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SURVEILLANCE

CHAPTER 2 PARTS 121, 135 AND 91 SUBPART K INSPECTIONS

2 General Policies and Procedures for Parts 121, 135, and 91 Subpart K Surveillance

1 INTRODUCTION. Title 49 of the United States Code (U.S.C.) authorizes the Secretary of the Department of Transportation (DOT) to conduct inspections of certificate holders. Statutory requirement empowers the Federal Aviation Administration (FAA), “...to carry out the functions, powers, and duties of the Secretary relating to aviation safety.” One of the most significant duties of the FAA is to conduct surveillance in all areas of air transportation safety. Surveillance is a continuing duty and responsibility of all aviation safety inspectors (ASI) in the Flight Standards Service (AFS) organization. The term “surveillance,” as used in this handbook, relates to this ongoing duty and responsibility and related programs. Surveillance programs provide the FAA with a method for a continual evaluation of certificate holder compliance with Title 14 of the Code of Federal Regulations (14 CFR) and safe operating practices. Information generated from the surveillance programs permits the FAA to act upon deficiencies which affect, or have a potential affect on, aviation safety. For surveillance programs to be effective, ASIs must carefully plan and execute surveillance during the conduct of specific inspection activity. Inspections provide specific data, which can be further evaluated. Therefore, they support and maintain ongoing surveillance programs. Inspections are specific work activities which have the following characteristics:

• A specific work activity title and Program Tracking and Reporting Subsystem (PTRS) code.

• A definite beginning and a definite end.

• Defined procedures.

• Specific objectives.

• A requirement for a report of findings (either positive, negative, or both).

2 OBJECTIVE OF SURVEILLANCE PROGRAMS. The primary objective of surveillance is to provide the FAA, through a variety of inspection, with an accurate, real-time, and comprehensive evaluation of the safety status of the air transportation system. Inspectors accomplish this by:

• Determining each certificate holder’s compliance with regulatory requirements and safe operating practices.

• Detecting changes as they occur in the operational environment.

• Detecting the need for regulatory, managerial, and operational changes.

• Measuring the effectiveness of previous corrective actions.

3 SURVEILLANCE PROGRAM DEVELOPMENT FOR 14 CFR PART 135. On September 10, 2008, AFS issued N 8900.49, Work Program Development for Part 135 Helicopter Emergency Medical Services (HEMS) Operators or Commercial Air Tour Operators. The cancellation date of that notice was September 10, 2009. That notice gave guidance to ASIs with oversight responsibility for one or more part 135 air carriers conducting either HEMS operations or commercial air tour operations. Those ASIs received guidance to use the Safety Performance Analysis System (SPAS) Surveillance Priority Index (SPI) tool in the development of their work programs.

1 Transition. AFS will transition to a Safety Assurance System (SAS) that will help with work program development. However, we do not expect the implementation of a SAS until 2013. In the meantime, some offices are using the 135 Surveillance and Evaluation Program (SEP). The Director of AFS, AFS-1, has determined that the use of the SPAS 135 SPI tool until a SAS is implemented will:

• Help develop work programs,

• Consider National Transportation Safety Board (NTSB) recommendations and Office of Inspector General (OIG) audit findings,

• More efficient use of resources, and

• Enhanced safety and reduced accidents.

2 SPI Tool. When developing the ASI’s annual work program or reassessing the work program throughout the year, principal inspectors (PI) with oversight responsibility for one or more than one part 135 air carriers must use the 135 SPI tool, which is a module in the SPAS. This tool will allow inspectors to prioritize work functions based upon the SPI-ranked analysis in addition to other analysis data.

1 Principal operations inspectors (POI), principal maintenance inspectors (PMI), and principal avionics inspectors (PAI) are required to review and revise their part 135 certificate holders’ assessments as a team at least once per fiscal year. Once a current SPI assessment has been entered for a given part 135 certificate holder, an updated SPI assessment will be due within 12 months from the date of the current assessment.

2 You can use the 135 SPAS SPI tool to increase or redirect surveillance and include en route surveillance (as necessary) based on priority. The tool allows the FAA to leverage resources smartly, focusing proper attention and surveillance where it is most needed.

N PIs should use the SPI tool to help prioritize surveillance, but should evaluate the results of the model carefully. The SPI results should provide input into the PI’s decisionmaking, but should not serve as a substitute for the PI’s judgment in prioritizing surveillance needs.

3 Reviewing, Entering, and Updating an SPI Assessment. To review the assessment details and enter a Current SPI assessment for a given certificate holder, the inspectors follow the steps outlined below:

1 Access the 135 SPI (Draft) under the Air Operators heading via the following link: . (See Figure 6-11B, 135 Surveillance Priority Index Link.) The SPAS shows PIs their part 135 certificate holder responsibilities in the left hand frame. The inspector can display the certificate holder’s assessments, if any, by clicking the radio button next to the desired certificate holder. The assessment status is also displayed for each certificate holder.

2 Review the SPI status for part 135 certificate holders. PIs should review the status of the SPIs for each certificate holder in the record list. The statuses are as follows:

1 Current. The assessment has been performed in the past year.

2 Due. The last assessment was performed over a year ago and is due for review (the last assessment will be used in the calculation of the Priority Index).

3 Incomplete. No assessment has been performed for this certificate holder; the Priority Index will be calculated without the assessment and is considered incomplete.

3 Enter a current SPI assessment for each certificate holder whose assessment is due or incomplete. If the assessment is current, no further action should be necessary unless the PI wishes to make changes. For each certificate holder whose assessment is due or overdue, the PI team must enter a current assessment. There are two steps to entering a current assessment:

1 Review of the Priority Index Data-Derived Factors. The review of data-derived factors entails opening the certificate holder’s SPI Assessment Record and reviewing the values determined by the data-derived factors to generate the certificate holder’s final SPI score. The data-derived factors are listed below:

• Fatal Accidents within the past 3 years.

• Non-fatal accidents within the past 3 years.

• Incidents within the past 3 years.

• Violations within the past 3 years.

• The Department of Defense (DOD) Activity Flag in concern state?

• Management changes in the past year.

• PI changes in the past year.

• Passenger carrying capacity (“#” seats).

• Average surveillances per aircraft (within the past year).

• Number of system inspections in the past 3 years.

• New entrant (within the past 5 years)?

N In reviewing the data-derived factors, PIs should examine the certificate holder’s applicable data values shown for each factor, the rules for PI assignment within each factor, and the computed index value for each data-derived factor.

2 Review and Update of the PI Assessment Factors. The PI Assessment Factors are a set of risk factors that cannot be derived from an available data source, so their assessment values are entered directly into the SPI by PIs as either “Yes” or “No” based on the inspector’s perception of whether the certificate holder is exposed to each individual factor. The PI Assessment Factors included in the SPI consist of the following:

• Rapid expansion.

• Labor disputes.

• Financial distress.

• Mergers/takeovers.

• High employee turnover.

• Non-compliant attitude.

• Poor safety culture.

• Challenging operational environment.

• Participates in safety program.

• No information.

• No information.

• No information.

• No information.

• No information.

• No information.

• No information.

• No information.

• No information.

• No information.

• No information.

• No information.

N The “no information” statements will be replaced at a later date with the updated PI Assessment Factors.

4 The PIs can access and update the PI Assessment Factors by clicking the “Review/Revise Principal Inspector Assessments for your Responsibilities” button at the bottom of the SPAS 135 SPI Query screen. Updating these PI Assessment Factors requires the PIs to enter a “Yes” or “No” response for each of the nine PI Assessment Factors questions/assessments. The PI team makes their assessment and clicks the save button for each part 135 certificate holder.

Figure 6-11A, Review/Revise Principal Inspector Assessments for your Responsibilities Button

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5 The current PI Assessment Factors are briefly defined below.

1 Rapid expansion and financial distress (Volume 6, Chapter 2, Section 18).

2 Labor disputes (Volume 6, Chapter 9, Section 18).

N The guidance in Volume 6, Chapter 2, Section 18 and Volume 6, Chapter 9, Section 18 talk specifically about repair stations but the information is largely applicable across the board.

3 Financial Distress. Risk may exist at certificate holders experiencing adverse financial conditions.

N When a certificate holder experiences financial instability, the possibility for risk may increase due to a number of complex and interrelated causes, factors, and results. These may directly or indirectly impact various aspects of the certificate holder’s system, subsystem, element structure, and may overlap with other risk indicators, or become a causal factor for the generation of risk in other areas. Figure 6-29, Financial Condition Assessment Decision Aid, in Volume 6, Chapter 2, Section 18 discusses the issues of financial risk.

4 Mergers/takeovers (see Volume 3, Chapter 34, Section 1).

5 High Employee Turnover. The certificate holder has experienced significant turnover in personnel. While high employee turnover can be managed the following circumstances should prompt a PI to consider high turnover as being a risk:

• Turnover of personnel is sudden and due to employee dissatisfaction.

• Turnover of personnel does not appear to be a controlled change.

• High turnover of personnel is within the maintenance and/or operations organizations.

• New or remaining staff is being re-trained or cross-trained to perform the new or expanded functions.

• Concern exists for adverse impact due to widespread and rapid personnel turnover in safety-sensitive areas with very high impact on critical systems.

• The certificate holder has not demonstrated appropriate or effective management of the event(s).

6 Noncompliant Attitude. Concern exists regarding the certificate holder’s relationship with the FAA due to considerations such as:

• Little or no history of strong two-way communication between the certificate holder and assigned FAA personnel.

• Recent indications of unwillingness to share data and findings with assigned FAA personnel on the part of the certificate holder.

• FAA recommendations and suggestions not welcomed by the certificate holder.

• Concern exists due to apparent failure of cooperation with assigned FAA personnel in critical areas or the certificate holder has not demonstrated appropriate or effective management.

7 Poor Safety Culture. A poor safety culture could be indicated if the certificate holder does not have the following in place:

• Policy or procedures that define a method by which risk is managed.

• A risk management process to monitor the critical programs.

• A safety assurance process; this is equivalent to an Internal Evaluation Program (IEP).

• A method of promoting safety and a means for employees to report safety deficiencies without fear of reprisal.

• A means of monitoring its safety critical programs.

N In addition, a poor safety culture could be a concern if repeated and critical human factors performance errors remain uncorrected and appear to indicate a negative trend with escalation in severity.

8 Challenging Operational Environment. The complexity of a certificate holder’s particular operation must be considered. There are many factors that can that can be considered as “challenging.” Some examples are:

1 Diversity of Fleet. How many different types of aircraft does the certificate holder operate?

2 Age of Fleet. Aging aircraft can present a concern but so can a brand new aircraft if it is a type not previously operated by the certificate holder.

3 Areas of Operation. These are the areas listed in the certificate holder’s operations specifications (OpSpec) paragraph B050. Some areas of operation can present particularly challenging environments especially if they are located in remote areas of the world.

4 The ability of the certificate-holding district office (CHDO) to observe flight operations in progress. Observations and en route inspections may be difficult to conduct if the certificate holder operates into remote areas.

5 A high number and/or type of human factors performance errors are occurring.

9 Participation in Safety Programs. If the certificate holder participates in voluntary safety programs such as Voluntary Self-Disclosure, the Aviation Safety Action Program (ASAP), or flight operations quality assurance (FOQA), it can be an indication of a positive safety culture.

Figure 6-11B, 135 Surveillance Priority Index Link

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6 To learn more about the SPAS SPI tool, select the movie camera icon located at the top of the page illustrated in Figure 6-11C, SPAS Surveillance Priority Index Query Web Page. An instructional video will appear and describe how PIs can use this tool to enhance their surveillance activities. In addition, the “Need Help?” tab located in the left hand corner of the SPI contains additional detailed information on the use of the SPI.

Figure 6-11C, SPAS Surveillance Priority Index Query Web Page

[pic]

4 Interpreting SPI Scores. Once SPI scores have been generated, SPAS provides a rank order listing of SPI scores that can be viewed for all part 135 active certificate holders associated with either an individual inspector, an office, a region, or a pre-defined SPAS peer group. A listing of 135 SPI scores can even be viewed for all active part 135 certificate holders nationwide.

1 When using the 135 SPAS SPI tool and interpreting SPI scores, it is important to remember that a certificate holder’s calculated index value is not an absolute measure of safety risk, but rather a tool to assist PIs in prioritizing their surveillance activities. Inspectors can only make a definitive assessment of any certificate holder’s safety risk after conducting surveillance and analyzing the surveillance results along with other relevant data. PIs can use the 135 SPAS SPI tool to identify increased hazards within a particular certificate holder, to increase or redirect surveillance, and to include en route surveillance (as necessary) based on priority.

2 In general, when interpreting SPI scores and comparing certificate holders by SPI scores, a certificate holder with a high SPI numerical score can be viewed as being a higher priority than the certificate holder with the lower score based on the risk factors considered by the SPAS SPI tool. However, the “Priority Index” scores shown in the list are default values assigned by the standard SPAS SPI algorithm, and the PIs have the ability to adjust the weights in individual risk factors to generate a set of alternative SPI values that reflect their expert judgment on how much weight each factor should have in generating an SPI score. The alternate SPI score will be shown as “My Priority Index” on the SPAS SPI screens. If the PI team’s judgment supports a change in the weights for selected factors, the weights can be adjusted by a PI using the Review/Revise Index Factors and Point Assignments (i.e., “My Point”) function accessible on the SPI Query screen. Re-running the model after entering adjusted weights will calculate an alternate SPI score using adjusted weights that reflect the PI team’s desired weighting factors.

N This adjustment to the weighting will not change the default SPI value factors but will calculate a modified set of alternate SPI scores for every part 135 certificate holder, including those that are the responsibility of the PI entering the adjusted weights. The alternate SPI score will be shown as “My Priority Index” on the SPAS SPI screens.

3 In addition, it is possible that more than one certificate holder in an office, region, etc., will have the same score. In such cases, the following options can be considered to assist in differentiating between certificate holders with the same SPI score.

1 Check the SPI trend for each certificate holder who has the same score, and begin prioritizing by selecting the ones with the higher scores.

2 Drill down to base data for selected factors such as accidents, incidents, violations, the DOD Flag factor, etc., and consider the recency of any events currently being incorporated into the current SPI score. If one certificate holder has a pattern of more recent events as compared with another, the one with more recent events could be considered a higher priority.

3 Review the point values and weighting structure for the individual factors. Are the default weights and point assignment criteria consistent with the team’s perception and judgment on how each factor should be weighted? If the PI team’s judgment supports a change in the weights for selected factors, the weights can be adjusted using the Review/Revise Index Factors and Point Assignments (i.e., “My Points”) function accessible on the SPI query screen to calculate an alternate SPI score using adjusted weights that reflect the PI team’s desired weighting factors.

4 Review the “My Priority Index” and evaluate the PI Assessment Factors and adjust those scores if necessary and appropriate.

N SPAS should add the most current safety assessment guidelines within the system.

5 En Route Inspection. Additionally, we highly recommend that PIs of certificate holders conducting commercial air tours conduct at least one en route inspection annually. When possible, PIs should plan their en route inspections so as to not occupy a seat previously sold to a revenue passenger (i.e., do not “bump” revenue passengers).

4 PLANNING AND EXECUTING SURVEILLANCE PROGRAMS. The following are four phases involved in planning and executing any type of surveillance program:

• Phase 1: Developing a surveillance plan by determining the types of inspections necessary and the frequency of those inspections.

• Phase 2: Conducting the surveillance plan by conducting the inspections.

• Phase 3: Analyzing surveillance data gathered from inspection reports and related information from other sources.

• Phase 4: Determining appropriate course of action.

1 Phase 1: Developing a Surveillance Plan. The development of a surveillance plan requires planning at the headquarters (HQ), regional, district office, and individual inspector levels. A surveillance program may be based on the need to conduct routine and ongoing surveillance, or the need to conduct special emphasis surveillance as a result of certain events such as accidents, incidents, violations, and strikes. When planning a surveillance program, FAA personnel should determine the program objectives, evaluate the resources available, and determine the specific types and numbers of inspections in support of that program. The National Program Guidelines (NPG) provide a base level of surveillance data which should be evaluated. You should use the results of this evaluation as a basis for planning future surveillance programs. You should use this information, along with other related information such as previous inspection reports, accident/incident information, compliance and enforcement information, and public complaints to determine the types and frequency of inspections. When developing a surveillance program, inspectors should first consider NPG requirements. The NPG requirements, however, only provide a base level of surveillance data. Therefore, you should consider a certificate holder’s compliance status and other factors such as ongoing certification work activities when developing a surveillance program. Other factors to consider are the geographic areas where the inspectors should conduct the various types of inspections and the frequency of those inspections. The latest NTSB safety recommendations are available at the following link: . It may be appropriate to change the emphasis or objectives of surveillance programs by changing the types and numbers of inspections.

2 Phase 2: Conducting the Surveillance Plan Inspections. During the conduct of the surveillance plan inspections, accurate and qualitative inspection reporting is essential. High quality inspection reporting is necessary for the effective accomplishment of the third and fourth phases of a surveillance program.

3 Phase 3: Analyzing Surveillance Data. After reporting the inspection data, conduct an evaluation of the information obtained from inspection reports and related sources. The purpose of this evaluation is to identify the areas of concern and note areas such as the following:

• Noncompliance with regulations or safe operating practices.

• Both positive and negative trends.

• Isolated deficiencies or incidents.

• Causes of noncompliance, trends, or isolated deficiencies.

4 Phase 4: Determining Appropriate Course of Action. Inspectors and PIs must use their professional judgment when deciding on the most effective course of action. The appropriate course of action depends on many factors. There are also many choices that you can make, such as: taking no action; informal discussion with the certificate holder; formal written request for corrective action; withdrawal of FAA approval of a program, manual, or document; and initiation of an incident or enforcement investigation. Consider the results of the evaluation of surveillance data and the certificate holder’s response to the course of action taken. Part of the fourth phase of a surveillance program is for the FAA to determine, as a result of the information gathered from the program, what will become the inspection requirements for subsequent surveillance programs. Depending on the situation, it may be appropriate to increase or decrease the rate at which inspectors conduct inspections during subsequent surveillance programs.

Figure 6-12, The Four Phases of a Surveillance Program

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5 SURVEILLANCE PLANNING AND EVALUATION RESPONSIBILITIES. There are six organizational elements within AFS which are responsible for ensuring the developing and maintaining of comprehensive surveillance programs. These six elements are as follows:

• Washington HQ.

• Regional AFS division.

• District offices.

• PIs.

• Geographic program managers.

• ASIs.

1 Washington HQ. Washington HQ (AFS-1) has the primary responsibility for establishing national surveillance programs and for developing the direction and guidance for inspectors to use when conducting these programs. These responsibilities include developing pertinent inspector handbook material to control and guide national inspection programs, such as NPG and other special surveillance programs. Washington HQ is responsible for evaluating surveillance data from a national standpoint. Washington HQ has the additional responsibility of ensuring that the NPG inspection data, and other types of surveillance data, are available to the appropriate regional offices.

2 Regional AFS Divisions. Regional AFS division offices have primary responsibility for the implementation of national surveillance programs, including the assignment of NPG and other national inspection requirements. The regional offices serve to assure quality control (QC) and to coordinate district office surveillance planning. These regional offices are responsible for evaluating surveillance data from a regional standpoint. Regional offices must forward reports of nationally or regionally-directed inspections to the appropriate CHDO.

3 District Offices. FAA district office managers play a key role in developing effective surveillance programs. These managers are responsible for ensuring that PIs, program managers, and unit supervisors are planning and conducting effective surveillance programs. These programs must include inspections of certificate holders whose certificates are held by the district office as well as inspections of certificate holders who conduct operations within the geographic area of the district office. District office managers are responsible for ensuring that these programs provide high quality surveillance data.

4 PIs. PIs are the primary surveillance program planners in the FAA since they are the focal point for all operational matters between the FAA and the certificate holder. PIs must ensure that there are periodic reviews of all aspects of the certificate holder’s operations. They must specifically determine the certificate holder’s compliance status by establishing effective surveillance programs, and evaluating previous surveillance data and other related information. PIs must establish a continuing program for evaluating surveillance data to identify trends and deficiencies, and to decide upon and take appropriate courses of action.

5 Geographic Program Managers. Geographic program managers are responsible for planning and carrying out inspection programs within their area of responsibility and for ensuring the inspection results are accurately recorded. These managers ensure that all of the activities of certificate holders conducting operations in their geographic area are considered for inspection and the PI receives the results through the PTRS. The geographic program manager is specifically responsible for assigning available inspectors to conduct the necessary inspections, providing on-the-job training (OJT) for assigned inspectors, and for supervising assigned inspectors for efficiency and effectiveness.

6 ASIs. Individual inspectors are responsible for conducting inspections in accordance with the direction, guidance, and procedures in this handbook. A primary responsibility of each inspector is to report inspection results in a clear, concise, and factual manner. Supervisory inspectors are responsible for reviewing inspection reports for clarity and accuracy. Supervisory inspectors should also review any onsite corrective actions the inspector already took, and determine if any followup action is appropriate.

6 DETERMINING INSPECTION REQUIREMENTS. When developing a surveillance program, PIs must determine the number and types of inspections to conduct. For a routine surveillance program, there should be a representative number of each type of inspection. Circumstances or results from previous inspections, however, may indicate that a specific area should receive emphasis and therefore more inspection activity of a particular type. Conversely, surveillance data may indicate that certain types of inspections are ineffective, or that fewer inspections can effectively accomplish the objective.

1 Complexity and Size. The PI should consider the complexity and size of the certificate holder when determining the number of inspections to accomplish. A method to consider complexity and size is to separate each operation into homogenous groups. Examples of homogenous groups include pilots, mechanics, aircraft, Flight Attendants (F/A), training and qualification records, line stations, and various types of manuals. The PI can consider each of these groups separately when determining the number and types of inspections not yet conducted.

2 Statistical Methods. When considering a large homogenous group, such as trip records, certain statistical methods may be useful for determining how many inspections to conduct.

1 A specific number, or sampling, of a group can produce a 95 percent confidence level that inspectors will accomplish a sufficient number of inspections to properly assess the compliance status of that particular area. Table 6-1, Number of Inspections Recommended to Achieve 95 Percent Confidence Level, provides guidance for sample sizes (the number of inspections) of varying population sizes (the homogenous group) that will result in a statistical confidence level of 95 percent:

Table 6-1, Number of Inspections Recommended to Achieve 95 Percent Confidence Level

|Population of Homogeneous Group|Recommended Number of |

| |Inspections |

|Up to 100 |50% (50) |

|200 |40% (80) |

|400 |35% (140) |

|500 |33% (165) |

|1,000 |28% (280) |

|2,000 |16% (322) |

|3,000 |11% (330) |

|4,000 |8.8% (352) |

|5,000 |7.7% (355) |

|10,000 |3.7% (370) |

2 You may draw samples from the homogenous group in several ways, but the sample must be random. The following is one method of conducting a random sampling. First establish a sampling interval. For illustration purposes, we use an interval of nine. Out of the first nine items of a rank (airman records in alphabetical order), the first item is chosen at random. Thereafter every ninth record is selected. For example, if a sample size of 330 records is selected from a homogenous group of 3,000 records (see Table 6-1), the sampling interval would be every ninth record (3,000 divided by 330). If an inspection starts at a randomly-selected record between 1 and 9 and continues with the selection of every ninth record thereafter, a 95 percent confidence level will be produced. When a method such as this is used, all elements (records) in the group are given equal chance of inclusion in the sample.

3 Types of Inspections. Each type of inspection varies in its basic objective. Many types of inspections, however, share common events or elements in the aviation system. For example, inspectors evaluate pilots during en route inspections, initial operating experience (IOE), simulator training sessions, and required checks. PIs should consider this when developing surveillance programs. For example (and to illustrate the use of the previous table), if a certificate holder employs 500 flightcrew members (pilot in command (PIC), second in command (SIC), and Flight Engineers (FE)), we recommend the evaluation of at least 33 percent (or 165 flightcrew members). If the objective is to inspect this number of flightcrew members, the inspection may include any combination of en route inspections, IOE observations, training sessions, line checks, or proficiency checks for a total of 165 inspections.

4 Qualitative Information. The information in Table 6-1 is guidance only and you should not construe it as a mandatory method for determining the number of inspections during a surveillance program. The primary objectives of a surveillance program are for the inspectors to conduct inspections which are qualitative and provide effective results. The quality of inspections has a higher priority than the actual number of inspections conducted. PIs should review and, when necessary, revise their surveillance programs semi-annually and annually to adjust them according to national surveillance programs and ensure they are effective and meeting planned objectives.

7 EVALUATION OF INSPECTION RESULTS.

1 Importance of Evaluating Inspection Results. Inspector evaluation of inspection results is a key phase of any surveillance program. The primary purpose of evaluating surveillance data is to identify both negative and positive trends as well as deficiencies not associated with an apparent trend. PIs should determine the appropriate course of action to take based on their evaluation. This evaluation is also important in terms of redefining and implementing subsequent surveillance objectives and inspection activity. PIs must adopt systematic methods that permit accurate and effective evaluation of inspection results. Additionally, other related information from incidents, accidents, enforcement actions, and other sources may provide valuable trend information which may relate to the certificate holder’s safety and compliance status. PIs should use all available inspection results and related information to decide on appropriate courses of action. For example, if in a series of ramp inspection reports a trend of deficiencies show up in the use of the minimum equipment list (MEL), but the cause of these deficiencies cannot be identified, the PI may need to adjust the emphasis on the types of inspections conducted. In this case, training program inspections, manual inspections, or flight control inspections (flight release procedures) may be more effective in determining the cause of these deficiencies. In this example, the PI’s initial course of action might be to informally discuss the identified trend of deficiencies with the certificate holder. After other types of inspection results identify the cause of the deficiencies, the PI can take an effective course of action by formally requiring the certificate holder to correct the problem at its source. The previous example only illustrates how to determine surveillance action for a particular situation.

2 Organization of Surveillance Data. There are several broad areas of interest in a surveillance program that, when organized into more defined elements, will provide an effective and comprehensive evaluation of surveillance data. The PTRS is an effective tool which the PI should use during the ongoing evaluation of a surveillance program. Inspection results are available in ad hoc formats or in established report formats for real-time and comprehensive data analysis (see Section 2). The PTRS design processes surveillance data by organizing the data into broad areas of interest and by collecting elements of information within those broad areas. Section 2 discusses (in detail) the PTRS. This system provides for the organized retrieval of surveillance data related to a broad area of interest. Primary areas are broad areas of interest in the PTRS. The PTRS, as currently designed, organizes the broad areas of interest (primary areas) under the following titles:

• Air Carrier Operations.

• General Aviation Operations.

• ATC/Airspace.

• Airports.

• Air Agencies.

• Air Carrier Airworthiness.

• General Aviation Airworthiness.

• Aircraft ATA Codes.

• Crewmembers.

1 A key word list of elements of information further organizes each primary area. This framework provides a method for PIs to use when organizing surveillance information for effective trend evaluation strategies. The following is a list of the major titles of the elements of information (relating to operations) that are currently designed into the PTRS:

• Personnel.

• Manuals.

• Records/Reports.

• Training.

• Facilities/Equipment.

• Conformance (compliance with regulations and safe operating practices).

• Operations (flight conduct).

• Flight Control.

• Key Personnel Programs.

• Management.

• Aircraft.

2 Each of these elements of information provides a database of related information obtained from inspection reports. By grouping inspection results from related types of inspections, any developing trends or areas that will require an appropriate course of action (or additional emphasis) during subsequent inspections are more readily identified. For example, you can obtain surveillance data related to the element of information titled “personnel” from the following types of related inspection reports:

• En route inspections (IOE and line checks).

• Ramp inspections.

• Proficiency check inspections.

• Training inspections.

• Other related inspections.

8 PTRS INPUT. Document each en route inspection conducted on a part 135 commercial air tour operator with the PTRS code 1624.

• Enter “ATOUR” in the “National Use” field (without the quotes and without any spaces).

• Once the above actions have been accomplished, as appropriate, close out the PTRS.

RESERVED. Paragraphs 6-173 through 6-185.

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