2. MPL Informat io n – This document provides informatio n and instructio ns about contractors used by 14 CFR parts 121, 135, 121/135, and 145 in two formats; these formats are Excel and XML.
(b) Once completed, the MPL must be submitted to the air carrier’s FAA CHDO by the last day of each calendar month. The AFS-300 Web site can be found at http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs300/.
NOTE: The MPL does not include subcontractors used by the MP. The air carrie r should accept the MP’s subcontractors at the forefront of the contractual agreement and ensure that procedures exist to notify the air carrie r of any future changes.
9-2. RESPONSIBILITY FOR MAINTENANCE PERFORMED BY OTHERS. Consistent with part 121, § 121.1(b), part 135, § 135.1(a)(2), and others, when you use an MP to accomplis h all or part of the maintenance activities on your airplane or its component parts, that MP becomes part of your maintenance organization and falls under your control. Additionally, §§ 121.363 and 135.413 make it clear that you remain primarily responsible for all of the maintenance performed by that MP on your aircraft. You must determine that the MP has the capability to do your work on your behalf, direct their work, and determine that their work was done satisfactorily according to your manual and your standards. Because all work on your aircraft must be performed in accordance with your maintenance manual and your maintenance program, you must also provide the MP with appropriate materia l from your mainte na nce manual for that work. You must ensure that the MP follows the procedures in your manual that you have provided (see subparagraph 3-2c). You should accomplish this through work-in-progress audits while the MP is actually accomplishing the work. Your manual system should accommodate work performed for you by each MP. The policy and procedures portion of your maintenance manual should assign clear authority and responsibilities and outline procedures for your personnel to administer, control, and direct all contract maintenance. You should arrange the technical material that you provide for the use and guidance of the MP. You should have a written contract with anyone performing contract maintenance for you on a continuing basis. This will help ensure that your responsibilities are addressed. In the case of major operations, such as engine, propeller, or airframe overhaul, the contract should include a specification for the work. You should include or reference that specification in your manual system.
9-3. UNSCHEDULED CONTRACT MAINTENANCE PERFORMED AWAY FROM REGULAR FACILITIES. Sometimes, you will need maintena nce performed on your aircraft while it is away from your regular maintenance facilities. You also may need maintenance services on short notice. Your maintenance manual should include procedures for obtaining these services under these unanticipated conditions. You should never use the term “emergency maintenance” to describe short notice, unscheduled maintenance, as such terms imply to your employees and your MPs that the FAA’s regulatio ns and your procedures do not have to be followed. “Emergency” means that a serious situation has occurred unexpectedly, involves a peril to life or property, and demands immediate action. An out-of-commission aircraft parked on an airport ramp could hardly constitute a peril to life or property. You should outline the procedural steps that you will take to control and direct the unscheduled maintenance Par 9-1 Page 39
accomplished by your MP. Unscheduled, short notice requirements for maintenance do not void your responsibility to determine that your MP has the organizatio n, adequate facilities and equipment, competent personnel, and appropriate portions of your manual for the work that needs to be done. These determina t io ns must be made before any MP starts to work on your aircraft. These procedures and method of determination should be in your manual.
9-4. AIRWORTHINESS RELEASE OR AIRCRAFT LOG ENTRY REQUIRED BY §§ 121.709 AND 135.443. For the purposes of contract maintenance, it is important to note that §§ 121.709(b)(3) and 135.443(b)(3) outline specific requirements for the persons authorized to sign an airworthiness release or aircraft log entry. As defined in part 1, § 1.1, a person is an individual, firm, partnership, corporation, company, association, joint stock association, or government entity. Thus, a repair station, as a company, qualifies as a person defined in § 1.1 and can prepare, or cause to be prepared, an airworthiness release or an appropriate entry in the aircraft log. Such a release or aircraft log entry is limited to the work the repair station is rated to perform and actually performs on an aircraft for certificate holders operating under 14 CFR parts 121, 125, and 135. However, in preparing the airworthiness release or aircraft log entry, the person or, in this instance, the part 145 certificated repair station (CRS), must comply with the procedures set forth in the part 121 or 135 certificate holder’s manual for preparing the airworthiness release or aircraft log entry. Because there is no reference to “person” in §§ 121.709(b) or 135.443(b), the “certificate holder” refers not to the repair station, but the part 121 or 135 certificate holder for whom the repair station is performing maintenance. This provision corresponds to the part 121 and 135 certificate holder’s duty under §§ 121.367 and 135.425 to ensure that not only are competent personnel performing maintenance on their fleets, but that each aircraft released to service is airworthy.
a. Log Entry or Airworthiness Release Form. You must designate each individ ual authorized to execute the log entry or Airworthiness Release Form for you by name and occupationa l title. The individ ua l making the log entry or Airworthiness Release Form acts as your authorized agent. He or she certifies that the maintenance was accomplished according to your maintenance manual and maintenance program procedures, and that no known condition exists that would make the aircraft unairworthy. This arrangement does not reduce the responsibility of maintenance personnel to accomplish maintenance functio ns or tasks in accordance with your manual.
b. Proce dure s for Log Entry or Airworthine ss Re le ase Form. Consistent with §§ 121.709(b)(1) and 135.443(b)(1), you must include in your maintenance manual the procedures for making an aircraft Airworthiness Release Form or log entry. Our regulatio ns require you to make a log entry or complete an Airworthiness Release Form before you can operate your aircraft for any reason after you have accomplished any maintenance. You are required to make a log entry or an Airworthiness Release Form. Other than form or format, there is no legal or technical difference between an Airworthiness Release Form and a log entry.
9-5. EVALUATING NEW MAINTENANCE PROVIDERS. Before you can use an MP for the first time, you must determine that the MP candidate complies with pertinent requirements of part 121 subpart L or part 135 subpart J. In most cases, you would conduct an onsite audit. You must demonstrate, through this audit or by some other means, that the MP has an adequate organization, adequate facilities and equipment, competent personnel, and is capable of Par 9-3 Page 40
performing the work consistent with the requirements of your program. You should use a risk assessment process to determine whether to accomplish an onsite audit or not. Your risk assessment should take into account what happens (the failure effect) when the aircraft part or aircraft system that the MP works on fails. If the failure effect is safety, your procedures should mandate an initial onsite audit along with recurrent onsite audits, as well as the posting of a resident employee at the MP’s facilit y, who is assigned audit and oversight duties.
NOTE: Since the failure effect of parts and systems that come under essential maintenance concerns safety, the air carrie r shouldhave robust policies and procedures to qualify, supervise, and control these MPs, which should include onsite audits.
9-6. CONTINUING MAINTENANCE PROVIDER OVERSIGHT. Ensuring that each one of your MPs is in continuo us compliance is a major functio n of your CASS. You should use your risk-based process for establishing a schedule for auditing and inspecting each of your MPs.
Inherent with a risk-based process, you may determine that some of your MPs do not require an onsite audit. Consistent with the “performance” wording of § 121.373 or § 135.431, the audits that you accomplish should be primarily work-in-progress audits that serve to determine that your MPs are followin g your manual. The audits should be accomplished by trained auditors, and the results analyzed by trained analysts. The results of the analysis should permit you to determine each MP’s continuing compliance with part 121 subpart L or part 135 subpart J, as appropriate, and your maintenance program.
9-7. USING A CERTIFICATED REPAIR STATION (CRS) AS ONE OF YOUR MAINTENANCE PROVIDERS.
a. Arrangements for Maintenance. If you decide to exercise your authority under § 121.379 or § 135.437 to make arrangements with other persons to accomplish contract maintenance for you as provided in your manual, you may choose to make these arrangements with an FAA CRS, but these rules do not require you to do so. The scope of your authorization to make arrangements for maintenance is very broad; you can make arrangements for maintenance with any person as that term is defined in 14 CFR part 1, § 1.1, as long as that MP accomplishes your maintenance in accordance with your manual and maintenance program. Although the § 1.1 term “person” include s a CRS, it also includes anyone who does not hold an FAA certification.
b. Part 145 MP. The air carrier regulatory and maintenance program requirements that you would use to qualify an MP that holds a current part 145 repair station certificate are exactly the same as those that you would use for an MP who does not hold a current part 145 repair station certificate; there is no difference. Consistent with § 119.1(c), § 121.1(b), or § 135.1(a)(2), each person, whether certificated or not, that is employed or used by you for any maintenance, preventive maintenance, or alteration of your aircraft is required to comply with the part 121 requirements and your maintenance program requirements, not 14 CFR part 65 or 145 requireme nt s (see paragraph 8-3). Further, your § 121.379(b) or § 135.437(b) authorization to approve your aircraft for return to service after maintenance extends to the work accomplished under your § 121.379(a) or § 135.437(a) authorization to make arrangements with other persons for maintenance.
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CHAPTER 10. PERSONNEL TRAINING
10-1. MAINTENANCE PROGRAM TRAINING REQUIREMENTS. You can find your specific air carrier maintenance training requirements in certain sections of 14 CFR part 121 subpart L and part 135 subpart J. Part 121, § 121.375 and part 135, § 135.433 require you to have a training program that ensures each person (including inspection personnel) who determines the adequacy of work done for you is fully informed about procedures, techniques, and new equipment in use, and is competent to perform his or her duties. There is an additional implied training requirement in part 121 subpart L and part 135 subpart J based on your responsibility to provide competent personnel for the proper performance of your maintenance program. A training program is the logical means for ensuring that maintenance personnel are competent.
FAA regulatio ns allow you to develop a training program that fits your particular needs.
10-2. TYPES OF TRAINING. Some of the possible types of training in your training program are initial training, recurrent training, specialized training, competency-based training, and maintenance provider (MP) training. You should select the appropriate training for your personnel, includ ing your MP personnel, which you should base on an assessment of training needs. This assessment is a reflection of the required knowledge, skills, and ability to properly accomplish a given task or function, and the current capability of those who you would assign a particular task or function.
10-3. INITIAL TRAINING. You should provide initial training right after you hire an employee, or when your existing employees begin to work on new equipment or a new assignment. Your initial training program may include subjects such as employee indoctrination or orientat io n; maintenance department policies and procedures; maintenance recordkeeping and documentation; aircraft systems or ground equipment; specific skills (e.g., avionics, composite repair, aircraft run-up and taxi); skills upgrade; human factors; task-specific training;
hazardous materials (hazmat); or Enviro nmental Protection Agency (EPA) and Occupational Safety and Health Administ rat io n (OSHA) regulat io ns familia r iza t io n. Your init ia l training should also include a competence-based assessment of employees. This evaluates an employee’s previous training and experience and helps identify his or her specific individ ual training needs.
The objective is to provide training that addresses the gap between required competence and the competence an individual already has.
10-4. RECURRENT TRAINING. Recurrent training is education occurring on a repetitive basis. You must provide maintenance personnel with the informatio n and skills necessary to maintain your standard of competence. This training also accommodates the introduction of new aircraft; aircraft modifications; new or different ground equipment; new procedures, techniques, and methods; or other new informatio n. Your recurrent training, although occurring on a repetitive basis, may not adhere to a defined schedule. You should not provide repetitive informatio n in recurrent training unless it is needed to maintain the desired degree of competence. Your recurrent training may include:
• Continuing competency training designed to maintain regulatory and certificate currency requirements.
• Refresher training on a seldom-accomplished task or seldom-used skill.
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• Update training for particular tasks or skills. Update training can include training bullet ins, bullet in board items, self-study tasks, and computer-based instruction (CBI).
• Any other continuing education or training that may not be provided on a defined schedule.
10-5. SPECIALIZED TRAINING. Your specialized training should focus on competence in specific tasks or Areas of Responsibility (AOR), such as Required Inspection Items (RII), borescope, nondestructive testing, or flight control rigging. You might provide this training with initial or recurrent training. You do not need to limit it to maintenance subjects, but instead may include management skills training for new supervisors, computer skills, or other training necessary because of a change in an individual’s duties and responsibilities.
10-6. M AINTENANCE PROVIDER TRAINING. Your training program must provide appropriate information to each employee of a MP about your specific program. The training should include functio n-specific training appropriate to each person’s job assignment or AOR.
You do not need to provide training to MP personnel in areas that do not concern them. For example, training on aircraft log procedures and minimum equipment list (MEL) procedures would not be required for aircraft interior cleaners, but would be required for maintenance personnel assigned to oncall maintenance for you.
NOTE: If your MP has specific types of training for its personnel, you do not need to duplicate that training for those individuals. However, you must ensure your MP actually has provided the training, and that the training meets your own needs and training standards. This could be a Continuing Analysis and Surveillance System (CASS) work-in-prog re ss audit.
10-7. COMPETENCY-BASED TRAINING. Although air carriers historically have provided a specified number of maintenance training hours to ensure employees have the competencies needed for their jobs, studies have shown that it may be better for you to train to a competency-based standard. You do not have to perform this type of training on a defined schedule or for a specific number of hours. Rather, you should test each individ ual to evaluate what training he or she needs, and then use these evaluatio ns to identify those personnel who retain a high level of subject competence and who may not require a particular block of instructio n. Conversely, you also should identify those individ uals who require more training.
Training to competence permits you to tailor training programs to the specific requirements of your individ ual maintenance personnel and MPs.
a. When to Require Competency-Based Training. You could use competency-based training to raise an employee’s level of competence to that level required by the individual’s duties and responsibilities. You should have procedures to determine when an individual requires competency-based training. You may determine the nee d for this type of training through pre- or post-employment testing, or through the analysis and corrective action functio ns of your CASS.
If you use competency-based training, it should specifically address the lack of competence. In some instances, competency-based training may consist of an appropriately knowledgeable person simply reviewing procedures with an employee through on-the-job training (OJT). You should design competency-based training to fix an immed iate knowledge or skill deficie nc y, and Par 10-4 Page 44
the training may focus on one individ ual or a small group. You may include competency-based training in your initial or recurrent training requireme nts.
b. Com petency Deficiencies. For those circumstances where you identify a competency deficiency through the investigatio n of an event, your competency-based training should show an individual what happened, why it happened and demonstrate, in a positive manner how to prevent it from happening again.
c. Competency Improvement Training. You should orient your competency improvement training toward correcting personnel competence deficiencies that you have identified through your CASS.
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CHAPTER 11. CONTINUING ANALYSIS AND SURVEILLANCE S YSTEM
11-1. BACKGROUND OF THE CONTINUING ANALYSIS AND SURVEILLANCE SYSTEM (CASS). Introductio n of the CASS requirement resulted from an FAA industry study of a series of maintenance-rel ated air carrier accidents occurring during the 1950s. The study found that, in many cases, the primary causal factor of an accident was a fundamental weakness or weaknesses in the air carrier maintenance program. The study found that in some cases maintenance personnel failed to accomplish required maintenance tasks or failed to accomplish the task correctly. They simply didn’t follow the manual. In other cases, the study found that the maintenance program, even when followed as planned and documented, was not effective in preventing the situation that led to the accident. It did not produce the desired results.
a. Regulations. Responding to this finding, we introduced regulations (14 CFR part 121, § 121.373 and part 135, § 135.431) that require you to establish and maintain a system for the CASS of the performance and effectiveness of your maintenance program.
b. Correcting Deficiencies. These regulatio ns further require that you include a process in your CASS to correct any deficiency identified in your maintenance program, regardless of whether you did the work or had a maintenance provider (MP) do the work.
11-2. CASS IS A SAFETY MANAGEMENT TOOL. A CASS is your system for managing safety as it relates to maintenance functions. As a tool to manage safety, it is part of your overall structure of policies and procedures that you use to ensure your operations are to the highest possible degree of safety. It is a structured, methodical process that helps you reach your maintenance program objectives. CASS is the only management system that we currently mandate by regulatio n. If you use it properly, your CASS becomes an inherent way of doing business for you, and helps you to promote a culture of safety in your company by providing a formal process for your employees to identify and correct safety deficiencies. As you will see in the following brief discussion of the structure of a CASS, the same objectives of measuring and continuo usly improving the performance (program executio n) and effectiveness (program results) of a major functio n (maintenance) apply equally to all safety-related maintenance program functio ns that you must manage.
11-3. BASIC CASS PROCESSES.
a. CASS Processes. Your CASS is a risk-based, closed-loop system that has four basic processes:
(1) Surveillance. An informatio n gathering/audit process you use to collect data to measure your program execution and measure your program results.
(2) Analysis. An analysis process you use to identify any maintenance program deficiencies and any necessary corrective actions.
(3) Corre ctive Action. A planning process you use to ensure that your corrective actions are imple me nted.
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(4) Followup. A performance measurement process that you use to verify that your corrective actions are effective. This is also an information gathering and analysis process, thereby closing the loop.
b. Using an Audit Program.
(1) During the first step, surveillance, you will gather and obtain data using an audit program to support measurement of performance (program execution). Your audit program should be well-structured, based on risk assessment, and accomplished by individuals trained and skilled specifically at auditing. Consistent with the wording of the regulatio n, your primary type of audit should be work-in-progress audits that evaluate if the worker is following the manual.
Your auditors would also look at areas, such as manuals and other maintenance technical data, aircraft condition, actual in-process maintenance practices, training, publicatio ns, and ground operations.
(2) In addition, information gathering to obtain data that will support the measurement of effectiveness (program results) is generally a collection of flight operational data, such as accidents/incidents, mechanical delays and cancellations, in-flight engine shutdowns, unscheduled landings, engine performance, pilot logbook writeups, and unconfirmed component or part removals.
c. Data Analysis. In the second step, you will analyze the data to identify indications of maintenance program weaknesses. Your data analysis should be accomplished by individuals experienced and/or trained as analysts. One of your key objectives here is to not only identify a weakness, but to determine its root cause. This is where your knowledge of human factors becomes critical.
d. Developing Corrective Action. Based on the results of your analysis, the third step is for you to develop a corrective action, if necessary, again taking into account human factors so that your corrective action is likely to be successful. Once you determine what the corrective action is, you will develop and implement a corrective action plan (CAP).
e. Conduct a Followup Measurement Process. To close the loop, the fourth step of your CASS will have you conduct a followup measurement process using surveillance and analys is to verify that your corrective action has effectively corrected the deficiency that you identified. You can design this followup data-gathering process specifically for the issue of interest, or you can make it a part of your continuing surveillance that is the first step of your CASS. Determining if you need a special informatio n gathering procedure is part of your analysis that you accomplished in step three.
f. Aspects of Surveillance. Note that both the initial and followup surveillance can and should have proactive and reactive aspects to them. In the case of audits by auditing systems and procedures, as well as specific transactions, the analysis of audit results can identify weaknesses in a process. Correcting these weaknesses before a problem results is a proactive approach. An audit also may uncover a missed or improper maintenance action. Investigating this finding and correcting the immediate problem is a reactive process. Developing and implementing a corrective action to prevent a similar future event is equally important for improving the Par 11-3 Page 48
maintenance program, and the regulatio ns require it. Similarly, your analysis of operational performance data from a systems point of view can result in identification of a system’s weakness before a specific unwanted event (e.g., a cancellation) occurs, which is a proactive process. Investigating and correcting an undesirable operational event related to the maintenance program after it has occurred, though reactive, is also a necessary and desirable procedure.
11-4. RISK-BASED DECISIONS. All effective CASSs take into account the need to manage risk to an acceptable level, as well as the practical limitations that you must face when addressing deficiencies. Consequently, you must set priorities and make choices for planning audits and other information gathering activities, analyzing data, and selecting and implementing corrective actions. You should tie setting such priorities directly to a risk assessment process so that the resulting maintenance program achieves its objectives.
11-5. SCOPE OF A CASS. The CASS monitors all 10 elements of your maintenance program:
• Airworthiness responsibility,
• Air carrier maintenance manual,
• Air carrier maintenance organizatio n,
• Accomplishment and approval of maintenance and alterations,
• Maintenance schedule,
• Required Inspection Items (RII),
• Maintenance recordkeeping system,
• Contract maintenance,
• Personnel training, and
• CASS.
11-6. CASS DESIGN PRINCIPLES.
a. Attributes of System Safety.
(1) Clear authority.
(2) Clear responsibility.
(3) Specific written procedures.
(4) Effective controls.
(5) Performance measures.
(6) Well-defined interfaces.
b. CASS Design. These six system safety attributes should be the starting point for the design of your CASS. It should be clear who in your organizatio n is responsible for, and who has authority over, the CASS. You should not divide responsibility/authority into two or more parts due to the likely possibility that activity such as auditing and operations data analysis are poorly coordinated. Typically, in addition to an individual with overall CASS responsibility, you should Par 11-3 Page 49
have a management board or committee to ensure good communication and coordination of all CASS functio ns, and to maintain regular senior level management involvement. This oversight group also can provide a form of control over critical aspects of your CASS operation and measure the performance and effectiveness of the CASS itself.
c. CASS Interfaces. In addition to the many elements within your maintenance organization, there are many interfaces between the CASS and functions or organizational elements of a typical air carrier that are outside maintenance. Some of the more obvious examples are engineering, flight operations, purchasing, safety, and the FAA. It also is important that you clearly define and coordinate your CASS relationships to your other programs (if they exist), such as Internal Evaluatio n Programs (IEP), flight operations quality assurance (FOQA) programs, voluntary disclosures, and Aviatio n Safety Action Programs (ASAP).
11-7. CASS PERSONNEL REQUIREMENTS.
a. Effective CASS Skills. An effective CASS requires certain skills that you may not have readily availab le within your maintenance organizatio n. For example, auditing skills are not automatica l ly inherent in those skilled in accomplis hing mainte na nce. Analys is capabilit y, particularly related to root cause determination, risk analysis, and consideration of human factors, is specialized and generally requires sp ecific training and experience.
b. Sharing Personnel. For all operators, but particularly for the smaller ones, required CASS personnel can be shared. You may choose to have your personnel perform CASS functions as a collateral duty, and you may choose to hire someone outside your organizatio n to accomplish some or all of your CASS functions. However, it is essential that you recognize the need for knowledge and skills in your CASS that do not necessarily coincide with those knowledge and skills resulting from many years of maintenance experience repairing airplanes.
NOTE: You can find more detailed information concerning developing and implementing a CASS in AC 120-79.
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