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Recommendation issued to: Civil Aviation Safety Authority

Recommendation details
Output No: R20040066
Date issued: 25 June 2004
Safety action status:
Background:

Output text

Safety Recommendation

The ATSB recommends that CASA review its airworthiness surveillance processes and Certificate of Approval assessment processes to ensure that it provides adequate guidelines to assist CASA inspectors to identify priority areas for consideration during surveillance and approval activities, such as programs for compliance with the requirements of Airworthiness Directives.

Initial response
Date issued: 23 August 2004
Response from: Civil Aviation Safety Authority
Action status: Closed - Not Accepted
Response text:

Legislation relating to the approval of a maintenance facility is outlined in Civil Aviation Regulation (CAR) (1988) 30.
1. A person engaged, or intending to engage, in any stage of design, distribution or maintenance of aircraft, aircraft components or aircraft materials, or in the training of candidates for, or in the conducting of, the examinations referred to in paragraph 31 (4) (e) may apply to CASA for a certificate of approval in respect of those activities.
2. An application must be in writing and must:
(a) set out the following:
(i) a statement of the activities to be covered by the certificate;
(H) the address of the main place (if any) at which the applicant proposes to carry out those activities;
(Hi) the number of appropriately qualified or experienced persons employed by the applicant who will be involved in carrying out those activities; and
(b) have with it evidence of:
(i) the relevant qualifications and experience of the applicant and the applicant's employees; and
(H) the facilities and equipment available to the applicant for the carrying out of the activities; and
(Hi) the arrangements made to ensure the applicant has, and will continue to receive, information necessary for the carrying out of those activities; and
(iv) a system of quality control that satisfies the requirements of subregulation (20); and
(c) if maintenance of class A aircraft is an activity to be covered by the
certificate -have with it a copy of the procedures manual, in which the system of quality control procedures must be set out, that the applicant proposes to use if the certificate of approval is granted.
When an application is made the following criteria is required to be addressed to satisfy the requirements of paragraph (20) of CAR 30:
(20) In deciding whether it is satisfied as mentioned in subregulation (2A), CASA must have regard to:
(a) the relevant qualifications and experience of the applicant and the applicant's employees; and
(b) the facilities and equipment available to the applicant for the carrying out of those activities; and
(c) the arrangements made to ensure the applicant has, and will continue to receive, the information necessary for the carrying out of those activities; and
(d) the applicant's system of quality control; and
(e) if the applicant is required by paragraph (2) (c) to have a procedures manual- the applicant's procedures manual.
In order to comply with this legislation, CASA inspectors are required to utilise the Certificate of Approval Procedures Manual.
The current process requires that applicants make an initial application to the CASA Service Centre, who will co-ordinate the application process, before forwarding the application to the appropriate Area Office for assessment. It is at this point that detailed assessment of the organisations procedures, facilities, equipment, technical data and qualified personnel is performed.
The COA Procedures Manual Assessment Procedures states that:
"Discretionary powers are provided under CAR 30(28) and these should be fully utilised by the Inspector to achieve and maintain a high standard of quality and competence among new applicants. The aim of the assessment is to ensure that the applicant achieves the highest practical standard within the regulatory framework...
Standards generally tend to erode, rather than improve, after approval is granted. The principal aim when assessing applications should be to ensure that the applicant achieves the highest possible standard before approval is granted. A firm but tactful insistence on the required standard for the facilities, equipment, technical data and qualified personnel should be applied.
The purpose of the assessment is to ensure that the applicant's facilities, including mobile facilities, equipment and resources are suitable for carrying out those activities to which the application relates."
Section 3.1.2 of the COA Procedures Manual.outlines the scope of the assessment process and requires the inspector to:
.Obtain and review any CASA records relating to the applicant's history .Peruse documents submitted
.Become aware of any mandatory requirements applicable to the applicant's activities
.Perform an assessment of the applicant's: 0 Facilities and resources
0 Data and documentation 0 Tools and equipment 0 Premises
0 System of certification,
.Interview appropriate persons, and:

Also consider the applicant organisation's airworthiness control and the ability to: .Implement the requirements of Airworthiness Directives, modifications and
special inspections
.Schedule maintenance tasks .Report service difficulties
.Authorise personnel for maintenance, training and certification tasks .Review technical instructions
.Carry out all repairs and modifications to approved specifications .Control contractors.
Clearly, the COA Procedures Manual requires the assessing inspector to apply discretionary powers to ensure that the highest standards are applied when performing an assessment for initial issue of a Certificate of Approval.
Although no specific requirements appears to exist with regard to assessing whether an organisation has adequate personnel, the assessing inspector is required to apply his discretionary powers. The periodic inspections performed by Compliance staff are used to assess such matters on an ongoing basis, and are reported on a six monthly cycle using the Safety Trend Indicator (STI) form.
Similarly, no process seems to be evident in identifying priority areas in entry control. Rather, all areas are required to be at the highest standard prior to approval. The assessing inspector is required to consider the applicant airworthiness control and consider his ability to implement the requirements of Airworthiness Directives, modifications and special inspections.
The entry control process procedures are written to ensure that the assessing inspector uses his discretionary powers to ensure compliance at the highest possible level from the time of certificate issue. CASA then relies on regular surveillance and compliance action to ensure that these standards are maintained.
Additionally the legislation firmly places the responsibility of ensuring that maintenance, including Airworthiness Directives, on the Certificate of Registration (CoR) holder. The Licenced Aircraft Maintenance Engineer (LAME) or Certificate of Approval (CoA) holder is responsible for ensuring that the maintenance is correctly performed and certified.
C In addition to the information provided above, I am advised that Chapters 4.11 and 5.2 of the Surveillance Procedures Manual (SPM), provides guidance to staff on identifying priority areas when scoping surveillance tasks.
Furthermore, the CASA Airline Operations Branch has drafted guidance material for inspectors that allows them to identify priority areas from audit findings in the form of the CGI Handbook. Additionally, Compliance Management Instruction (CMI) 3/66, which relates to the Airline Operations Regulatory Oversight Program enables further developments during 2004/05.

 
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Last update 01 April 2011