CHAPTER 9. CONTINUING ANALYSIS AND SURVEILLANCE SYSTEM
900. What are the origins of the Continuing Analysis and Surveillance System?
Introduction of a Continuing Analysis and Surveillance System (CASS) resulted from a FAA/National Transportation Safety Board (NTSB) joint study of a series of maintenancerelated air carrier accidents occurring during the 1950s. The joint study found that, in some cases, the primary causal factor of an accident was the effectiveness of the air carrier’s maintenance program itself. The study found that some maintenance programs were incapable or ineffective in preventing the failure that led to the accident. In other cases, the maintenance program was determined to be effective, but maintenance personnel failed to accomplish required maintenance tasks or failed to accomplish the task correctly. The study found that the maintenance program was often not performed properly.
a. Responding to this discovery, FAA introduced regulatory requirements that require air carriers to establish and use a system for the continuing analysis and surveillance of the performance and effectiveness of their inspection, maintenance, preventive maintenance, and alterations programs.
b. The system must also provide a way to correct any deficiency in those programs, regardless of whether those programs are carried out by the air carrier or by another person.
CASS is crucial to the effective management of your maintenance program and your realization of the highest possible degree of safety.
901. What is CASS?
CASS is an air carrier quality assurance system. In a structured, methodical manner, CASS helps you ensure that you reach your maintenance program objectives. CASS is the only management system that is mandated by regulation. Used properly, your CASS becomes an inherent way of doing business for you, and helps you promote a safety culture in your company by providing a formal process for employees to identify and correct safety discrepancies.
902. What does CASS do?
Your CASS must be designed to detect and correct air carrier maintenance program deficiencies in the areas of program effectiveness and program performance (program execution). Your CASS provides a structured process to identify factors that could lead to an accident or incident through collection and evaluation of information that can be used as indicators of the degree of maintenance program effectiveness and performance. This is accomplished through a closedloop, continuous cycle of surveillance, investigations, data collection and analysis, corrective action, corrective action monitoring, and back to surveillance. Your CASS should ensure that all elements of your maintenance program are being accomplished in accordance with your manual (program execution), that your program is effective in achieving its goals, and that deficiencies in your maintenance program and manuals are identified and corrected. CASS collects information, analyzes the information, and looks for precursors, indicators, or symptoms of discrepancies in your maintenance program so that you can develop and implement corrective action. FAA’s regulations allow the FAA to direct changes to your maintenance program to correct deficiencies if you do not make the changes by yourself.
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903. What part of your air carrier maintenance program does your CASS monitor?
CASS monitors all nine elements of your maintenance program:
/g183/g32 Airworthiness responsibility /g183/g32 Maintenance manual /g183/g32 Maintenance organization /g183/g32 Maintenance schedule /g183/g32 Maintenance recordkeeping system /g183/g32 Accomplishment and approval of maintenance and alterations /g183/g32 Contract maintenance /g183/g32 CASS /g183/g32 Personnel training
904. How does CASS work?
a. CASS has three primary functional areas:
(1) Monitoring a maintenance program’s effectiveness;
(2) Monitoring a maintenance program’s performance (program execution); and
(3) Developing and implementing corrective action for a maintenance program identified during the surveillance, investigations, and analysis process.
b. Two subfunctions within the first two primary functional areas are: scheduled (proactive) surveillance, investigations, and analysis; and unscheduled (reactive) surveillance, investigations, and analysis.
c. A subfunction within the third primary functional area is monitoring/feedback to ensure the corrective action accomplished what was intended.
905. What are the principal elements of CASS?
Your CASS should have two major sections: program execution and program effectiveness.
Both should include at least the following basic elements.
a. The Accountable Manager: the person in charge. This person should have the corporate duty and responsibility to commit, control, and direct the corporate resources necessary to reach the objectives of the system and to make the maintenance program and manual amendments identified as necessary by your CASS.
b. Detailed policy and procedures for determining whether you need to amend your maintenance program or manual, and for making those amendments. These policies and procedures should cover both Proactive Surveillance and Analysis and Reactive Surveillance and Page 34 Par 903
Analysis. Both types of analysis are continuous processes of surveillance, data collection, and analysis; investigations; corrective action; and monitoring and feedback. Proactive analysis forecasts faults in your maintenance program or manual through the collection and analysis of a wide variety of data. It corrects those faults, including human factors issues, in advance of any specific event, accident, or incident. Reactive analysis responds to events or accidents to address the faults, including human factors issues, in your maintenance program or manual that were responsible for those events or accidents.
906. What are the general CASS objectives?
Your CASS should accommodate your objectives by helping you:
a. Realize the levels of safety and reliability that you have set;
b. Restore the levels of safety and reliability that you have set in the event deterioration occurs;
c. Collect the information necessary to identify systemic or other maintenance error contributors that degrade airworthiness and the level of safety and reliability that you have set;
d. Collect the information you need to continuously validate that all elements of your maintenance program are being executed in accordance with your manual;
e. Collect the information you need to continuously validate the effectiveness of each element of your maintenance program;
f. Collect the information you need to continuously validate the effectiveness of each scheduled maintenance task and its associated interval; and
g. Compile the information you need to improve the design of items whose level of safety and reliability proves inadequate.
907. What does the program execution part of your CASS accomplish?
The program execution part of your CASS should ensure that everyone, including all of your maintenance providers, complies with your manual and program and with all applicable regulations and statutes. Generally, the program execution part of your CASS functions through a system of scheduled audits and investigation of operational events. You should consider each negative audit and each operational event as an indicator or symptom of a program or systemic failure. Your program execution part of CASS should include a continuous cycle of both scheduled and unscheduled (proactive and reactive) surveillance and investigations, data collection and analysis, corrective action, and monitoring and feedback.
1. Proactive surveillance and analysis.
Your CASS should provide a continuous process of surveillance, collection, and analysis of items discovered during scheduled audits and other data collections. Your CASS audit schedule should include, but not be limited to, the following items:
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a. All manuals, publications, and forms are useable, current, accurate, and readily available to the user.
b. All maintenance and alterations are, in fact, performed in accordance with the methods, standards, and techniques specified in your manuals.
c. Maintenance records are generated in accordance with the manual procedures, and are adequate, correct, and complete.
d. All RIIs are clearly identified and handled in accordance with your RII procedures.
e. Air carrier airworthiness releases are executed by authorized persons and accomplished in accordance with the procedures specified in your manuals.
f. Shift turnover records and deferred maintenance are handled in accordance with your manual procedures. You should consider focusing on shift turnover errors in your surveillance system. Shift turnover errors have been identified as primary causal factors in a number of fatal air carrier accidents and incidents.
g. All maintenance facilities and equipment, including contract maintenance facilities and equipment, are adequate for the maintenance required.
h. All personnel, including contract personnel, are competent to properly execute the maintenance that is to be performed.
i. Each aircraft released to service is airworthy and properly maintained for service in air transportation.
2. Reactive surveillance and analysis.
Your CASS should monitor and respond to unexpected operational events on an unscheduled surveillance item basis. This is a continuing process of real-time surveillance, investigations, and analysis of random events that reduce the availability of the aircraft. Your event investigation should follow the causal chain much further than the determination that “the pylon pin safety lock was left off,” or “the check valve was installed backwards.” You should determine why the event occurred and take appropriate corrective action. While you should correct each individual discrepancy (for example, install the backward check valve properly), your CASS should emphasize analysis and correction of that part of your maintenance program that allowed the program performance fault (backward check valve) to occur in the first place. It helps determine what changes are needed to fix the deficiencies in your maintenance program that allowed the random event to occur. Your CASS reactive surveillance and analysis should address, but should not be limited to, the following items:
a. Aborted takeoffs;
b. Unscheduled landings;
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c. In-flight engine shutdowns;
d. Accidents/incidents;
e. Canceled flights due to unscheduled maintenance requirements;
f. Delays due to an unscheduled maintenance requirement; and
g. Any other maintenance or operational related event leading to an unsafe condition.
908. What does the program effectiveness part of your CASS accomplish?
The program effectiveness part of your CASS should ensure that all elements of your maintenance program are effective in what you intend them to accomplish. The essential philosophy of the program effectiveness portion of your CASS is that certain indicators, such as adverse trends, premature failures, and maintenance-related flight cancellations/delays may be indicative of an effectiveness deficiency in a portion or portions of your maintenance program.
Your CASS should function by continuously surveying, collecting information, and analyzing and validating your operation, including, but not limited to, maintenance time limits, maintenance procedures, and maintenance methods, techniques, and practices. It includes a continuous cycle of surveillance, investigations, data collection and analysis, corrective action, and monitoring and feedback.
While you must dispose of each documented aircraft discrepancy (for example, “replaced the leaking hydraulic pump”), this element of your CASS focuses on analysis and correction of that portion of your maintenance program that allowed the program performance discrepancy (what caused the hydraulic pump to leak?) in the first place. This part of your CASS should include, but not be limited to, a continuous review of pilot report data, failure analyses, previous inspection findings, and component removal rates. You can use these and other indicators as tools to identify rogue parts, and to direct maintenance and repair activity. Procedures for documenting, reporting, and analyzing inspection findings, operational malfunctions, or abnormal operations, such as hard or overweight landings, are essential parts of this element.
1. Proactive surveillance and analysis.
Your CASS should provide a continuous process of surveillance, collection, and analysis of certain data that detects impending failures or adverse trends in your maintenance program.
Some data you might collect, monitor, and analyze include:
a. An increased frequency of unscheduled parts replacement or increased need for unscheduled maintenance.
b. An increased degree and frequency of adjustment and/or calibration of equipment.
c. Changes in operational capability or reliability (i.e., delays).
d. Dispatch availability rates.
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e. Trend analysis of individual item failure rates.
2. Reactive surveillance and analysis.
Your CASS should monitor and respond to unexpected operational events on an unscheduled surveillance item basis. This is a continuing process of real-time surveillance, investigations, and analysis of random events that reduce the availability of the aircraft. It helps determine what changes you need to make to fix the deficiencies in your maintenance program that allowed the random event to occur. Your CASS reactive surveillance and analysis should address, but not be limited to, the following items:
a. Aborted takeoffs;
b. Unscheduled landings;
c. In-flight engine shutdowns;
d. Accidents or incidents;
e. Flights canceled due to an unscheduled maintenance requirement;
f. Delays of more than 15 minutes due to an unscheduled maintenance requirement; and
g. Any other event leading to an unsafe condition or a reduction in the availability of the aircraft for service.
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CHAPTER 10. PERSONNEL TRAINING
1000. What are the basic requirements for the training program?
You can find specific air carrier maintenance training requirements in certain sections of part 121, subpart L and part 135, subpart J. These regulations state, in part, that air carriers must “have a training program to ensure that each person (including inspection personnel) who determines the adequacy of work done is fully informed about procedures and techniques and new equipment in use and is competent to perform his duties.” There is an additional implied training requirement in subpart L and subpart J in that the air carrier must provide competent personnel for the proper performance of the maintenance program. As a result, a training program for maintenance personnel has evolved as an uncomplicated means of ensuring that maintenance personnel are competent. FAA’s regulations contain the measure of flexibility necessary to allow each air carrier to develop a training program fitting its particular needs.
1001. What are some of the types of training that can be included in a training program?
Some of the types of training that can be included in an air carrier training program are: initial training, recurrent training, specialized training, maintenance provider training, and competencebased training.
1002. What is initial training and what does it include?
Initial training is provided right after a person is hired, or when personnel begin to work on new equipment or a new assignment. Your initial training program may include subjects such as employee indoctrination or orientation, maintenance department policies and procedures, maintenance recordkeeping and documentation, aircraft systems or ground equipment, specific skills (avionics, composite repair, aircraft run-up and taxi, etc.), skills upgrade, human factors, task-specific training, hazardous materials, or Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) regulations familiarization. Your initial program may also include a competence-based assessment of employees. This evaluates an employee’s previous training and experience and helps identify their specific individual training needs.
1003. What is recurrent training and what does it include?
Recurrent training is education occurring on a repetitive basis. It provides maintenance personnel with the information and skills necessary to maintain the required level 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 information. Recurrent training, although occurring on a repetitive basis, may not adhere to a defined schedule. This training should not provide repetitive information unless it is to maintain the desired degree of competence. Recurrent training may include:
a. Continuing competency training designed to maintain regulatory and certificate currency requirements;
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b. Refresher training on a seldom accomplished task or seldom used skill;
c. Update training for particular tasks or skills. Update training can include training bulletins, bulletin-board items, self-study tasks, and computer-based instruction;
d. Specific training designed to correct deficiencies identified through the air carrier’s CASS; and
e. Any other continuing education or training that may not be provided on a defined schedule.
1004. What is specialized training and what does it include?
Specialized training focuses on competence in specific tasks or areas of responsibility. You might provide this training with initial or recurrent training. You don’t need to limit it to maintenance subjects; 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.
1005. What is maintenance provider training and what does it include?
Your training program must provide appropriate information to each employee of a maintenance provider about your specific program. The training should include functionspecific training appropriate to each person’s job assignment or area of responsibility. You do not need to provide training to maintenance provider personnel in areas that do not concern them. For example, training on aircraft log procedures and minimum equipment list procedures would not be required for aircraft interior cleaners, but would be required for maintenance personnel assigned to on-call maintenance for you.
NOTE: If a maintenance provider has specific types of training for its personnel, you do not need to duplicate that training for those individuals, but you must ensure the maintenance provider has indeed provided the training and that the training meets your own needs and training standards.
1006. What is competence-based training and what does it include?
Although air carriers have historically provided a specified number of maintenance training hours to ensure that employees have the competencies needed for their jobs, studies have shown that it may be better to train to a competence-based standard. This type of training need not be done on a defined schedule or for a specific number of hours. Rather, you should test each individual to evaluate what training he or she needs. Use these evaluations to identify personnel who retain a high level of subject competence and who may not require a particular block of instruction. Conversely, you should also identify those individuals who require more training. Training to competence permits you to tailor training programs to the specific requirements of your individual maintenance personnel and maintenance providers.
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CHAPTER 11. HAZARDOUS MATERIALS AND DANGEROUS GOODS
1100. What should my manual contain about hazardous materials?
If your maintenance operations require the use of aircraft components or consumable materials that contain hazardous materials or dangerous goods as defined in 49 CFR § 173.34, your manuals should include procedures and information about these materials. Your manuals should cover:
a. Procedures and information to help maintenance, shipping, or stores personnel to identify or recognize aircraft components or consumable materials that contain hazardous materials;
b. Procedures and instructions for the safe movement, storage, or handling of those aircraft components or consumable materials within your facility or within one of your maintenance providers’ facilities;
c. Procedures and information for determining the proper packaging, marking, labeling, and materials compatibility of aircraft components or consumable materials that contain hazardous materials while they are within your facility or within one of your maintenance provider’s facilities;
d. Information, guidance, and precautions regarding the specific hazards associated with aircraft components or consumable materials containing hazardous materials that are to be moved, stored, or handled within your facilities; and
e. Information, instructions, and detailed procedures for the proper disposal of unserviceable aircraft components or consumable materials containing hazardous materials.
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CHAPTER 12. ADMINISTRATIVE MATTERS
1200. Which advisory circular does this AC cancel?
This AC cancels AC 120-16C, Continuous Airworthiness Maintenance Programs, dated August 8, 1980.
1201. What is the regulatory basis of this AC?
You can find the regulations that underlie this AC in the following parts of Title 14 of the Code of Federal Regulations:
1. Air Carriers’ Responsibility for Airworthiness, 14 CFR §§ 121.363 and 135.413;
2. Air Carrier Maintenance Programs, 14 CFR §§ 119.5, 119.49, 121.133, 121.367, or 135.21;
3. Maintenance Program Manual, 14 CFR §§ 121.133, 121.137, 121.367, 121.369, 135.21, and
135.427;
4. Maintenance Organization, 14 CFR §§ 119.65, 119.67, 119.69, 119.71, 121.365 and 135.423;
5. Maintenance Time Limits, 14 CFR §§ 119.49, 121.135, and 135.23;
6. Performance and Approval of Maintenance and Alterations, 14 CFR §§ 121.379 and 135.437;
7. Performance and Approval of Maintenance and Alterations Performed by Other Persons, 14 CFR §§ 121.379 and 135.437;
8. Continuing Analysis and Surveillance System, 14 CFR §§ 121.373 and 135.431;
9. Personnel Training, 14 CFR §§ 121.375 and 135.433;
10. Maintenance Recordkeeping and Reports, 14 CFR part 121, subpart V; 14 CFR §§ 121.369,
121.380; 135.415, 135.417, 135.427, and 135.439(b);
11. Maintenance Log, 14 CFR §§ 121.563, 121.701, 121.709, and 135.65;
12. Mechanical Reliability Reports, 14 CFR §§ 121.703 and 135.415;
13. Required Inspection Items, 14 CFR §§ 121.365, 121.369, 121.371, 135.427, and 135.429;
14. Mechanical Interruption Reports, 14 CFR §§ 121.705 and 135.417;
15. Alteration and Repair Reports, 14 CFR §§ 43.9(b), 121.707, and 135.439(a)(2)(vi); and
16. Hazardous Materials Regulations, 49 CFR parts 171, 172, 173, and 175.
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1202. Where can you find regulatory and guidance material related to the information in this AC?
For more information, consult:
1. CFR parts 43, 91, 119, 121, and 135.
2. 49 U.S.C. § 46310, Reporting and Recordkeeping Violations.
3. As revised, AC 91-56, Supplemental Structural Inspection Program for Large Transport Category Airplanes.
4. Revised AC 91-60A, The Continued Airworthiness of Older Airplanes.
5. FAA Order 8300.10, Airworthiness Inspector’s Handbook.
6. FAA Order 8300.12, Corrosion Prevention and Control Programs.
7. Air Transport Association MSG-3, Latest Revision.
8. Report number AD-A066-579, Reliability-Centered Maintenance.
1203. Where can you get materials related to the information in this AC?
1. You can get the CFRs and those ACs for which there is a fee from the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. A listing of CFR and current prices is located in AC 00-44, Status of Federal Aviation Regulations. You can also get a copy of current regulations from the CFR on-line at http://www.access.gpo.gov/ecfr/.
2. You can be placed on FAA’s mailing list for free ACs by contacting the U.S. Department of Transportation, SVC-121.21, Washington, DC 20590.
3. You can request free ACs from the U.S. Department of Transportation Subsequent Distribution Office, SVC-121.23, Ardmore East Business Center, 3341 Q 75th Avenue, Landover, MD 20785.
4. You can get Report Number AD-A066-579, Reliability-Centered Maintenance, from the U.S.
Department of Commerce, National Technical Information Service, Springfield, VA, 22161.
Telephone: (703) 487-4650.
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