Appendix 3
• Name,
• Position,
• Telephone number, and
• E-mail address.
e. Analysis.
(1) Summary of evidence. This summary should describe the scope of the apparent violation and explain how it was detected. In addition, conclusions reached regarding possible or probable systemic deficiencies (i.e., who, what, when, why, and how the noncompliance occurred) should be described.
(2) Reasons why the apparent violation was inadvertent.
(3) Supporting documentation. The evidence associated with the apparent violation should be attached. This evidence should include a statement regarding how the RE determined the extent of the apparent violation.
f. Comprehensive Fix Proposal. The proposed long term corrective steps to be taken by the RE to preclude recurrence of the apparent violation should be listed in this section. Each corrective step should identify the individual or department responsible for implementing and completing the corrective step as well as the time allotted for completion of each corrective step.
Examples of types of questions or issues that a comprehensive fix proposal should address are as follows:
(1) Does the apparent violation involve equipment, facilities, or individuals beyond those addressed in the initial notification and for which immediate action was taken?
(2) Are procedural or organizational changes necessary?
(3) How will it be determined whether any procedural or organizational changes are effective?
(4) What procedures will be developed to ensure that the affected area is periodically reviewed in the future so that concerns can be identified before a violation occurs?
(5) Who will be responsible for performing periodic reviews?
(6) To whom in the RE’s organization will the results of those periodic reviews be reported, and how they will be documented?
(7) A schedule for completion of a self-audit by the RE following implementation of the comprehensive fix to verify the action taken corrects the noncompliance. This self-audit is in addition to any audits conducted by the FAA and identification of the individual(s) responsible for conduct of the self-audit.
Appendix 3
g. Responsibility for Monitoring Implementation of the Comprehensive Fix.
(1) Name.
(2) Position.
(3) Telephone number.
(4) E-mail address.
h. FAA Acceptance (to be completed by the FAA).
(1) Name.
(2) Position (PI).
(3) Date.
(4) Office.
6. STAGE IV: WRITTEN REPORT REVIEW BY THE FAA. The FAA works with the certificate holder to ensure that the RE has identified any root causes and systemic issues which led to the apparent violation. This collaboration helps to ensure that the corrective actions contained in the comprehensive fix are acceptable to the FAA.
7. STAGE V: IMPLEMENTATION OF THE COMPREHENSIVE FIX AND FAA SURVEILLANCE.
a. Continued FAA and RE Cooperation. During the implementation period, the FAA and the pertinent RE should continue to work together. The FAA may advise and assist the entity in correcting any identified systemic problems. Changes will be made to the proposed comprehensive fix when the need is identified. Upon determining that the initial implementation of the proposed comprehensive fix is satisfactory, the PI may issue a letter of correction in Stage V. If the letter of correction is issued in Stage V, and subsequent changes are made to the Comprehensive Fix, the PI shall issue an amendment to the letter of correction which reflects the corrective action, as implemented.
b. The FAA’s Monitoring of Corrective Step Implementation. The FAA monitors the implementation of the corrective steps. Throughout the implementation period, the FAA assesses the pertinent RE’s corrective efforts and top management’s awareness of these efforts. If, during this period, the FAA determines that the steps taken by the entity are not those documented in the comprehensive fix and acceptable corrective action by the RE is not forthcoming, the letter of correction may be rescinded, and appropriate legal enforcement action initiated.
8. STAGE VI: INSPECTOR SIGNOFF.
a. Conclusion. At the conclusion of the implementation period, the PI makes a final assessment. If all elements of the comprehensive fix have been adequately accomplished, Page 6
Appendix 3 Page 7 (and 8) including a satisfactory self-audit by the RE, the PI finds the fix satisfactory and closes the case.
The case remains subject to reopening in the event that the agreed upon actions, outlined in the comprehensive fix, are not completed to the satisfaction of the FAA. A statement of followup investigation, confirming that the comprehensive fix was satisfactorily implemented and completed, is prepared to complete the FAA’s investigative package.
b. PI Authority. The PI has the authority to close the case. Consultation with regional specialists, legal counsel, or other FAA personnel may be accomplished when deemed appropriate by the PI.