INTERNAL EVALUATION PROGRAM (IEP)
The concept of the 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.
A good IEP 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. Better to find and correct deficiencies before noticed by others, particularly the FAA.
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, In-flight, Field Services, Training Departments, Flight Safety Department, System Operations Control, (Dispatch), and Crew Scheduling, among possible others. Specific topics covered include applicable Federal Aviation Regulations (FARs), company policies 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 should complete the internal evaluation annually, note any findings, and take corrective action. At the specified interval, an Internal Evaluation Finding Report should be made which provides a summary of departmental findings and progress in their resolution. This also provides evidence of due diligence in correcting deficiencies.
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
- When accomplished on a consistent basis it provides an excellent barometer of change in operational performance
- It helps build and maintain employee awareness and interest in how their particular function/duty effects safety
- Effectively conducted, it promotes improved operational performance through detailed feedback and corrective action time tables
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:
- Documents or manuals reviewed
- Equipment examined
- Activities observed
- Interview data
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 –
- Class A ANY non-compliance with any FAR.
- 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.
- 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.
AIR TRANSPORTATION SYSTEM OVERSIGHT (ATOS)
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. While some safety managers feel that ATOS is being replaced by the implementation of SMS, it is still with us and will be prominently embedded into the FAA mandated SMS. Having an IEP address all the elements and attributes of ATOS will go a long way in building confidence in your FAA Certificate Management Office Inspector team that you have a good handle on safety risk management.
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.
Automated Safety Audit Tools
A good audit management software tool should:
- Organize all organization audit requirements and findings into one database
- Organize and schedule audits of all operational departments
- Provide ATOS-compliant audit checklists that are user-controlled and easy to change
- Allow identification and data collection on all safety issues
- Provide a central clearing house for all audit findings and corrective actions
- Allow tracking of all corrective actions and Safety Risk Management risk mitigations
- Provide formal work processes for consistency throughout organization
- Provide tracking of organizational safety due diligence on all safety issues
- Reduce audit program manpower
- Reduce the time it takes to complete and report audits
- Provide aggregate organizational audit and safety data analysis in customizable reports
- Provide trend analysis and real time data reports
- Be intuitive and easy to use requiring minimal training
- Present easy navigation paths from the opening screen and promote easy travel to each function
For more information on how your company can quickly gain these advantages, please email one of our Senior Consultants to find out more