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INTERNAL EVALUATION PROGRAM
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Introduction
The concept of the QIT Consulting Internal Evaluation
Program is based on the premise of verifying compliance with safety
regulations in accordance with FAA HBAT 99-19 and Advisory Circular
120-59.
It also ensures that safe operating practices
are a responsibility shared by each functional department within
the airline. The incorporation of internal evaluation techniques
into functional department operating practices will enhance the
ability to detect system weaknesses that can result in an unsafe
condition. In addition, the internal evaluation concept fosters
improvement on a continuing basis, rather than in response to an
inspection finding from an outside source.
The Internal Evaluation Program is not intended
to replace other regularly scheduled company audit functions or
result in a reduction of normal FAA surveillance programs.
Scope and Approach
The internal evaluation program includes all major
functional departments involved in the airlines airworthiness, flight
and ground operations programs. These departments are Flight Operations
Line, Flight Operations Technical, Inflight, Field Services, QIT
Consulting Training Department, (AETD), Flight Safety Department,
System Operations Control, (SOC), and Crew Scheduling. Specific
topics covered include applicable Federal Aviation Regulations (FARs)
and FAA mandated publications and operations specifications.
The internal evaluation method focuses on allowing
the functional manager to detect and correct deficiencies that can
affect safety or result in FAR compliance problems. All departments
will be required to complete the internal evaluation annually, note
any findings, and take the corrective action. At the specified interval,
an “Internal Evaluation Finding Report” will be made which provides
a summary of departmental findings and progress in their resolution.
Evaluation Benefits
A thorough and well supported internal evaluation
program provides several benefits, some of which are: It enables
management at the various levels within the company to assess the
effectiveness of their particular departments
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When accomplished on a consistent basis it
provides an excellent barometer of change in operational performance
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It helps build and maintain employee awareness
and interest in how their particular function/duty effects safety
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Effectively conducted, it promotes improved
operational performance through detailed feedback and corrective
action time tables
QIT IEP BENEFITS
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Utilizing QIT’s Internal Evaluation Program
software provides the following organization benefits:
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Organizes all organization audit requirements
into one database
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Organizes audits of all operational department
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Provides ATOS-compliant audit checklists that
are user controlled and easy to change
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Allows identification and data collection
on all safety issues
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Provides a central clearing house for all
audit findings and corrective actions
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Allows tracking of all corrective actions
and Safety Risk Management risk mitigations
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Provides formal work processes for consistency
throughout organization
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Provides tracking of organizational safety
due diligence on all safety issues
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Reduces audit program manpower
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Reduces the time it takes to complete audits
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Provides aggregate organizational audit and
safety data analysis in customizable reports
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Provides trend analysis and real time data
reports
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Software is intuitive and easy to use requiring
minimal training
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Software system navigation is presented on
opening screens and easy to travel
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Utilizes QIT's consulting services and our
Senior Consultants' years experience to quickly set up IEP program
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IEP procedure and audit checklist review
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IEP Program Pre-assessment - review manual,
procedures and current program structure and management
scheme. Provide suggestions and a proposed IEP audit system
and management scheme
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IEP Audits - Help clients forming a audit
management scheme, and then conduct the audits regularly
based on clients' behalf
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IEP Auditor Training - Conduct on-site
training for auditors to quickly bring the auditors up to
the requirements
With a minimal training session that can be accomplished
remotely, your safety or audit personnel can be on their way to
efficient, organized auditing and tracking of issues that are of
concern to upper management.
Key Terms and Definitions
Objective Evidence – Documented
statement of fact, prepared by the functional department. Material
may be quantitative or qualitative and is based on observations,
measurements, or tests, (questions), which can be verified. This
data is necessary to substantiate findings or concerns and to enable
management or evaluators to determine the root causes of reported
findings. Sources are:
Finding – Objective evidence which
demonstrates instances of noncompliance or nonconformance with a
specific standard (such as a FAR).
Noncompliance – A finding in which
objective evidence shows that established policies and procedures
are not consistent with regulatory requirements and standards, thereby
indicating potential systemic deficiency.
Nonconformance – A finding in which
objective evidence shows that a particular action was not performed
in accordance with regulatory requirements and standards. Does not
indicate a systemic deficiency.
Concern – Objective evidence that
does not produce a finding, but rather, a condition that may become
a finding. Emphasizes the anticipatory aspect of the internal evaluation
program.
Classes of Findings -
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Class A – ANY non-compliance
with any FAR.
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Class B – Failure of the certificate
holder to adhere to documented company procedures, related to
specific regulatory requirements or safety, that have been developed
by the certificate holder and approved or accepted by the FAA.
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Class C – Findings are Opinions
and Recommendations concerning safety of flight, passenger and
crew safety, safety related to aircraft operations on the ground,
or airworthiness items.
NOTE: It is the “findings” that
are categorized. Category determinations do not reflect the severity
or corrective action taken to resolve the finding.
ATOS
(AIR TRANSPORTATION
SYSTEM OVERSIGHT)
The Air Transportation Oversight System (ATOS)
was implemented in 1998 as a new approach to FAA certification and
surveillance oversight, using system safety principles and systematic
processes to assure that air carriers are in compliance with the
Federal Aviation Administration regulations and have safety built
into their operating systems.
Unlike the traditional oversight methods, ATOS
incorporates the structured application of new inspection tasks,
analytical processes, and data collection techniques to the oversight
of individual air carriers. This approach enables Flight Standards
inspectors to be more effective in the oversight of air carriers
by focusing on the most critical safety aspects of an air carrier's
operation. As currently applied, ATOS provides a systematic process
for conducting surveillance, identifying and dealing with risks,
and providing data and analysis to guide the oversight of each carrier.
Under ATOS, an air carrier's operations have been
separated into 7 systems, 14 subsystems, and 88 underlying component
"elements" which provide the structure for conducting surveillance,
collecting data, and identifying risks or areas of concern. A model
may be referenced at
http://www.faa.gov/about/initiatives/atos/
Surveillance is effectively implemented through
two distinct types of inspection, the Safety Attribute Inspection
(SAI) and the Element Performance Inspection (EPI). An SAI is planned
for at the subsystem level and conducted at the "element" level
by a team of inspectors to determine if the air carrier has the
safety attributes of Responsibility, Authority, Procedures, Controls,
Process Measurement, and Interfaces adequately designed into their
system element processes.
EPIs are also conducted at the "element" level,
but are accomplished by individual inspectors to determine if the
carrier's system element processes meet established performance
requirements, if the air carrier's procedures and controls are adhered
to, and if proper records are maintained. In addition, over 2200
specific regulatory requirements have been incorporated into the
SAIs and EPIs to ensure that air carriers are in full compliance
with all applicable CFRs.
For more information on how your company can quickly
gain these advantages, please
email one of our Senior Consultants to find out more