audits or a long series of single person audits is most appropriate for the particular situation. A further consideration in the case of a combined Part-145/147 organisation is the possibility to combine the audits.
3. Where it is intended that the maintenance training organisation may conduct training and examinations away from the maintenance training organisation address(es) in accordance with 147.A.145(c), then a sample audit should be carried out by the CAA from time to time of the process to ensure that procedures are followed. For practical reasons such sample audits will need to be carried out when training is being conducted away from the maintenance training organisation address(es).
4. The auditing surveyor should ensure that they are always accompanied throughout the audit by a senior member of the organisation making application for Part-147 approval. Normally this should be the proposed quality manager. The reason for being accompanied is to ensure that the organisation is fully aware of any findings during the audit. In any case, the proposed quality manager/senior member of the organisation should be debriefed at the end of the audit visit on the findings made during the audit.
5. There will be occasions when the auditing surveyor may find situations in the applicant's organisation on which he/she is unsure about compliance. In this case, the organisation should be informed about possible non-compliance at the time of audit and the fact that the situation will be reviewed before a decision is made. The organisation should be informed of the decision within 2 weeks of the audit visit in writing if the decision is a confirmation of non-compliance. If the decision is a finding of being in compliance, a verbal confirmation to the organisation will suffice.
6. A change of name of the maintenance training organisation requires the organisation to submit a new application as a matter of urgency stating that only the name of the organisation has changed including a copy of the organisation exposition with the new name. Upon receipt of the application and the organisation exposition, the CAA should reissue the approval certificate valid only up to the current expiry date.
7. A name change alone does not require the CAA to audit the organisation, unless there is evidence that other aspects of the maintenance training organisation have changed.
8. A change of accountable manager requires the maintenance training organisation to submit such fact to the CAA as a matter of urgency together with the amendment to the accountable manager exposition statement.
9. A change of any of the senior personnel specified in 147.A.105(b) requires the maintenance training organisation to submit a Form 4 in respect of the particular person. If satisfied that the qualifications and experience meet the standard required by Part-147, the CAA should indicate acceptance in writing to the maintenance training organisation.
10. A change in the maintenance training organisation’s exposition requires the CAA to establish that the procedures specified in the exposition are in compliance with Part-147 and then to establish if these are the same procedures intended for use within the training facility.
11. Any change of location of the maintenance training organisation requires the organisation to make a new application to the CAA together with the submission of an amended exposition. The CAA should follow the procedure specified in 147.B.110(a) and (b) in so far as the change affects such procedure before issuing a new Part- 147 approval certificate.
12. The complete or partial reorganisation of a training organisation should require the re-audit of those elements that have changed.
13. Any additional basic or aircraft type training courses requires the maintenance training organisation to make a new application to the CAA together with the submission of an amended exposition. For basic training extensions, an additional sample of new examination questions relevant to the modules associated with the extension being sought will be required to be submitted. The CAA should follow the procedure of paragraph 11 in so far as the change affects such procedures unless the CAA is satisfied that the maintenance training organisation has a well-controlled procedure to qualify such change when it is not necessary to conduct the audit elements of the paragraph 11 procedure.