INTERNAL EVALUATION PROGRAM

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

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

QIT IEP BENEFITS

Utilizing QIT’s Internal Evaluation Program software provides the following organization benefits:
Organizes all organization audit requirements into one database
Organizes audits of all operational department
Provides ATOS-compliant audit checklists that are user controlled and easy to change
Allows identification and data collection on all safety issues
Provides a central clearing house for all audit findings and corrective actions
Allows tracking of all corrective actions and Safety Risk Management risk mitigations
Provides formal work processes for consistency throughout organization
Provides tracking of organizational safety due diligence on all safety issues
Reduces audit program manpower
Reduces the time it takes to complete audits
Provides aggregate organizational audit and safety data analysis in customizable reports
Provides trend analysis and real time data reports
Software is intuitive and easy to use requiring minimal training
Software system navigation is presented on opening screens and easy to travel
Utilizes QIT's consulting services and our Senior Consultants' years experience to quickly set up IEP program
- IEP procedure and audit checklist review
- 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
- IEP Audits - Help clients forming a audit management scheme, and then conduct the audits regularly based on clients' behalf
- 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.

Consulting Service

Along with the software package, we also provide services in:

IEP procedure and audit checklist review
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
IEP Audits - Help clients forming a audit management scheme, and then conduct the audits regularly on clients' behalf
IEP Auditor Training - Conduct on-site training and share experiences for auditors to quickly bring auditors up to the requirements
Email one of our Senior Consultants to find out more

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.

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/safety/programs_initiatives/oversight/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

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