AMC4 145.A.200(a)(6) Management system

CAA ORS9 Decision No. 38

COMPLIANCE MONITORING — FEEDBACK SYSTEM

(a) Another essential element of the compliance monitoring function is the feedback system.

(b) The feedback system should not be contracted to external persons or organisations.

(c) When a non-compliance is found, the compliance monitoring function should ensure that the root cause(s) and contributing factor(s) are identified (see GM1 145.A.95), and that corrective actions are defined. The feedback part of the compliance monitoring function should define who is required to address any non-compliance in each particular case, and the procedure to be followed if the corrective action is not completed within the defined time frame. The principal functions of the feedback system are to ensure that all findings resulting from the independent audits of the organisation are properly investigated and corrected in a timely manner, and to enable the accountable manager to be kept informed of safety issues and the extent of compliance with Part-145.

(d) The independent audit reports referred to in AMC2 145.A.200(a)(6) should be sent to the relevant department(s) for corrective action, giving target closure dates. These target dates should be discussed with the relevant department(s) before the compliance monitoring function confirms the dates in the report. The relevant department(s) is (are) required to implement the corrective action and inform the compliance monitoring function of the status of the implementation of the action.

(e) Unless the review of the results from compliance monitoring is given to the safety review board (ref. AMC1 145.A.200(a)(1) point (b)(4)), the accountable manager should hold regular meetings with staff to check the progress of corrective actions. These meetings may be delegated to the compliance monitoring manager on a day-to-day basis, provided that the accountable manager:

(1) meets the senior staff involved at least twice per year to review the overall performance of the compliance monitoring function; and

(2) receives at least a half-yearly summary report on non-compliance findings.

(f) All records pertaining to the independent audit and the feedback system should be retained for three years, or for such periods as to support changes to the audit planning cycle in accordance with AMC2 145.A.200(a)(6), whichever is the longer.