Appendix 1
k. Corrective Action.
Final Root Cause Analysis (RCA) Responsibility Manager(s) of technical area(s) affected.
Procedures The director of CASS transmits preliminary analysis results to the manager of the affected department, who designates technical personnel to coordinate final RCA with the auditor/analyst. The CASS auditor/analyst oversees the process and ensures that the formal RCA process, including human factors and systems analysis, is followed.
Use of specific analytical systems Internally developed analytical process and industry tools.
Flow The auditor/analyst and technical department develop a joint final report and submit it to their respective managers.
Determination of Corrective Action Options Responsibility The CASS board appoints a corrective action team to include the CASS auditor/analyst, reliability group, technical area(s) affected, and related areas potentially affected (for example, flight operations).
Procedures The team leader is from the technical area affected. Perform risk assessment of the problem and develop corrective action options. The CASS auditor/analyst or reliability group representative does not propose corrective actions but reviews options for systems considerations and relevance to RCA.
Flow The manager(s) of the affected area(s), working with the team, transmits options to the CASS board.
Selection of Corrective Action and Corrective Action Plan Responsibility CASS board.
Procedures Decision based on a priority for safety and regulatory compliance. Risk assessment is the basic tool to support the decision. CASS personnel do not participate in the development of the corrective action but review for systems considerations and relevance to RCA.
Flow Depends on the level of the problem and the corrective action. Routine issues may be resolved at the team level with direct implementation by the affected area manager; the CASS board is then advised of this action. More significant program changes may require prior review and concurrence from the CASS board. The CASS board may raise highest level decisions to the director of QA or senior vice president of engineering and maintenance.
Appendix 1 Followup Responsibility Manager of CASS.
Procedures CASS auditor/analyst or reliability group, as applicable, assigned to develop a followup plan based on the seriousness of the problem.
Followup may include communications from technical area verifying effectiveness, followup audits or data collection, and/or a followup evaluation.
Flow The technical area reports implementation status to the manager of the CASS, who informs the CASS board. The CASS board may inform the director of QA if the problem is sufficiently serious or the implementation plan is not followed.
NOTE: The above tables provide many examples of the system safety attributes: controls and procedures.
l. Communications Between CASS and Other Personnel (A System Safety Attribute:
Interfaces).
Communication of Specific CASS Results and Actions Responsibility CASS board.
Procedures Audits based on updated checklists. The CASS collects and stores operational data in computer systems, and some analysis and alerting features are automated. Audit and analysis results communicated through company electronic mail system, with acknowledgements.
Corrective action tracking through computerized database system.
Flow Electronic mail and standard electronic reports of information flow among CASS board, corrective action teams, technical areas, and director of QA, when applicable.
Communications with Maintenance Personnel Responsibility CASS board.
Procedures The CASS initial and recurrent training included for all personnel, including lectures from CASS personnel. Monthly newsletter summary to production areas regarding CASS activities.
Flow The CASS department works with the training and company communications department, and receives feedback from managers and supervisors, particularly in the maintenance areas.
Appendix 1 Interfaces (A System Safety Attribute: Interfaces) Responsibility CASS board.
Procedures Reliability group provides regular reports on analysis results, trends, and concerns.
Auditors/analysts provide regular reports on findings, analyses, trends, and concerns.
VDRP manager provides summaries of disclosures and proposed comprehensive fixes for CASS review and input.
Copies of C.A.S.E. audit results.
To CASS Board CASS auditors review reports from company ASAPs and at least annually review maintenance-related Aviation Safety Reporting Program reports for consideration in setting audit and operational data collection priorities.
Feedback to technical areas regarding findings, trends, concerns, and followup results.
Feedback to VDRP manager regarding proposed comprehensive fixes;
coordination with manager of CASS.
Monthly reliability analysis summaries and other CASS summaries for distribution to the vice president of engineering and maintenance, director of QA and other senior management, department managers in maintenance, flight and ground operations, Internal Evaluation Program (IEP), safety office, and FAA principal inspector (PI).
CASS reports reflect VDRP comprehensive fixes without detailing the initiating circumstances.
Semiannual summary report to chief executive officer (CEO).
Copies of reliability reports and CASS summaries to the FAA PI. The FAA PI has online access to CASS reports and documents such as summaries, analysis, trends, and corrective action tracking.
From CASS Board CASS board meeting minutes.
Flow Communications channeled through manager of CASS.
m. Personnel Who Perform CASS Functions.
(1) Full-time auditors and analysts; in some cases, an auditor may also be an analyst.
(2) All members of the CASS board who have not participated in specific CASS training receive a total of 16 hours initial training covering CASS, root cause and systems analysis, and human factors.
(3) Company has hired a human factors specialist to address issues across all departments and to participate on the CASS board.
Appendix 1 Page 7 (and 8) How the Certificate Holder Evaluates Its CASS (A System Safety Attribute: Process Measurement) Responsibility Senior vice president of engineering and maintenance.
Procedures IEP evaluates CASS annually.
Flow The CASS transmits IEP reports directly to the CEO and to the senior vice president of engineering and maintenance.
Appendix 2 APPENDIX 2. SAMPLE CASS FOR A MEDIUM CERTIFICATE HOLDER Type of Certificate Holder Fleet composition 75 turboprop and turbojet airplanes; ATR–42, Canadair Regional Jets.
Number of maintenance base and line stations Base station and five line stations.
Proportion of maintenance contracted to third parties A, B, and C checks and most major maintenance in-house. Off-wing engine maintenance, avionics, and instrument overhauls contracted.
Scheduled or on-demand Scheduled (Title 14 of the Code of Federal Regulations (14 CFR) part 121).
Size and structure of the maintenance organization Engineering and maintenance organizations, including small engineering capability, shops for support, components, electronics, engines, etc.; and quality assurance (QA) department.
a. Continuing Analysis and Surveillance System (CASS) Management and Planning.
b. General Priority. This certificate holder prioritizes in the following general manner:
(1) Safe operations (air and ground).
(2) Detect and prevent noncompliance.
(3) Improve operating efficiency.
c. CASS Written Procedures (A System Safety Attribute: Procedures). An appendix to the general maintenance manual describes CASS. The detailed CASS appendix includes specific procedures for root cause and systems analysis, and discussion of awareness of human factors.
d. CASS in the Certificate Holder Organization. The chief executive officer (CEO) supports the CASS. CASS specifically appears on the functional organizational flowchart.
e. Authority for CASS (A System Safety Attribute: Authority). The senior vice president of engineering and maintenance (14 CFR part 119, § 119.65 Director of Maintenance (DOM)) has overall authority and responsibility for this air carrier’s maintenance program, including the CASS. In this case, the senior vice president of engineering and maintenance also has the direct authority for this air carrier’s CASS.
f. Responsibility for CASS (A System Safety Attribute: Responsibility). The director of QA heads the CASS board, which includes key department heads in engineering and maintenance, training, and flight operations.
g. Policy for CASS Auditor/Analyst Independence from Production (A System Safety Attribute: Controls). CASS auditor/analysts are in a separate department under QA.
Operational data collection and analysis assigned to a “CASS reliability group” that is contained within the engineering department. The CASS documentation is explicit that this certificate
Appendix 2 holder’s reliability program is not Federal Aviation Administration (FAA)-approved. The reliability group reports CASS information directly to the director of QA.
h. Policy Regarding Personnel Actions Resulting from CASS Findings/Results. Inadvertent errors will not lead to disciplinary action. Encourage full reporting and disclosure to facilitate system corrections. Certificate holder participates in the FAA Voluntary Disclosure Reporting Program (VDRP).
i. Surveillance and Analysis of Performance of Maintenance Program.
Audits Responsibility Director of QA.
Prioritization CASS board develops audit plan based on risk assessment.
Cycles The CASS board reviews its established audit plan annually. The CASS board completes onsite audits on a semiannual or biannual basis, depending on the risk assessment. Also depending on the risk assessment, some areas never receive an onsite audit assignment.
Scope All internal and third-party areas of maintenance.
Process CASS board developed audit checklists for use by auditors. Auditors conduct their audits in accordance with the annual plan. The CASS department receives reports of all maintenance-related events such as rejected takeoffs for analysis and use in risk assessment for audits. The CASS may schedule special audits as needed. Some vendors conduct their audits by document reviews, written questionnaires, and telephone followup, or combinations of these. If preliminary results raise concerns, you must followup.
Flow Initial reports and summaries to director of QA.
Analysis Responsibility Director of QA.
Perform preliminary root cause analysis Auditor/analyst.
Classify hazards/ perform risk assessment CASS board and analysts classify hazards and perform risk assessment.
Flow Director of QA reports summaries of all findings/initial analysis and details of issues to the CASS board for review and concurrence. CASS board transmits results to affected department, which forms corrective action team.
Appendix 2
j. Surveillance and Analysis of Effectiveness of Maintenance Program.
Operational Data Collection Responsibility Director of QA.
Prioritization Reliability group.
Scope Includes pilot reports, Engine Condition Monitoring (ECM), mechanical delays, teardown reports, and other data.
Process Modeled after FAA-approved reliability programs. Data collection oriented toward detecting trends, positive or negative, before occurrence of events. However, data collection (and analysis) may vary based on maintenance-related events. The CASS board formally reviews collected operational data sets every 2 years; initial list based on Advisory Circular (AC) 120–17, Maintenance Control by Reliability Methods; and CASS board determinations.
Flow Reliability group, although located within the engineering department, has a direct reporting relationship to the director of QA.
Analysis of Operational Data Responsibility Director of QA.
Prioritization Reliability group.
Process Analysis performed by technical experts within the reliability group;
includes preliminary determination of possible root causes or possible procedural changes.
Flow Results are reported to CASS board.
k. Corrective Action.
Final Root Cause Analysis Responsibility Director of QA.
Procedures CASS board transmits preliminary analysis results to the manager(s) of the affected department(s), who designates technical personnel to conduct final RCA with CASS auditor/analyst. CASS analyst oversees the process and ensures the RCA process, including human factors and systems analysis, is followed.
Use of specific analytical systems Internally developed formal analysis process or common industry tools.
Flow Technical department develops final report and submits it to the director of QA.
Appendix 2 Determination of Corrective Action Options Responsibility Director of QA designates corrective action team, led by primary affected technical department(s), whose manager(s) designates a team leader.
Procedures Risk assessment of the problem and the options. The CASS auditor/analyst or reliability group representative does not propose corrective actions but reviews possibilities for systems considerations and relevance to RCA.
Flow Team presents recommendation to CASS board.
Selection of Corrective Action and Corrective Action Plan Responsibility Director of QA.
Procedures Decision based on a priority for safety and regulatory compliance. Risk assessment is the basic tool to support the decision. CASS board verifies systems considerations and relevance to RCA.
Flow Depends on the level of the problem and the corrective action. Routine issues may be resolved at the team level with direct implementation by the affected area manager; advise the CASS board of this action. More significant program changes may require prior review and concurrence from CASS board or elevation to vice president of engineering and maintenance.
Followup Responsibility CASS board.
Procedures CASS auditor/analyst or reliability group, as applicable, assigned to develop a followup plan based on the seriousness of the problem.
Followup may include communications from a technical area verifying implementation, followup audits or data collection, and/or followup evaluation.
Flow Technical area manager reports to director of QA, who reports to CASS board.
NOTE: The above tables provide many examples of the system safety attributes: controls and procedures.
Appendix 2
l. Communications Between CASS and Other Personnel (A System Safety Attribute:
Interfaces).
Communication of Specific CASS Results and Actions Responsibility CASS board.
Procedures Audits based on updated checklists. Operational data are collected and stored in computerized database systems; some analysis and alerting features are automated. Audit and analysis results communicated through paper forms. Corrective action tracking through computerized database system.
Flow Through electronic mail communications and standard paper reports, information flows among CASS board, corrective action teams, technical areas, and the director of QA.
Communications with Maintenance Personnel Responsibility CASS board.
Procedures CASS training included for all personnel. Initial and recurrent training.
The certificate holder’s employee newsletter includes a brief monthly report on CASS results.
Flow CASS board works with training and company communications department, and receives feedback from managers and supervisors, particularly in maintenance areas.
Appendix 2 Interfaces (A System Safety Attribute: Interfaces) Responsibility CASS board.
Procedures Reliability group provides regular reports on analysis results, trends, and concerns regarding operational data.
Auditors/analysts provide regular reports on findings, analyses, trends, and concerns.
VDRP manager provides summaries of disclosures and proposed comprehensive fixes for CASS review and input.
To CASS Board Designated CASS auditor/analyst reviews reports and at least annually reviews maintenance-related Aviation Safety Reporting Program reports for consideration in setting audit and operational data collection priorities.
Feedback to technical areas regarding findings, trends, concerns and followup results.
Feedback to VDRP manager regarding proposed comprehensive fixes;
coordination with director of QA.
Monthly reliability analysis summaries and CASS summaries for distribution to vice president of engineering and maintenance; director of QA and other senior management; department managers in maintenance, flight and ground operations, IEP, and safety office; and FAA principal inspector (PI).
CASS reports reflect VDRP comprehensive fixes without detailing the initiating circumstances.
Copies of reliability reports and CASS summaries to FAA PI.
CASS board meeting minutes.
From CASS Board Semiannual summary report to CEO; copy to FAA PI.
Flow Communications channeled through director of QA.
m. Personnel Who Perform CASS Functions.
(1) Full-time auditors and analysts; in some cases, an auditor may also be an analyst.
(2) All members of the CASS board who have not participated in specific CASS training receive a total of 12 hours initial training covering CASS, root cause and systems analysis, and human factors.
How the Certificate holder Evaluates Its CASS (A System Safety Attribute — Process Measurement) Responsibility Vice president of engineering and maintenance.
Procedures IEP evaluates CASS annually.
Flow The CASS transmits IEP reports on CASS directly to the CEO and to the vice president of engineering and maintenance.
Appendix 3 APPENDIX 3. SAMPLE CASS FOR A SMALL CERTIFICATE HOLDER Type of Certificate Holder Fleet composition Two turbojet airplanes; Gulfstream G-III (12 seats).
Number of maintenance base and line stations Base station only.
Proportion of maintenance contracted to third parties A checks in-house; B, C, and D checks, all off-wing engine maintenance and all overhauls of engines, instruments, and avionics contracted out.
Scheduled or on-demand On-demand (Title 14 of the Code of Federal Regulations (14 CFR) part 135).
Size and structure of the maintenance organizations Maintenance organizational structure comprises of the Director of Maintenance (DOM) with chief inspector.
a. Continuing Analysis and Surveillance System (CASS) Management and Planning.
b. General Priority. This certificate holder prioritizes in the following general manner:
(1) Safe operations (air and ground).
(2) Detect and prevent noncompliance.
(3) Improve operating efficiency.
c. CASS Written Procedures (A System Safety Attribute: Procedures). CASS chapter in general maintenance manual. The CASS chapter includes specific procedures for root cause and systems analysis, and discussion of awareness of human factors.
d. CASS in the Certificate Holder Organization. Chief executive officer (CEO) actively participates in the CASS. CASS specifically appears on functional organizational flowchart.
e. Authority for CASS (A System Safety Attribute: Authority). The DOM (14 CFR part 119, § 119.65 DOM) has overall authority and responsibility for this air carrier’s maintenance program, including the CASS.
f. Responsibility for CASS (A System Safety Attribute: Responsibility). DOM heads CASS committee, which includes the CEO, chief inspector, and director of flight operations.
g. Policy for CASS Auditor/Analyst Independence from Production (A System Safety Attribute: Controls). DOM “borrows” auditors from within or outside the company based on auditor qualifications. Priorities are (1) independence from audited department and (2) experience or familiarity with the area to be audited. Every 5 years the company contracts an independent firm to conduct an outside evaluation of CASS and other certificate holder systems and programs to verify sufficient objectivity in the audits.
h. Policy Regarding Personnel Actions Resulting from CASS Findings/Results. Inadvertent errors will not lead to disciplinary action. Full reporting and disclosure encouraged to facilitate system corrections.
Appendix 3
i. Surveillance and Analysis of Performance of Maintenance Program.
Audits Responsibility DOM.
Prioritization CASS committee assigns priorities based on risk assessment.
Cycles The CASS committee establishes an audit plan and accomplishes onsite audits annually, depending on the risk assessment. Also depending on the risk assessment, some areas never receive an onsite audit assignment.
Scope All internal and third-party areas of maintenance.
Process CASS committee developed audit checklists for use by auditors, who may be committee members or personnel drawn from throughout the company. DOM receives reports of all maintenance-related events such as rejected takeoffs for analysis and use in risk assessment for audits.
Schedule special audits as needed. Vendors conduct their audits by document reviews, written questionnaires, and telephone followup, or combinations of these. Regulations require followup if preliminary results raise concerns.
Flow Initial results are reported to the DOM.
Analysis Responsibility DOM (conducts preliminary analysis with the auditor).
Perform preliminary root cause analysis Auditor/analyst.
Classify hazards/ perform risk assessment CASS committee.
Flow CASS committee reviews all findings/initial analysis and details of issues as deemed necessary by the DOM. The CASS committee acts as the core corrective action team (as required, other personnel may supplement this).