Considerations Related to Combined Airworthiness Organisation (CAO) Organizational Audit
A review carried out by SofemaOnline (www.sofemaonline.com)
Checklist for CAO Organisational Audit
While this checklist is presented as a “sample” of the areas which should be covered during an independent audit of a “small” CAO organisation - It will also serve to provide guidance as to the required scope of the Quality System for a non-small CAO Organisation
For every item it should be considered that this audit is against a “standard” it is a compliance audit - where there is no documented standard directly available from the regulations - The organisation should develop & document its own standard.
- Scope of work
a) Check that all aircraft under contract are covered in EASA Form 3-CAO.
b) Check that the scope of work in the CAE is consistent with EASA Form 3-CAO.
c) Check that no work has been performed outside the scope of EASA Form 3-CAO and the CAE.
d) Is it justified to retain in the approved scope of work aircraft types for which the organisation has no longer aircraft under contract?
- Maintenance data
a) Check that the maintenance data is present and up to date for the ongoing maintenance activity.
b) Check that no change has been made to the maintenance data from the design approval holder (DAH) without the DAH being notified.
- Equipment and tools
a) Check the availability of maintenance equipment and tools against the lists in the CAE and check if they are still appropriate with regard to the maintenance data.
b) Check tools for proper calibration (sample check).
- Stores
a) Do the stores meet the criteria of the CAE procedures?
b) Check by sampling some items in the store for the presence of proper documentation and any overdue items.
- Certification of maintenance
a) Has maintenance on products and components been properly certified?
b) Have implementations of modifications/repairs been carried out with appropriate approval of such modifications/repairs (sample check)?
- Maintenance contracted
a) Sample check of maintenance records.
b) Existence and adequacy of the work order.
c) Data received from the maintenance organization.
d) Valid CRS including any deferred maintenance.
e) List of removed and installed components and copy of the associated EASA Form 1 or equivalent.
f) Obtain a copy of the current approval certificate (EASA Form 3) of the maintenance organisations contracted.
- Maintenance subcontracted
a) Check that subcontractors for specialised services are properly controlled by the organisation.
- Relations with the owners/operators - maintenance
a) Has maintenance been carried out with suitable work orders?
b) When a maintenance contract has been signed with an owner/operator, have the obligations of the contracts been respected by both parties?
- Relations with the owners/operators - continuing airworthiness management
a) Has a contract (in accordance with Appendix I to Part-M or Appendix I to Part-ML) been signed with each external owner/operator, covering all the aircraft whose airworthiness is managed by the CAO?
b) Have the owners/operators under contract fulfilled their obligations identified in the contract? As appropriate.
c) Are the pre-flight checks correctly performed? (interview of pilots)
d) Is the technical log or equivalent correctly used (record of flight hours/cycles, defects reported by the pilot, identification of what maintenance is next due, etc.)?
e) Have flights occurred with overdue maintenance or with defects not properly rectified or deferred? (sample check from the aircraft records)
f) Has maintenance been performed without notifying the CAO (sample check from the aircraft records, interview of the owner/operator)?
- Maintenance records
a) Have the maintenance actions been properly recorded?
b) Perform a sample check of maintenance records (including EASA Form 1 or equivalent, and certificates of conformity) to ensure completeness and storage during the appropriate periods.
- Continuing airworthiness records
a) Perform a sample check of continuing airworthiness records to ensure completeness and storage during the appropriate periods.
b) Is the storage of computerised data properly ensured?
- Airworthiness review and permit to fly records
a) Perform a sample check of airworthiness review and permit to fly records to ensure completeness and storage during the appropriate periods.
- Airworthiness situation of the fleet
a) Does the continuing airworthiness status (AD, maintenance programme, life-limited components, deferred maintenance, ARC validity) show any expired items? If so, are the aircraft grounded?
- Aircraft maintenance programme (AMP) development and control
a) For Part-ML aircraft, ensure that the AMP has been approved by the CAO and has been subject to annual review.
b) For Part-M aircraft, check that all revisions to the DAH instructions for continuing airworthiness (ICA), since the last review, have been (or are planned to be) incorporated in the maintenance programme, unless otherwise approved by the competent authority.
c) Has the maintenance programme taken into account all modifications or repairs?
d) Have all maintenance programme amendments been approved at the right level (CAO, competent authority or indirect approval)?
e) Does the status of compliance with the maintenance programme reflect the latest approved maintenance programme?
f) How has the organisation managed:
I/ the tolerances (variations) to the AMP intervals?
II/ the deviations from the maintenance tasks to be performed in accordance with the AMP?
III/ Have the deviations from the DAH ICA in the development of the AMP been properly justified and recorded?
- ADs (and other safety measures mandated by the competent authority or EASA)
a) Have all ADs issued since the last review been incorporated into the AD status?
b) Does the AD status correctly reflect the AD content: applicability, compliance date, periodicity, etc.? (sample check on ADs)
- Modifications/repairs
a) Are all modifications/repairs listed in the corresponding status approved in accordance with M.A.304 or ML.A.304? (sample check on modifications/repairs)
b) Have all the modifications/repairs which have been installed since the last review been incorporated in the corresponding status? (sample check from the aircraft/component logbooks or equivalent)
- Personnel
a) Check that the current accountable manager and other nominated persons are correctly identified in the approved CAE.
b) If the number of personnel has decreased or if the activity has increased, check that the organisation has still sufficient and adequate staff.
c) Check that the qualification of all new personnel (or personnel with new functions) has been appropriately assessed.
d) Check that the staff has been trained, as necessary, to cover changes in:
I/ regulations
II/ competent authority publications
III/ the CAE and associated procedures
IV/ the approved scope of work
V/ maintenance data (significant ADs, ICA amendments, etc.).
- Occurrence reporting procedures
a) Check that reporting is properly performed, actions taken and recorded.
- Airworthiness review and permit to fly procedures
a) Have airworthiness reviews been properly performed and the airworthiness review certificate or recommendation been properly issued?
b) Have permits to fly been properly issued and the approved flight condition been complied with?
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