Many of us aircraft maintenance engineers (AMEs) and operators were brought up in the industry doing things a certain way. I’ll call that “old school thinking.” And surprisingly, many people — myself included — still approach audits with that same mindset.
It’s easy for approved maintenance organizations (AMOs), operators, and even manufacturers to fall back on long-standing habits simply because “that’s how it’s always been done.” One area where this shows up is in how we handle internal audit cycles.
The AMO, operator, and manufacturer all have internal audit requirements for the maintenance function(s) to demonstrate compliance with regulations as part of a Quality Assurance Program. If you ask a Person Responsible for Maintenance (PRM) what the audit cycle is for their organization, they will most likely state an annual requirement: every 12 months.
For most aircraft operators, the Maintenance Control Manual (MCM) is written and then approved by Transport Canada (TC) for the control of maintenance activities in the operation (AOC, or aircraft operating certificate). Likewise, for maintenance organizations, the Maintenance Policy Manual (MPM) is written and then approved by TC for the control of maintenance activities in the AMO.
That being said, this is what the Canadian Aviation Regulations currently state:
CAR 706.07 3.(a) (b) — AOC
(a) an initial audit within 12 months after the date on which the air operator certificate is issued;
(b) subsequent audits conducted at intervals set out in the MCM.
CAR 573.09 3.(a) (b) — AMO
(a) an initial audit within 12 months after the date on which the AMO certificate is issued;
(b) subsequent audits conducted at intervals set out in the MPM.
For approved aviation manufacturers, CAR 561.09(3)(a) requires “an initial audit, within 12 months after the day on which the manufacturer certificate is issued, that covers all aspects of the manufacturer’s activities.”
With the above internal audit cycle(s) clearly identified, it remains up to the operator, the maintenance organization, or the approved manufacturer to determine what the subsequent repetitive audit cycle will be after the initial 12-month audit.
CAR 706.07(4) states: “The records required under paragraph (3)(g) shall be retained for the greater of
(a) two audit cycles; and
(b) two years.”
The interval should be reflective of various considerations. There may be other factors as to why an organization would determine that an annual audit cycle is required, and one factor might be a client requirement.
In any case — and stemming from personal experience — I would suggest that any organization would benefit from reviewing its internal audit cycle and determining whether it is actually meeting the intent of an internal audit, versus simply being a token exercise that is inconvenient at any time of the year.
It’s important to note that the only other mention within the regulations specific to the Quality Assurance Program with a 12-month repetitive requirement is in CAR Std. 426.14(b), which is the Flight Training Quality Assurance requirement. It states: “The flight training unit quality assurance program shall include: recurring internal audits conducted at 12-month intervals.”
Similar to the idea of a hazard reporting system, an internal audit should be designed to identify items that are not in conformance or compliance, or simply need consideration for improvement.
An internal audit should offer real value, not just satisfy a checkbox. Old habits are hard to break, but taking a fresh look at how often we audit, and why, can help ensure the process supports both compliance and continuous improvement.
With over 45 years of experience as an aircraft maintenance engineer, Terrence D. Eissfeldt holds a current Transport Canada license with M1 and M2 certification. His previous positions include director of maintenance, quality assurance manager, chief executive officer, and accountable executive.
