AMC2 145.A.200(a)(6) Management system

CAA ORS9 Decision No. 38

COMPLIANCE MONITORING — INDEPENDENT AUDIT

(a) An essential element of the compliance monitoring function is the independent audit.

(b) The independent audit should be an objective process of routine sample checks of all aspects of the organisation’s ability to carry out all maintenance to the standards required by this Regulation. It should include checking compliance of the organisation procedures with the Regulation, adherence of the organisation to these procedures, and product or maintenance sampling (i.e. product audit), as this is the end result of the maintenance process.

(c) The independent audit should provide an objective overview of the complete set of maintenance-related activities. It should include a percentage of unannounced audits carried out on a sample basis while maintenance is being carried out. This means that some audits should be carried out during the night for those organisations that work at night.

(d) The organisation should establish an audit plan to show when and how often the activities as required by this Regulation will be audited.

(e) Except as specified in points (h) and (j), the audit plan should ensure that all aspects of Part-145 compliance are verified every year, including all the subcontracted activities. The auditing may be carried out as a complete single exercise or subdivided over the annual period. Theindependent audit should not require each procedure to be verified 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 verified every year without resultant findings. Where findings have been identified, compliance with the particular procedure should be verified against other product lines until the findings have been closed, after which the independent audit procedure may revert back to a yearly interval for the particular procedure.

(f) Except as specified otherwise in point (h), the independent audit should sample check one product (such as one aircraft or engine or component) while undergoing maintenance on each product line every year as a demonstration of compliance with the maintenance procedures and requirements associated with that specific product. This should include in particular the verification of:

- the maintenance data and compliance with the organisation procedures, including consideration of human factors issues;

- the facility and maintenance environment;

- the standard of inspection and precautions;

- the completion of work cards/worksheet;

- the tools and material;

- the authorisation of the person carrying out maintenance.

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

It therefore follows, for example, that a Part-145 maintenance organisation approved to maintain aircraft, engines, brakes and autopilots would need to carry out at least four complete product audits each year, except as specified otherwise in points (f), (h) or (j).

(g) The product audit includes witnessing any relevant testing and visually inspecting the product and the associated documentation. The product audit should not involve repeated disassembly or testing unless the product audit identifies findings that require such an action.

(h) Except as specified otherwise in point (j), where the organisation contracts the independent audit element of the compliance monitoring function in accordance with point (l), the audit should be carried out twice every year.

(i) Except as specified otherwise in point (j), where the organisation has line stations listed as per point 145.A.75(d), the compliance monitoring documentation should include a description of how these line stations are integrated into the monitoring 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 and the related safety hazards identified. Except as specified otherwise in point (j), the maximum period between audits of a particular line station should not exceed 2 years.

(j) Except as specified otherwise in point (f), provided that there are no safety-related findings, the audit planning cycle specified in this AMC may be increased by up to 100 %, subject to a risk assessment and/or mitigation actions, and agreement by the competent authority.

(k) A report should be issued each time an audit is carried out describing what was checked and the resulting non-compliance findings against applicable requirement and procedures.

(l) Organisations with a maximum of 10 maintenance staff actively engaged in carrying out maintenance may subcontract the whole independent audit element of the compliance monitoring function to another organisation or contract a qualified and competent person to become responsible for this element, with the agreement of the competent authority.

This does not prevent a larger organisation from occasionally using external support for conducting particular audits.