CAR-145 management system Foundamental Element

What are the foundational elements and oversight mechanisms of a CAR-145 management system?

The foundational elements of a CAR-145 management system (145.A.200) include several key components that define accountability, safety philosophy, risk management, personnel competency, and documentation.

Foundational Elements of a CAR-145 Management System

The maintenance organization is required to establish, implement, and maintain a management system that incorporates the following elements:

1. Accountability and Responsibility: There must be clearly defined accountability and lines of responsibility throughout the organization, which includes the direct safety accountability of the accountable manager.

2. Safety Policy and Objectives: The organization must define its overall philosophies and principles regarding safety, known as "the safety policy," along with related safety objectives.

3. Safety Risk Management: This involves hazard identification, evaluation of those hazards, and the management of associated risks, including taking actions to mitigate the risks and verify the effectiveness of those actions.

4. Personnel Competency: The organization must maintain personnel trained and competent to perform their assigned tasks.

5. Documentation: All management system key processes must be documented, including a procedure for informing personnel of their responsibilities and a process for amending that documentation.

6. Compliance Monitoring Function: The system must incorporate a function dedicated to monitoring the compliance of the organization with the relevant requirements.

The management system must be tailored to match the size of the organization and the nature and complexity of its activities, taking into account inherent hazards and associated risks. If the organization holds additional certificates under the Aircraft Rules, 1937, the management system may be integrated across these certificates.

Oversight and Monitoring Mechanisms

The management system's oversight relies heavily on the compliance monitoring function and dedicated safety reporting schemes:

1. Compliance Monitoring and Auditing

The compliance monitoring function serves to provide an independent review of how the organization maintains compliance with applicable requirements, policies, and procedures, and it must initiate action when non-compliances are identified.

• Feedback System: This function must include a feedback system of findings directed to the accountable manager to ensure corrective actions are effectively implemented when necessary.

• Independent Audit: A crucial element of compliance monitoring is the independent audit, which is an objective process involving routine sample checks of all aspects of the organization’s adherence to required maintenance standards and procedures.

• Audit Scope: Audits include checking compliance of procedures against the regulation, adherence to those procedures by the organization, and product or maintenance sampling (product audits).

• Audit Plan: An audit plan must be established to detail when and how often activities will be audited, with the aim of verifying all aspects of CAR-145 compliance every year, including subcontracted activities. Audits may include unannounced checks carried out while maintenance is being performed.

2. Safety and Occurrence Reporting

The organization must establish and maintain an occurrence-reporting system encompassing both mandatory and voluntary reporting, as a part of its management system.

• Internal Safety Reporting Scheme (145.A.202): This scheme is established to collect and evaluate occurrences reportable under mandatory requirements (145.A.60), as well as errors, near misses, and hazards reported internally that do not fall under mandatory reporting.

• Purpose of Internal Reporting: Through this scheme, the organization must identify the causes and contributing factors to reported errors, near misses, and hazards, and address them using the safety risk management process. The scheme should ensure confidentiality and encourage free and frank reporting of safety-related issues.

• Mandatory Reporting (145.A.60): The organization must report safety-related events or conditions—especially accidents or serious incidents—to the DGCA and to the design approval holder of the affected aircraft or component. Reports affecting aircraft must also be sent to the person or organization responsible for the continuing airworthiness of that aircraft.

The oversight mechanisms function somewhat like a continuous radar system. The compliance monitoring acts as the radar searching for system weaknesses (findings), while the internal safety reporting scheme provides real-time inputs (reports of errors, near misses, and hazards) from personnel on the ground, ensuring that potential issues are identified, evaluated, and mitigated through the overall management system before they can escalate.