2.
An essential element of the quality system is the independent audit.
3.
The independent audit is an objective process of routine sample checks of all aspects of the MCAR-M Subpart G organisation’s ability to carry out continuing airworthiness management to the required standards. It includes some product sampling as this is the end result of the process.
4.
The independent audit represents an objective overview of the complete continuing airworthiness management related activities. It is intended to complement the MCAR-
M.902 requirement for an airworthiness review to be satisfied that all aircraft managed by the organisation remain airworthy.
5.
The independent audit should ensure that all aspects of MCAR-M Subpart G compliance are checked annually, including all the sub-contracted activities, and may be carried out as a complete single exercise or subdivided over the year period in accordance with a scheduled plan. The independent audit does not require each procedure to be checked against each product line when it can be shown that the particular procedure is common to more than one product line and the procedure has been checked every year without resultant findings. Where findings have been identified, the particular procedure should be rechecked against other product lines until the findings have been rectified after which the independent audit procedure may revert back to year for the particular procedure.
Provided that there are no safety related findings, the audit time periods specified in this AMC may be increased by up to 100% subject to agreement by CAD.
6.
Where the organisation has more than one location approved the quality system should describe how these are integrated into the system and include a plan to audit each location every year.
7.
A report should be raised each time an audit is carried out describing what was checked and the resulting findings against applicable requirements, procedures and products.
8.
The independence of the audit should be established by always ensuring that audits are carried out by personnel not responsible for the function, procedure or products being checked.
9.
An organisation should establish a quality plan acceptable to CAD to show when and
how often the activities as required by MCAR-M Subpart G will be audited.
AMC M.712 (f) Quality system
A small organisation is considered to be an organisation with up to 5 full-time staff (including all MCAR-M.706 personnel) or equivalent proportional number when using part-time staff.The complexity of the organisation, combination of aircraft and aircraft types, the utilisation of the aircraft and the number of approved locations of the organisations should also be considered before replacing the quality system by an organisational review.
Appendix XIII should be used to manage the organisational reviews.
The following activities should not be considered as subcontracting and, as a consequence,
they may be performed without a Quality System, although they need to be described in the
continuing airworthiness management exposition and be approved by CAD:
.
Subscription to a technical publisher that provides maintenance data (Aircraft Maintenance Manuals, Illustrated Parts Catalogues, Service Bulletins, etc.), which may be applicable to a wide range of aircraft. These data may include maintenance schedules recommended by different manufacturers that can be afterwards used by the continuing airworthiness management organisation in order to produce customised maintenance programmes.
.
Contracting the use of a software tool for the management of continuing airworthiness data and records, under the following conditions (in addition to MCAR-M.714(d) and (e)):
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