GM2 145.A.200(a)(6) Management system

COMPLIANCE MONITORING — AUDIT PLAN

(a) The purpose of this GM is to provide guidance on one acceptable working audit plan to meet part of the needs of point 145.A.200(a)(6). There is any number of other acceptable working audit plans.

(b) The audits described in the audit plan are intended to monitor compliance with the applicable requirements, and at the same time to review all areas of the organisation to which those requirements are applicable.

(c) In order to achieve this objective, as a first element, the organisation needs to identify all the regulatory requirements that are applicable to the activity and the scope of work under consideration, to allow the audit plan to focus on the relevant topics. Each topic (e.g. facilities, personnel, etc.) should be cross-referred with the relevant requirement and the related procedure of the organisation in the exposition that describes the particular topic. If the organisation follows a specific means of compliance to demonstrate compliance with the rule, that information may also be stated.

(d) As a second element, all the functional areas of the organisation in which Part-145 functions are intended to be carried out (i.e. the types of maintenance-related activities), including subcontracting, need to be listed in order to identify the applicability of any topic to each functional area.

(e) A matrix can be used, as shown in the example below, to capture the two elements mentioned above. This matrix is intended to be a living document to be customised by each particular organisation depending on its scope of work and its structure. This matrix should represent the overall compliance of the audit system, and needs to be amended, as necessary, based upon any change to the applicable regulations, the procedures of the organisation or the functional areas of the organisation (e.g. a change in the scope of work to include line maintenance, etc.)

Example (to be further completed) of an audit matrix for an organisation involved in aircraft base maintenance that does not hold airworthiness review privilege:

(f) The audit plan can be presented as a simplified schedule (see below), showing the operational areas of the organisation (i.e. where the maintenance-related activities are effectively carried out) against a timetable to indicate when each particular area was scheduled for audit and when the audit was completed. The audit plan should include a number of product audits (depending on the number of product lines), some of which should be unannounced (see AMC2 145.A.200(a)(6)).

Example (to be further completed) of an audit plan for an organisation, mentioned in point (e), that has two base maintenance hangars, and hydraulic and electrical workshops:

(g) The audit of each operational area will review all the topics that are applicable to the relevant functional area. For each topic, the audit should check that the particular Part-145 requirement is documented in the corresponding procedure in the exposition, and that the procedure is effectively implemented in the operational area that is being audited. In addition, the audit should also identify any practice/process implemented in the operational area which has not been documented in any procedure in the exposition.