Surveillance Procedures and Analysis in Transportation Canada's Civil Aviation

1. Surveillance Findings/Analysis/CAPs ATAC 2010

2. Transport Canada Civil AviationPrairie Northern Region • David White • SMS Coordinator PNR • Oversight Coordination Division • Based in Edmonton, Alberta • (780) 495-5216 • david.white@tc.gc.ca

3. Contents • Define surveillance activities • Discuss surveillance procedures (SI-SUR-001) • Refer to areas of review, SMS, QAP,Ops Control • Analysing Issues identified during surveillance • Causal analysis (root cause) • Generating acceptable Corrective Action Plans (CAP) • Effective communication during the process

4. What is an Assessment? • Assessment means the surveillance activity conducted to evaluate effectiveness and level of compliance with the CARs. • Staff Instruction (SI) SUR-001 • Sometimes referred to as 17 PVIs.

5. What is a PVI? • A systematic review of one or more SMS components of an organization ORother regulated areas of a certificate holder. • Used to determine if regulatory requirements are documented, implemented, in use and effective within certified organizations. • It is a means to focus on the effectiveness of management systems & make judgments on performance. • Quality Assurance (QA) and the Ops control system are examples of management systems

6. Additional distinction between terms • Assessment – Evaluation of entire SMS • Limited to companies that meet SMS requirements • PVI – Evaluation of regulated area of company’s control system or specific SMS component • Applicable to all companies • Process Inspection – In-depth review of steps to obtain specific output • Our focus will be on Assessments/ PVIs here today.

7. Surveillance Activity Overview • The activity consists of: • Documentation review (preparation) • On-site review (including interviews & sampling) • Analysis • Reporting

8. Notification Team selection PVI plan Preliminary doc review Documentation review Team meeting Sampling procedures On-site procedures PVI team on-site briefing On-site review Interviewing Analysis PVI worksheets Findings Exit meeting PVI report PVI CAP procedures PVI follow-up & closure Surveillance Procedures in SUR-001

9. Program Validation Inspection (PVI) • PVI will review the following areas for certificate holder without Quality Assurance (QA) Program: • Part III - Airport operator’s obligations • Part IV - Company operational control & supervision • Part VII - Subpart 3 or 4 - Company operational control • Part VII - Subpart 5 - Safety Oversight component • Part VIII - Operating certificate requirements

10. Quality Assurance Program • Regulations for certificate holders to have QA • Will be implemented in phased manner • PVIs for Parts III, IV, VII & VIII without fully implemented QA Program use customized PVI worksheets • SUR-001 Appendix A contains expanded list of all PVI worksheets organized by operating rule

11. Quality Assurance Program • Certificate holders that have QAP: • Inspectors use worksheet SUR-001 Appendix A Table 5.1 Quality Assurance • This includes certificate pursuant to: • CAR 561 • STD 566 • CAR 573 • Maintenance requirements for all Part IV & VII operators

12. Some Examples of Worksheets referenced in SI-SUR-001 (k) TABLE 3.1 – Reactive Processes (l) TABLE 3.2 – Proactive Processes (m) TABLE 3.3 – Investigation & Analysis (n) TABLE 3.4 – Risk Management (p) TABLE 5.1 – Quality Assurance (r) Program Validation Inspection Worksheet – CAR 302 (s) Program Validation Inspection Worksheet – CAR 406 (t) Program Validation Inspection Worksheet – CAR 703/704 (u) Program Validation Inspection Worksheet – CAR 801 (ee) Program Validation Inspection Worksheet EASA NOTE: These Worksheets are internal documents only

13. Surveillance Activity Responsibilities • Convening Authority • Identifies - Who • Defines - Scope & depth • PVI/Assessment Manager • Plans • Manages • Team Member(s) • Conduct

14. Documentation Review • Doc review 4-6 weeks before on-site review –Assessment • Doc review 1-2 weeks before on-site review –PVI • Includes review of all files & docs relevant to certificate holder and scope of the surveillance activity • Ensure all reference manuals/docs are available & include latest amendments • Confirm revision status of any manual subject to review • Review approved manuals for conformance to standard • Identify areas that require further review during on-site. • Develop specific questions for certificate holder and appropriate management based on intelligence gathered during review.

15. “A general policy statement is not usually enough to satisfy requirements. Document review team members must verify that there is a policy in place and that it is support by an appropriately documented procedure or process as required ” • This varies dependent on the area being reviewed and the type of certificate issued but is basically the “Write what you do and do what you write” principle. • TC may request additional documentation if the initial submission does not meet the team’s requirement.

16. Onsite Activities • Entrance Meeting • Interviews ( Management and selected employees) • Sampling • Based on size, scope and complexity of the organization. • Determined through process in SI-SUR-001 • Used in conjunction with interviews to determine regulatory compliance • Non-compliance issues Identified • Purpose of the activity is to determine regulatory compliance. • Company briefing(s) • Exit meeting

17. Surveillance Findings • We will concentrate on PVI examples today. • Ineffective Quality Assurance • Loss of Operational Control • Examples of Non-compliance with regulatory requirements. • Examples of Non-compliance with Company Policy/Procedures and processes.

18. Surveillance Reporting • Report generated with findings. • Required actions determined through review with CA. • Issues are typically handled through the Corrective Action Plan (CAP) process. • Required additional actions are based on the severity of non-compliance issues identified. • Additional actions may involve Certificate Action and/or Enhanced Monitoring.

19. Review of Findings • Recognizing the System Failure • Addressing the immediate concerns • Causal Analysis • Planning the short-term corrections • Planning the long term corrections • Informing TC

20. Causal Analysis SI-SUR-001, Section 10.4 CAP Evaluation … A Root Cause Analysis of the Non-conformance: The certificate holder’s analysis shall include a summary of the root cause as well as any causal factors that may have contributed to the non-conformance. Even though the certificate holder may use a causal analysis method that is not familiar to the CAP reviewer (e.g.: MEDA process, “5 Why’s”, etc.), the certificate holder must be able to demonstrate how they arrived at the root cause and it should be clear what caused the non-conformance to occur.

21. Causal Analysis • Causal Analysis seeks to identify and understand the reasons why things are as they are and hence enabling focus of change activity. • Some Examples: • The 5 Whys • Meda • Fishbone • The key is just to keep asking until you get to a real 'aha' that you can treat.

22. CAP Submission • TC Inspector Expectations • Causal Analysis • Appropriate Timelines • Documentation • Communication • SI SUR-001 Section 10.4 (2) states: *** “The role of the principal inspector responsible for the acceptance of the CAP shall be limited to the assessment of the process used by the certificate holder in reaching conclusions regarding the findings. It is not the inspector’s role to second-guess the CAP solutions, but rather to evaluate the process used in developing those solutions.”***

23. CAP Acceptance and Follow-up • Remember it is your Plan • Monitor the implementation to ensure it is implemented • Communicate Issues if implementation not as per plan. • Document the issues and resolution with the regulator. • Be prepared for the Activity follow-up…Confirming your systems are working not just that the examples identified during the inspection have been addressed

24. Surveillance Activity Closure • Effective systems are a continuing process. • Your responsibility for day to day compliance • Systems will mature and improve as we continue to use them.

25. Thank-you