9/13/18

 

8900.1 CHG 620

VOLUME 12  INTERNATIONAL AVIATION

Indicates new/changed information.

Chapter 6  IFO PROCEDURES FOR CONDUCTING SAMPLING INSPECTIONS OF FAA‑CERTIFICATED REPAIR STATIONS LOCATED OUTSIDE THE U.S. UNDER AN AVIATION AUTHORITY BASA/MIP

Section 1  Safety Assurance System: Sampling Inspection System Team Inspection of a Foreign Aviation Authority and Repair Stations Under a BASA/MIP

12-472    REPORTING SYSTEM. Use Safety Assurance System (SAS) automation and the associated Data Collection Tools (DCT).

12-473    OBJECTIVE. This section provides guidance to aviation safety inspectors (ASI) on conducting Federal Aviation Administration (FAA) Sampling Inspection System (SIS) Team inspections at Title 14 of the Code of Federal Regulations (14 CFR) part 145 repair stations located in a foreign country under Maintenance Implementation Procedures (MIP) of a Bilateral Aviation Safety Agreement (BASA). SIS teams must sample the implementation of a MIP by sampling foreign aviation authorities (AA) and part 145 repair stations.

NOTE:  ASIs must use this section in conjunction with the applicable Maintenance Agreement Guidance (MAG) of the foreign country. However, the MAG supersedes this section if conflicts exist between the two documents.

12-474    BACKGROUND.

A.    Conclusion of a U.S. MIP. The FAA and the AA base MIPs on an evaluation of 14 CFR parts 43 and 145 and the AA’s national 145 regulations governing Approved Maintenance Organizations (AMO). The SIS allows the FAA and the AA the ability to inspect each other’s application of the MIP. The SIS benefits the FAA, the AA, and the certificate holder in understanding the differences between part 145 and the relevant foreign AA’s national part 145 regulations and any procedural differences associated with implementation of the MIP. The conclusion of a MIP provides for:

1)    The mutual acceptance of recommendations for certificating, renewing, or amending the certificate, and the documentation of surveillance of part 145 maintenance organizations.
2)    Increased efficiency by reducing or eliminating duplicate surveillance and inspections while maintaining equivalent levels of safety (ELOS).
3)    Building confidence in each other’s internal quality control systems.

B.    The MAG Document. The MAG is the procedural document that supports the MIP and defines the Special Conditions and activities as agreed upon by the FAA and the AA. The FAA and AA must be satisfied that the certificate holder meets the conditions of the MIP and MAG.

NOTE:  A listing of all countries that have a BASA with applicable MIPs and MAGs is located at http://www.faa.gov/aircraft/air_cert/international/bilateral_agreements/baa_basa_listing/.

C.    Special Conditions. Special Conditions are requirements in either parts 43 and 145 or in the AA’s national part 145 regulations that have been found, based on a comparison of the regulatory maintenance systems, not to be common to both systems and which are significant enough that they must be addressed. A part 145 certificate holder that performs work on aeronautical products subject to a MIP must comply with the AA Special Conditions. The AA surveillance must include the FAA Special Conditions as outlined in the applicable MIP.

12-475    PREREQUISITES AND COORDINATION REQUIREMENTS.

A.    Prerequisites:

    Knowledge of parts 43 and 145 and the applicable MAG.

    Previous experience with certification or surveillance of part 145 repair stations.

    Successful completion of FAA Course FAA21058, Certification and Surveillance of Part 145 Stations, or equivalent.

    Completion of training/briefings on the applicable MAG, or equivalent.

A.    Coordination. This task requires coordination with:

    The certificate holder.

    The AA of the country in which the certificate holder is located.

    Aircraft Maintenance Division (AFS-300).

    International Field Management Branch (AFS-54).

    International Field Office (IFO).

12-476    REFERENCES, FORMS, AND JOB AIDS.

A.    References (current editions):

    Title 14 CFR Parts 43 and 145.

    FAA Order 8130.2, Airworthiness Certification of Aircraft.

    Volume 2, Chapter 11, Certification of a Part 145 Repair Station.

    Volume 10, Safety Assurance System Policy and Procedures.

    Volume 14, Chapter 1, Section 2, Flight Standards Service Compliance Action Decision Procedure.

    The Applicable MIP and MAG.

A.    Forms:

    SIS Form for inspecting the foreign-based repair stations (refer to the MAG, Section A).

    SIS Form for inspecting the AA (refer to the MAG, Section A).

    AA surveillance/inspection reports, and AA recommendation for FAA certification/renewal/amendment.

B.    Job Aids. Job aids are included in the MAG as appendices.

12-477    GENERAL. SIS Team inspections establish open communication and continued confidence in the ability to comply with the requirements of the MIP and to ensure consistent application of the MAG with emphasis on FAA Special Conditions.

A.    Focus of the SIS Team Inspection.

1)    The SIS Team will spend a considerable amount of time at the AA’s office reviewing records/files and enforcement actions taken by the AA. The SIS Team may also interview AA inspectors and their assistants to confirm they have access to and knowledge of the applicable MAG.
2)    The SIS Team will also inspect repair stations, specifically the FAA Special Conditions and those areas referenced in the FAA supplement. The SIS Team may visit selected repair stations and inspect methods and procedures used in maintaining U.S.-registered aircraft, foreign-registered aircraft operated under provisions of 14 CFR part 121 or 135, or articles for use on these aircraft.

NOTE:  The SIS Team may also inspect the part 145 regulations that were determined equivalent under the MIP but were not listed as Special Conditions. However, the SIS Teams normally limit inspections to the Special Conditions unless events lead them into additional areas. Communicate discrepancies that are uncommon to the FAA Special Conditions to the FAA Coordinator (AFS‑54).

B.    Unimpeded Access. The FAA and the AA will assist each other in gaining unimpeded access to the certificate holder subject to its jurisdiction. If the certificate holder requires additional information because of security issues, the AA should promptly notify the FAA to provide additional information. It is the responsibility of the certificate holder to provide unimpeded access to the FAA to all work areas having civil aviation application under part 145. The certificate holder should ensure that, where possible, there is clear delineation between work areas with civil and military applications.

C.    Resolution of Issues. Joint cooperation and communication is an essential part of the inspection’s success. Resolution of issues between the FAA and the AA will be made in accordance with the applicable MAG.

12-478    FAA RESPONSIBILITIES. See Volume 2, Chapter 11, Section 12 for additional duties and responsibilities of the FAA Coordinators.

A.    IFO Responsibilities. The following are responsibilities for the IFO to conduct a SIS inspection:

1)    The IFO manager designates an ASI as the FAA Coordinator (IFO) for each country with a MIP with the United States.
2)    The IFO manager assembles the SIS Team based on experience, qualifications, training, and available resources. The FAA Coordinator (IFO) of the applicable country should be the SIS Team Lead.
3)    The IFO must provide a list of certificate holders based off identified risks and must provide SIS recommendations to AFS-54.

B.    International Field Management Branch-FAA Coordinator (AFS-54) Responsibilities. The following are responsibilities of the FAA Coordinator (AFS-54) with countries under a BASA/MIP:

1)    Management will assign FAA Coordinators (AFS-54) to support the IFOs with BASA/MIP responsibilities.
2)    Develop a list of the AAs and certificate holders for the SIS Team to visit during the calendar year using objective criteria and risk analysis.
3)    Forward SIS recommendations to AFS-300 for concurrence.
4)    Forward the finalized SIS schedule to the AA coordinator per the MAG, Section A. Provide a copy of the schedule to the FAA National Coordinator (AFS-300).
5)    Coordinate with the IFO to ensure SIS corrective actions are properly closed according to the timeframe in the applicable MAG.
6)    Forward the accepted corrective action documents to the FAA National Coordinator (AFS-300).

C.    FAA Coordinator (IFO) Responsibilities. The following are responsibilities of the FAA Coordinator (IFO) in regards to conducting the SIS Team inspection in accordance with the applicable MAG procedures.

1)    Provide AFS-54 recommendations for selecting certificate holders for SIS inspections.
2)    Coordinate with the AA representative to confirm the dates and locations of the visit. Ensure the AA prepares or makes available the surveillance records for FAA certificate holders with part 145 approval.
3)    Coordinate the finalized planning schedule with AFS-54.
4)    Ensure the SIS Team findings are documented on the appropriate forms.
5)    Coordinate with the team to ensure SIS corrective actions are closed according to the timeframe in the applicable MAG.
6)    Ensure written correspondence is provided to the AA for closure of the SIS.
7)    Forward copies of the correspondence with the corrective action to AFS-54.

12-479    SIS TEAM INSPECTION PROCESS UNDER THE MIP. The SIS Team inspections verify that the AA is following the guidance provided in Sections A and C of the MAG. The SIS Team verifies that the AA is using an equivalent oversight system in managing and planning surveillance. The SIS Teams will conduct sampling inspections per the applicable MAG, Section A.

A.    Identify the AAs and Certificate Holders Requiring Sampling Inspections. The selection criteria for performing a SIS Team inspection within a MIP country is based on identified deficiencies within the AA, certificate holders’ deficiencies, IFO concerns, SIS Risk Decision Tools, or on the number and complexity of repair stations in that country. The SIS Risk Decision Tool is not all-inclusive, but it illustrates the main criteria used to help prioritize where high safety risk exists. The SIS Team inspection should be flexible enough to account for resource availability and scheduling constraints.

B.    AA SIS Inspection. The SIS inspection should focus on the FAA Special Conditions and any identified risk or trends.

1)    The SIS Team should conduct an in-briefing to the AA. The briefing will cover the purpose of the inspection, any recent changes in the MAG, lessons learned, and documentation and corrective actions procedures.
2)    Perform and document the SIS inspection on the AA in accordance with the applicable MAG.
3)    Coordinate with the AA to ensure it has resolved any discrepancies or identified items discovered during the AA SIS inspection. The AA must document and forward the corrective actions to the FAA Coordinator (IFO) for acceptance.

NOTE:  Identified discrepancies of the AA not meeting the MAG procedures can be documented using Program Tracking and Reporting Subsystem (PTRS) codes 3272/5272. The ASI should add an appropriate comment to record the AA actions.

C.    Repair Station SIS Inspection. The SIS inspection is to sample the AA surveillance standards and should focus on the FAA Special Conditions. The SIS Team ensures the AA is applying the MIP in a consistent manner and the certificate holder understands and follows the procedures associated with the MIP and the MAG.

1)    The SIS Team will conduct an in-briefing with selected certificate holders. The in-briefing will cover the purpose for the SIS inspection, corrective action process, and any follow-up actions. Instructions for conducting briefings are located in Volume 1, Chapter 3, Section 1.
2)    Perform the SIS inspection of the certificate holder in accordance with the applicable MAG.
3)    The certificate holder must forward all corrective actions or corrective action plans (CAP) to the AA for review.
4)    The AA must document any necessary follow-up actions and forward the certificate holder’s corrective actions to the FAA Coordinator (IFO) for acceptance.

D.    Document the SIS Inspections. Use the SIS forms in the applicable MAG to record any discrepancies or identified items.

1)    Identify any systemic findings, trends, or heightened safety concerns. Communicate these risks to the IFO management and the FAA Coordinator (AFS-54).
2)    Ensure the SIS forms are fully completed per the MAG.
3)    The SIS Team Lead inspector must provide the FAA Coordinator (AFS-54) copies of the SIS forms and allotted timeframes for corrective action.

E.    Fees. The FAA cannot charge any fees associated with a SIS inspection. Fees may only be charged if the FAA provides services (certification/authorization/inspection/approval). These services are not provided during a SIS inspection as agreed upon under the MIP.

12-480    ANNUAL SUMMARY REPORT. Each September, the FAA Coordinator (AFS-54) will develop and provide an annual summary of sampling inspections and findings to AFS-300. The summary report will include:

    The total number of sampling inspections of certificate holders and their certificate numbers;

    A list of all AA offices inspected;

    Trends or significant safety concerns;

    Timeframes for corrective action, or indication whether the certificate holder completed the corrective actions;

    Recommendations to revise policy or procedures associated with a MAG; and

    A listing of any FAA independent inspections.

12-481    TASK OUTCOMES.

A.    Conduct Debriefing. The SIS Team will work with the AA to ensure corrective actions resolve any identified risks. Conclude the inspection by taking the following actions:

1)    Prepare for the certificate holder debriefing.
a)    The FAA SIS Team and the AA representatives will meet to present their findings prior to debriefing the certificate holder’s management.
b)    The FAA and the AA should agree on a timeframe for the certificate holder to provide the AA with the required corrective actions or CAP within the allotted MAG timeframe.
2)    Debrief the certificate holder.
a)    After completing each inspection, the SIS Team and the AA will debrief the certificate holder on the identified items.
b)    The debriefing will ensure the certificate holder understands the identified items and the corrective action procedures and allotted timeframes. The certificate holder must forward all corrective actions or CAPs to the AA for review.

B.    Compliance and Enforcement Action. When the SIS Team notes a significant finding, such as a safety of flight issue, the FAA may process the action per the MAG, Section A. Investigate and gather the facts that led to any identified deficiencies. When debriefing the certificate holder, share information, discuss the facts, and identify the underlying root causes that led to the deficiencies. Review the certificate holder’s corrective actions and evaluate their effectiveness. Follow the process contained in Volume 14, Chapter 1, Section 2 to determine the appropriate FAA action.

1)    Compliance Action is the primary means of addressing safety concerns and regulatory noncompliance.
2)    Enforcement action is formal administrative and legal action taken when necessary.

C.    Closeout Actions. The FAA Coordinator (IFO) may work with the applicable AA to ensure that corrective actions will resolve any identified risks. The FAA Coordinator (IFO) may contact the AA and request a meeting with AA management to discuss possible added joint inspections to satisfy the SIS Team’s concerns. Conclude the inspection by taking the following actions:

1)    The SIS Team will review the certificate holder’s corrective actions, and if acceptable, inform the AA in writing the certificate holder’s corrective actions are acceptable for closure.
2)    The SIS Team will review the AA’s corrective actions, and if acceptable, inform the AA in writing the corrective actions are acceptable for closure.
3)    The SIS Team Lead will forward a copy of closure correspondence to the FAA Coordinator (AFS‑54).
4)    The FAA Coordinator (AFS-54) will provide a copy of the discrepancies and accepted closure correspondence to AFS-300.

D.    Complete the Task. Follow Volume 10 SAS guidance for Module 4 (Chapter 5) for Data Collecting and Data Reporting. Upload SIS documents supporting your “Inspector Actions Taken” into the DCT.

1)    Enter all discrepancies or identified items recorded on the certificate holder into SAS as an Element Dynamic Observation Report (DOR) or Other DOR.
2)    Principal inspectors (PI) follow Analysis, Assessments, and Action procedures for Module 5 (Chapter 6) and upload supporting documents for your actions into the Action Item Tracking Tool (AITT). File any required supporting paperwork in the certificate holder’s office file.
3)    Update the Vitals Information tab in the SAS Configuration Module, as required.
4)    SIS reports, schedules, and other pertinent written communication with the AA must be retained in an office file for each country under a MIP.

12-482    FUTURE ACTIVITIES. Follow the MAG procedures and Volume 10 SAS guidance to plan future risk‑based surveillance in SAS.

RESERVED. Paragraphs 12-483 through 12-496.