Corrective Action Plan Audit Follow-Up

Part 2 ✈ Chapter 1 - Airworthiness Audit Policy and Procedures Page 33 Part 1 - Civil Aviation Audit Policy and Procedures MRA – 1st Edition September 1998 2 It is important to review the company’s CAP to determine whether the company has developed a reasonable timetable for corrective action. It is also essential to ensure that the timetable has prioritised the corrective actions to address the most critical findings first. 3 Depending on the nature of the audit findings, the company’s CAP should involve: a Immediate Corrective Action. This is action taken immediately upon identification of the audit finding to remove the immediate threat to aviation safety; b Short-Term Corrective Action. This is short-term action to correct a non-conformance that does not pose an immediate threat to aviation safety, which ensures that conformance is established quickly until long-term action is completed to prevent recurrence of the problem. Short-term corrective action will normally take place within 30 days; and c Long-Term Corrective Action. This is longer-term action and has two components. The first will involve identifying the cause of the problem and indicating the measures the company will take to prevent a recurrence. These measures should focus on a system change. The second component will include a timetable for company implementation of the long-term corrective action. Long-term corrective action will normally take place within twelve months. 4 Long-term corrective action should be accompanied by the forwarding of supporting documents for review. Short-term corrective action should also be accompanied by the forwarding of supporting documents, which may take the form of logbook entries, purchase orders, memoranda or revised inspection procedure cards. It is important to verify as much supporting documentation as possible during subsequent surveillance. 5 If the company’s CAP is not acceptable, the responsible office will indicate the reasons, propose changes and negotiate a new target date. Otherwise, an alternative course of action may be pursued. 6 Where the audit findings are of a minor nature, no threat to aviation safety exists and the company has a reputable quality assurance or internal audit program, a “paper follow-up” may be acceptable. In this case, the documents are submitted with the CAP and no interim surveillance is required. As the company completes its audit responses as Part of the CAP, its progress will be monitored. 7 An audit will be formally closed when every audit finding has been corrected through the CAP, the corrections have been found to be acceptable by the follow-up office and post-audit surveillance has been completed. Page 34 Part 2 ✈ Chapter 1 - Airworthiness Audit Policy and Procedures MRA – 1st Edition September 1998 Part 2 ✈ Chapter 2 - Airworthiness Audit Policy and Procedures 8 Normally, the CA will ensure that a letter has been sent to the auditee, confirming that all audit findings have been completed and that the audit has been closed. A sample letter can be found in Appendix 10.

3.5.3 Post-Audit Surveillance

During audit follow-up, surveillance is the only means to ensure that companies with non-conformances comply with regulatory requirements and respond satisfactorily to audit findings. Post-audit surveillance can be conducted as informal visits or as a more structured follow-up audit. Airworthiness Audit Policy and Procedures

Chapter 1 Introduction

1.1 Audit Philosophy

The airworthiness audit function completes a loop in the regulatory process, confirming for Civil Aviation that an aviation document holder is upholding the commitments to which they agreed to prior to document issue. A candidate organisation is certified on the basis that the program submitted for Civil Aviation approval meets the minimum regulatory requirements. At this time, great emphasis is placed on the candidate’s control manual to ensure that the content adequately addresses program control. For the program to receive Civil Aviation approval, the manual must clearly explain how the organisation intends to meet the requirements of the standards and regulations relating to the scope of authority sought. Essentially, the greater degree of delegation, privilege, or authorisation accorded to the document holder, the more explicit the draft control manual must be. The manual is reviewed to ensure that the means of achieving conformance to standards and compliance with regulations is referenced and documented by process.

1.2 Applied Standard

The control manual, once approved, becomes the primary standard for evaluating an approved airworthiness organisation. In theory, conformance to the control manual should ensure compliance with the applicable regulations. If, for one Part 2 ✈ Chapter 1 - Airworthiness Audit Policy and Procedures Page 35 Part 1 - Civil Aviation Audit Policy and Procedures MRA – 1st Edition September 1998 reason or another, the approved control manual used by the document holder fails to meet the minimum requirements of Civil Aviation regulations, this failure must be documented in the audit report.

1.3 Program Amendments

For a program to be successful, a great deal depends on the skill of the participants; however, the quality of the program itself is equally important. The audit process will be amended from time to time to ensure that it will provide adequate and timely oversight of air operators.

1.4 Compliance

The concept of “fair but firm” treatment is the primary means of motivating voluntary compliance with regulatory requirements.

1.5 Conclusion

With all of these forces affecting the program, changes have been made to streamline the process. The overall intent remains consistent with our objective: “to ensure that the audit process is applied in a manner that is both fair and equitable.”

Chapter 2 Policy and Organisation

2.1 Purpose

Airworthiness audits are conducted primarily to ensure conformance to regulations and standards to provide a safe environment for the flying public. This section is intended to guide and direct Airworthiness personnel engaged in regulatory audits so that the standardisation of audit procedures is achieved and maintained. In addition, the establishment and maintenance of an audit monitoring system for the regulatory oversight of air operators is a requirement of the State.

2.2 Applicability

The audit policy and procedures contained in this chapter apply to all approved organisations that are subject to the audit process as a condition of document issue.