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8900.1 CHG 506

VOLUME 12  INTERNATIONAL AVIATION

Chapter 10  international field office PROCEDURES FOR CONDUCTING SAMPLING INSPECTIONS, FAA INDEPENDENT INSPECTIONS, AND PARTICIPATING IN an EU AVIATION AUTHORITY’S INTERNAL QUALITY AUDIT under the u.s./EU aviation safety agreement

Section 2  FAA Sampling Inspection System Team Conducting Sampling Inspections of EU-Based Approved Maintenance Organizations and Aviation Authorities

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12-590    REPORTING SYSTEM. Use Safety Assurance System (SAS) automation and the associated Data Collection Tools (DCT).

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12-591    OBJECTIVE. This section provides guidance to aviation safety inspectors (ASI) on how to participate on a Federal Aviation Administration (FAA) Sampling Inspection System (SIS) team. Per the U.S./European Union (EU) aviation safety agreement, also known as the Agreement, FAA SIS teams must sample the implementation of the Maintenance Annex in various EU member states affected by the Agreement. The team achieves this by sampling aviation authority (AA) compliance with the Agreement and by using a selection of Title 14 of the Code of Federal Regulations (14 CFR) part 145 repair stations as a product sample of the EU system. ASIs must use this section with the Maintenance Annex Guidance (MAG), Section A, Part II; however, the MAG supersedes this section if conflicts exist between the two documents.

NOTE:  See Volume 12, Chapter 10, Section 1 for background information regarding the MAG and the Agreement, which includes Annex 2, a maintenance annex. Both the MAG and the Agreement are available at http://www.faa.gov/aircraft/repair.

12-592    PREREQUISITES AND COORDINATION REQUIREMENTS.

A.    Prerequisites:

    Knowledge of 14 CFR parts 43 and 145;

    Successful completion of the Airworthiness Inspector Indoctrination course(s), or equivalent;

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

    Successful completion of training course 21058, Certification and Surveillance of Part 145 Stations, or equivalent;

    Successful completion of Web-based training course 27100066, Understanding the U.S./EU Aviation Safety Agreement;

    Knowledge of the Agreement; and

    Knowledge of the MAG.

B.    Coordination. This task requires coordination with:

    Approved Maintenance Organizations (AMO);

    The AA of the member state in which the AMO is located;

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    International Programs and Policy Division (AFS-50);

    FAA Coordinator (AFS-54);

    FAA Coordinator (IFO);

    Aircraft Maintenance Division (AFS-300); and

    European Aviation Safety Agency (EASA) Standardization Department.

12-593    REFERENCES, FORMS, AND JOB AIDS.

A.    References (current editions):

    Title 14 CFR Parts 43 and 145;

    Volume 2, Chapter 11, Certification of a Title 14 CFR Part 145 Repair Station;

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    Volume 10, Safety Assurance System Policy and Procedures;

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

    FAA Order 1350.14, Records Management;

    FAA Order 2150.3, FAA Compliance and Enforcement Program;

    The Agreement between the United States of America and the European Union on Cooperation in the Regulation of Civil Aviation Safety (the Agreement);

    Maintenance Annex Guidance Between the Federal Aviation Administration for the United States of America and the European Aviation Safety Agency for the European Union (the MAG); and

    Bilateral Oversight Board (BOB) decisions.

B.    Forms:

    FAA Form 8000-4, Air Agency Certificate;

    FAA Form 8310-3, Application for Repair Station Certificate and/or Rating;

    EASA Form 3, Approval Certificate;

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    Audit Report 1, FAA SIS Audit of an Aviation Authority (located in the MAG, Section A, Appendix 5);

    Audit Report 2, AA Recommendation of an FAA-Certificated AMO (located in the MAG, Section A, Appendix 6);

    Audit Report 3, SIS Audit of an FAA-Certificated AMO Located in the EU (located in the MAG, Section A, Appendix 8); and

    FAA Repair Station Operations Specifications (OpSpecs) in the Web-based Operations Safety System (WebOPSS).

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C.    Job Aids. Job aids are located in the MAG as Appendices.

D.    FAA Responsibilities. See Volume 2, Chapter 11, Section 11 for FAA Coordinator duties and responsibilities.

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12-594    SAMPLING INSPECTION PROCESS UNDER THE AGREEMENT. The FAA may inspect and sample AAs and AMOs holding a valid part 145 certificate as part of the sampling inspection in an EU member state listed in Annex 2, Appendix 2. The FAA Coordinator (AFS-54) and the International Field Office (IFO) manager will select countries and AMOs for a SIS inspection to visit during the calendar year using risk-based decision making tools, which include elements that target both AAs and AMOs.

A.    Identify AAs and AMOs Requiring a Sampling Inspection and Determine an Inspection Schedule. The selection criteria for a Member State’s AA may be performed per the MAG Section A, Part II, paragraph 4.3. Sampling inspections visits are based on an identified deficiency within the AA, IFO concerns, SIS Risk Decision Tools, or on the number and complexity of AMOs in the country. The SIS Risk Decision Tool is not all-inclusive, but it illustrates the main criteria used to help prioritize where high safety risks exist. The MAG contains additional guidance for determining risks and the SIS schedule.

1)    IFO management will provide a list of candidates and recommendations to the FAA Coordinator (AFS-54) based on identified risk. The FAA Coordinator (AFS-54) will develop a list of AAs for the FAA SIS team to visit during the calendar year using objective criteria and risk analysis, and will forward recommendations to the FAA National Coordinator (AFS-300) for concurrence. Upon AFS-300 concurrence, the FAA Coordinator (AFS-54) will coordinate with the EASA Standardization Coordinator, IFO management, and the FAA Coordinator (IFO) assigned to the specific member state.

NOTE:  The IFO management will designate an ASI as an FAA Coordinator (IFO).

2)    The FAA Coordinator (IFO) will coordinate with IFO management and the AA representative of the Member State to confirm the dates and locations, such as field offices or Regional Offices (RO) of the visit. The FAA Coordinator (IFO) will notify the AA to prepare, or make available to the FAA SIS team, previous AA surveillance reports for Level 1 and Level 2 findings for the selected AMOs. The FAA Coordinator (IFO) shall distribute the coordinated planning schedule to the FAA Coordinator (AFS-54) and IFO management.
3)    The FAA Coordinator (AFS-54) sends the schedule to the EASA International Standardization coordinator per the MAG, Section A, Part II, paragraph 4.4. The FAA Coordinator (AFS-54) will also provide a copy of the schedule to AFS-300.

B.    Accomplish the Inspection. The SIS inspection should focus on the FAA special conditions and any identified risk or trends.

1)    Use the SIS Audit Report 1 for the AA SIS inspection.
a)    Sample the AA surveillance reports for Level 1 and Level 2 findings at AMOs that hold a valid part 145 certificate for trend analysis and risk assessment of previous findings.
b)    The most recent AA documented recommendation of the AMO as listed on the Audit Report 2 should be used with the guidance in the MAG, Section A, Part II, paragraph 4.5 to verify the AA recommendation for the renewal inspection.
2)    Use the SIS Audit Report 3 for the AMO SIS inspection.
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C.    Record the Findings Per the MAG. Use the appropriate SIS forms to record any discrepancies or identified items.

1)    Use the SIS Audit Report 1 for the AA SIS inspection. Enter all AA discrepancies or identified items recorded on the SIS Audit Report 1.
2)    Use the SIS Audit Report 3 for the AMO SIS inspection.
a)    Enter all discrepancies or identified items recorded on the SIS Audit Report 3 into SAS as an element Dynamic Observation Report (DOR) or other DOR.
b)    Complete the Analysis, Assessment and Action (AAA) for each SAS DCT assessment.
c)    Track open findings in the Action Item Tracking Tool (AITT).
d)    Upload all SIS forms into SAS and file all supporting paperwork in the office file for the certificate holder.

D.    Closeout Actions. The IFO will work with the applicable AA to ensure corrective actions will resolve any identified risks. Conclude the inspection by taking the following actions:

1)    Prepare for the AMO Debriefing. The FAA SIS team and the AA representatives will meet to present their findings and recommendations prior to debriefing the AMO management. Refer to the MAG, Section A, Part II. At the meeting, the FAA and the AA should agree on a timeframe for the AMO to provide the AA with the required corrective action or a corrective action plan (CAP). The AA representatives should clearly understand the procedure for the AA to forward corrective action documents, with AA comments and recommendations, to the FAA.
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2)    Debrief the AMO. After completing each AMO inspection, the FAA SIS team and the AA will debrief the AMO on findings and provide a copy of the signed form (SIS Audit Report 3). The AMO will correct the findings per the MAG, Section A, Part II.

NOTE:  The FAA SIS Team must inform the AMO in writing of the identified items listed on the SIS Audit Report 3 form and provide the required timeframe for corrective action to be taken. The AMO must forward all corrective action or CAPs to the AA for review.

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3)    Debrief the AA Office. The FAA SIS team must debrief the local AA office and/or AA headquarters (HQ), with its management in attendance, on the results of the inspections. The briefing should summarize all findings or identified items recorded during the SIS inspections. Before leaving, the FAA SIS team should provide the AA with a signed copy of the form (SIS Audit Report 1).
4)    Acceptance of Corrective Actions of AMO. Once the AA has reviewed and forwarded the corrective action of the SIS discrepancies (SIS Audit Report 3) to the FAA Coordinator (IFO), the FAA SIS Team Lead will review the corrective actions. The SIS Team Lead will provide written correspondence to the AA indicating the corrective action to the identified items found during the AMO SIS inspections are acceptable and closed.
5)    Acceptance of Corrective Actions of AA. Once the AA has forwarded the corrective action of the SIS discrepancies (SIS Audit Report 1) to the FAA Coordinator (IFO), the FAA SIS Team Lead will review the corrective actions. The SIS Team Lead will provide written correspondence to the AA indicating the corrective action to the identified items found during the AA SIS inspections is acceptable and is closed out.

E.    Fees. The FAA cannot charge any fees associated with a SIS inspection or expenses associated with enforcement actions. This is due to the FAA not providing any services per 14 CFR part 187, such as certification and approvals, during a SIS or enforcement. The current edition of Advisory Circular (AC) 187-1, Flight Standards Service Schedule of Changes Outside the United States, lists the fee services.

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12-595    ENFORCEMENT, SAMPLING INSPECTION REPORTS, AND ANNUAL SUMMARY REPORTS.

A.    Possible Follow-Up Actions Regarding Safety Concerns.

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1)    After completing the sampling inspection, the FAA SIS team may need to identify compliance concerns involving safety issues. The FAA SIS team will notify the member state’s FAA Coordinator (IFO) and the FAA Coordinator (AFS-54) of any concerns. The FAA Coordinator (IFO) may contact the AA and request a meeting with AA management to discuss possible added joint inspections to satisfy the FAA SIS team’s concerns. Per findings developed by EASA, a Level 1 finding is any significant noncompliance with a Member State’s part 145 requirement which lowers the safety standard and seriously impairs flight safety. A Level 2 finding is a noncompliance with the part 145 requirements which could lower the safety standard and possibly affect flight safety.
a)    Level 1 findings require immediate action by a competent authority to revoke, limit, or suspend the AMO’s approval in whole or in part, depending upon the extent of the Level 1 finding, until the AMO has taken successful corrective action.
b)    Level 2 findings require a CAP appropriate to the finding but must not initially exceed three months to complete. In certain circumstances and subject to the finding, the AA may extend the three‑month period if the AA agrees to a satisfactory CAP. The AA must partially or totally suspend the approval if the AMO does not comply within the timescale granted by the AA.
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2)    Annex 2, paragraph 4.7 indicates that the FAA may conduct independent inspections of AMOs to address specific safety concerns, per Article 15.B of the Agreement. In this case, the FAA must inform the AA and inform EASA (either directly or through the AA) that the FAA will make such inspections. The FAA must inform the AA and EASA a maximum of 15 days after the independent inspection took place. The FAA will bill the AMO for all FAA independent inspection fees involving certification or approvals under AC 187-1.
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B.    Enforcement Policy. Annex 2, paragraph 7.3 indicates the FAA may recognize the corrective action of the AA without additional FAA action. The FAA may close this type of finding as “no action required,” but the IFO must retain a record of the findings and corrective action for future reference. When the FAA SIS team notes a significant finding, such as a safety of flight issue, the FAA will process the action per the MAG, Section A and Order 2150.3.

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C.    Preparing the Final Sampling Inspection Report. The FAA SIS team will prepare a final sampling inspection report of the AAs and AMO(s) and send it to the FAA Coordinator (AFS-54). The final sampling inspection report must contain:

1)    The names and addresses of the AMOs and the member states visited;
2)    The names, positions, and office addresses of the FAA ASIs and AA inspectors involved;
3)    The AA office holding the AMO’s certificate;
4)    The areas inspected and a list of findings; and
5)    The agreed-upon timeframe for the AMO’s corrective action or CAP.
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NOTE:  The FAA SIS team will send a copy of the sampling inspection forms to the FAA Coordinator (AFS-54) and to the FAA National Coordinator (AFS-300).

D.    Annual Country Summary Report. Each September, the FAA Coordinator (AFS-54) will develop and provide an annual summary of sampling inspections and findings and forward the summary report to AFS‑300. The summary report will include:

1)    A list of all AMOs inspected and their certificate numbers;
2)    A list of all AA offices inspected;
3)    The areas inspected and a list of findings. This may be a chart identifying the number of findings in each area;
4)    The timeframe for corrective action or indication whether the AMO completed the corrective action;
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5)    Recommendations to revise the policy or procedures associated with the MAG;
6)    A listing of any FAA independent inspections; and
7)    Trends or significant safety concerns.

12-596    TASK OUTCOMES. Follow SAS guidance for Modules 4 and 5 for data collection, reporting and principal inspector (PI) analysis, actions and tracking of CAPs in the AITT.

A.    Analyze Findings. Follow SAS guidance for Module 5.

B.    Document the Task. The ASI will file all supporting paperwork in the office file for the certificate holder and/or the AMO. For SIS reports and other pertinent written communication with the AA, each IFO will establish an office file for each AA in the IFO’s area of jurisdiction. The IFO will retain all such communication in its AA file per Order 1350.14.

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12-597    FUTURE ACTIVITIES. Follow the MAG procedures and SAS guidance in Volume 10 to plan future risk-based surveillance in SAS.

RESERVED. Paragraphs 12-598 through 12-609.