Civil Aviation Authority: Certification and surveillance functions.

Intended actions advised by the Civil Aviation Authority in response to our recommendations

Summary of findingsIntended action by the CAA
Recommendation 1: That the CAA continue to establish measures to better assess the effectiveness of safety interventions.Continue to review the current measures in order to establish their reliability and where appropriate develop replacements.
Recommendation 2a: That the CAA improve its analysis of industry information by including more analysis of the information in the Aviation Safety Report and the Aviation Summary in order to support further action and improve the timeliness of the reports.Identify further opportunities for analysis to include in the safety reports and improve the timeliness of the reporting.
Recommendation 2b: That the CAA improve its analysis of industry information by improving analysis of accident and incident data to identify further opportunity to make recommendations for safety interventions.Review data gathering and analysis processes to enhance the CAA’s ability to identify safety improvement opportunities and make recommendations for safety initiatives.
Recommendation 3: The current risk assessment tools used by the CAA to assess risks associated with individual operators are underdeveloped and the outcomes from the current practices are adversely affected by inaccurate or incomplete data.

Reassess the function of a client risk assessment as an audit planning tool.

Review the provision of accurate and meaningful input data from all sources within the CAA.

To improve the effectiveness of the NCI inspectors must record all instances of non compliance.

The inspectors should ensure that the audit report, the findings and the Quality Index are in accord.

Recommendation 4: The CAA, during certification and surveillance, does not examine or take significant account of the financial condition of a client when assessing the operator risk.

Review the impact of finance on safe aviation operations and the ability of CAA to meaningfully monitor this aspect of operators’ performance.

Establish if the CAA can require detailed financial data from a client for certification and subsequent monitoring purposes.

Recommendation 5: That CAA ensures that its inspectors follow the policies and procedures set down for certification.

DCA to make a clear statement that CAA are to adhere to approved policy and procedures.

That management ensure that all CAA/Group/Unit policies and procedures are current, relevant and documented.

Recommendation 6a: Elements of the current CAA surveillance function should be reviewed and this includes the processes and tools used to direct resources, activities and interventions at the highest risk operators.Review current processes and tools used to determine operators at risk and amend the current or develop new tools and procedures to plan and schedule resources, activities and interventions.
Recommendation 6b: Elements of the current CAA surveillance function should be reviewed and this includes the lack of sampling methodology and processes to enable inspectors to make informed decisions when planning and conducting an audit, and to assess risk.Develop and implement a sampling methodology for inspectors to use during surveillance/certification activities.
Recommendation 6c: Elements of the current surveillance function should be reviewed and this includes the lack of a sensible process to determine the reliance that can be placed on an operator’s quality & risk management systems so that audits can be refocussed on higher risk areas (e.g. inspect or monitor?).Develop and implement a methodology to determine the level of credence and reliability that can be placed on an operator’s QA and risk management systems so that the depth and style of a surveillance activity can be adjusted appropriately.
Recommendation 6d: Elements of the current surveillance function should be reviewed and this includes the depth and frequency of the current audit schedules (excepting customised programmes) as these do not necessarily reflect the individual operator risk level.Review the current policy to audit annually and develop policy, methodologies and procedures to allow the CAA to adjust the level of surveillance to better meet the assessed risk level of an operator.
Recommendation 7: CAA inspectors fail to issue findings for all identified instances of non-compliance and non-conformance.

Review and simplify the current systems and processes used to record findings.

Resolve the current CAA/client conflict over fees and charges for surveillance activities.

Establish programmes to train staff on the Rule parts essential to their regulatory tasks.

Establish regular currency training programmes for all staff on the policy, procedures and Rule parts essential to their regulatory tasks.

Review and establish a more rigorous peer & management review of audit reports and findings.

Recommendation 8a: CAA inspectors/ managers are not ensuring that operators close all findings in a timely manner.Review and amend current findings follow-up and close-out procedures.
Recommendation 8b: When a CAA inspector leaves CAA there is no process to transfer that inspector’s open findings to another inspector. Develop procedures to transfer the follow-up of open findings to another inspector when an inspector leaves the CAA.
Recommendation 9: CAA inspectors are not recording all the time spent on surveillance activities. This impacts on management’s ability to provide resources and accurately assess client’s risk levels.

Staff to be instructed in the necessity to maintain accurate time records.

Review current management processes to check accuracy of entry data in the time management system.

Resolve the current CAA/client conflict over fees and charges for surveillance activities.

Recommendation 10a: There is a lack of investment in the training of CAA staff to develop and maintain the appropriate skills to carry out their functions.Review current inspector audit training programmes.
Recommendation 10b: Operational groups are not addressing internal Finding Notices.Operational groups to review current practices for managing QA internal findings at their next QA Management Representative meeting
Recommendation 10c: The internal audit section is not able to regularly conduct audits of staff in the field given the current staffing levelReview, prioritise and document the Professional Standards Group’s workload in order to determine staff resource requirements
Recommendation 10d: Review staffing levels to ensure that there are sufficient resources to undertake the surveillance function once the current review of this function (Surveillance Review project) is complete. The review needs to take account of surge requirements brought about by unanticipated requests for certification for example.Review operational group staffing levels on completion of the Surveillance Review Project.
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