That time of year again.......audit time!

[qa guy]

I am starting the annual internal audit for the company, and find it ridiculous that our manual states we will also audit our sub contracted AMO's. These include the engine overhaul shop, avionics shop, prop shop, and welding. This work is all sourced out. They are all approved AMO's doing their own internal audits (as well as external from T.C) Why do I have to send them the same questionaire every year?
Does anyone else out there do this as part of their internal audit?

[iflyforpie]

Yeah it's audit time for me too.

To answer your question, no we don't audit outside AMOs/Vendors. We just have to audit all the activities our MPM covers. TC is impressed that we even do internal audits and action findings.

Another smaller AMO I worked at didn't do internal audits at all and all TC said was "you guys really should do internal audits, it's in your MPM after all".

[bombardierfixer]

I'm no expert but I beleive that everyone has to do that. We were audited all the time, my favorite is when a "potential" customer would come in to do a audit and everyone runs around like monkeys cleaning up. The funny thing was though you know they would never show up they just had you on their list of AMO's that they would use, we were just after "honest ricky's AMO and haircare salon". You just send a questionaire or do you call and give them a heads up before your walk around?

[qa guy]

Another smaller AMO I worked at didn't do internal audits at all and all TC said was "you guys really should do internal audits, it's in your MPM after all".

[/quote]

Really? I dont thnk our inspector would take it that well.
A few years ago we got written up for not having records of previous audits. We need to keep at least the last two.

[iflyforpie]

We don't even really get TC audits anymore. One of my findings last year was the absence of the previous year's audit (turns out it was on the desk under a huge pile of paper). TC came by for an 'inspection' (basically just a risk assessment of the AMO) and just said 'good finding' and were on their way.

Probably they are more relaxed because we're just light GA. Working for bigger companies and their MPMs just chocked full of self-imposed red tape, TC seemed to be a little harsher.

[GAC]

I have sent out audit questionnaire to some of the larger third party repair station in the States mainly to ensure that they meet the requirement of the MIP.
I had also audited a calibration/component shop before and found that they did know what they were doing and did not have calibrated test standards.

[qa guy]

We don't even really get TC audits anymore. One of my findings last year was the absence of the previous year's audit (turns out it was on the desk under a huge pile of paper). TC came by for an 'inspection' (basically just a risk assessment of the AMO) and just said 'good finding' and were on their way.

Probably they are more relaxed because we're just light GA. Working for bigger companies and their MPMs just chocked full of self-imposed red

tape, TC seemed to be a little harsher.

I think they are focussing more on SMS right now. We are GA as well; an FTU. But a few years ago T.C. audits were almost annually.
Has anyone taken measure to comply with 406 ELT requirements yet? Our company does not seem to be in a rush, and wants to take advantage of the 2 year phase in period......I think this is a bad idea! With the major increase in training hours, there seems to be an increase in incidents as well.....with us anyways. Anyone else out there seeing an increase in incidents?

[iflyforpie]

Yup, TC audits were annually or at least semi-annually for us too a few years ago. Then they brought in this 'risk assessment' thing because they don't have enough inspectors to go around. But since we haven't had any incidents/accidents yet and have low employee turnover we are low risk.

As for 406, we aren't in a rush either. We figure by waiting they might change the rules again. The 406 isn't going to prevent the plane from crashing and the 121.5 will still work for SAR purposes.

The best solution is to have students file and follow flightplans, give accurate and frequent position reports, and have an accurate operational flight plan that is closely monitored at the base.

We have live GPS tracking on our planes which IMO is more effective as doing wildlife telemetry or fire patrols, we are going all over the place.

[qa guy]

we are trying flight following as well. The problem is how do you distinguish an airplane that has crashed, to one that has stopped for lunch? Also, do the regs not require a sell activating ELT? I think this is the reason personal ones are not acceptable . Even though a company would be in compliance for 2 years, how do you justify not having the required equipment if an accident/incident were to arise?

[iflyforpie]

Well, you can't tell if a plane has crashed with live GPS, but if it is stopped over a mountain, lake, or some other non airport like feature it's time to pay attention. It can be caused by intermittent power or signal as well, but if something has gone wrong we will at least know where to start looking.

The GPS tracking will not satisfy the requirements for a 406 ELT so before it becomes law we will have to get them. It is for our piece of mind right now (and a ministry of forests requirement).

If an incident were to arise:
-We are meeting the current standards by having a 121.5 ELT in the aircraft.
-We are exceeding the current standards by having a live GPS tracking system in the aircraft.

Like I say, 406 ELT's aren't going to prevent a crash and if you believe everything COPA is ranting about they aren't any better than 121.5 ELTs. SARSAT won't track 121.5 anymore but any sap flying anything from a bugsmasher to a 747 can hear it on their VHF. Can't say the same thing about a 406.

[ettw]

Ah yes, the external audits.

I never did one but I did keep on file a copy of the AMO certs of the suppliers/facilities we dealt with and a 1 page questionaire that basically made them tell me that they were in compliance with their respective manuals and the date of their last internal audit. Our TC guy felt that it was nutso to expect that a small operator dealing with 10 or 15 different suppliers of parts and maintenance could possibly complete external audits in any other way than I was doing it.

I was always suprised to hear from my TC PMI how many other operators were not doing internal audits. I never understood that. How can you be sure you're doing it right if you don't look closely to find what you're doing wrong.

It was also their opinion that if you found something in your audits and could show short and long term corrective action plans along with the follow up sample audit at 90 days or so then it was off the table during their audits.

The one thing my PMI pointed out regarding audits is that they don't have to be completed all at once. You can do them as a phase item. Break it up into 12 chunks and complete each part as you move along thru the year. There are 2 benefits to this style of audits I think. First, it takes alot of time to do a full annual audit all in 1 block and 2, it helps to prevent those little things from getting away from you over a year that result in a big deal. Maybe you're auditing the tech library and in the process realize that you're not infact in compliance with your calibrate tools control policy (I just made that one up for example).

I liked the rationale behind it but never did implement it as a policy before I left maintenance management and QA.

Cheers,

ETTW

[qa guy]

Thanks to all for the informative replies. I think for this year I'll just send the stupid things out again. I guess it's not much to ask of these companies to fill out a 1 page questionaire, for all our business throughout the year.

[snoman]

Come on! Lot's of organizations are approved, but wouldn't you want to see for yourself what these operations are like? Sending out a little questionaire is only going to be handed off down the pion line where it will be filled out and sent back as fast as possible with the least effort to be truthful. Don't you want to know if these places are good shops and up to snuff doing great work, or do they have some serious deficiencies that are a cause for concern in your dealings with them. You should work within your reasonable time line, but you should go pay a visit at least to the place that does the most work, or the most important. Or visit one once a year...

One thing that drives me nuts is QA systems that only go through the motions to satisfy the regs. How about a Quality Assurance program that goes beyond satisfying the minimum, one that is progressive and effective. I think there is so much potential for the QA systems in a company to take a maintenance department to the next level of performance and safety standards.

Just my thoughts...

[lupin]

Is it just me or is the SMS process a farce? I mean lets face it.... self audits??? Most small operators I have worked for were cutting corners left right and center prior to sms implementation, if they now know transport Canada will not be dropping by, I can't imagine how far they will push things... Sounds like the wolves are babysitting the sheep....

The people making the decisions in small AMOs are usually the owners.... They have to make business decisions to insure the survival of their business.... Faced with a decision of bending the rules in order to get ahead or adhering to the regulations, which path will they choose?

Éric

[bombardierfixer]

Not to be overly sarcastic to snoman, just because I agree, but in my experiance that is unfortunatly just a dream, and its only going to get worse due to the economic situation facing us. Any long tern stratagies are going to be shelved to make that extra buck. SMS is a bad way to go but it won't change until a ditch is dug with a aircraft.

[snoman]

Well, I don't think it's much of a pipe dream myself, I think changes small and big are quite do-able, but there has to be a progressive attitude within a company that wants to self-improve without feeling that the regulator has to be hovering for it to happen. I don't think that the economy has anything to do with it, but as long as the old-school attitudes towards operating prevail, it will never change. I see it time and again... the old lets give them something easy to find so they won't dig any deeper; lets not change anything, because TC might not like it; lets just fix our findings with short term resolutions because it's easier to fix this bit than change our procedures so it doesn't happen anymore... I see that mentality as rediculous, unnecessary and obsolete.

It seems that there is nothing but resistance to change, even though it's probably the best thing for a lot of places. It really is disappointing.

[qa guy]

Sno I do agree with most of what you express. Improvements start with an open mind and pro-active approach. And that comment about [b]leaving something for the auditors to find[/b] makes my blood boil like an overcharged battery.

Now I can see if I run an FTU and am contracting out my maintenance, clearly I need to know how this shop runs. My point is these companies are our overhaul and support shops.Also they are some of the biggest in the country who have a whole team of QA guys.
I think it would be a good idea to pop-in one day, get a tour of the shop, at the very least meet some people and improve the business relationship. Im just not so sure my DOM will go for it though. We'll see.