1. Air Carrier Continuing Analysis and Surveillance System (CASS)
Inspector Roles and Responsibilities

2. Objectives
Describe general roles and responsibilities of the FAA Inspector
Evaluate the operators CASS through the assessment of well-defined process measures
Identify CASS health indicators while working with the Carrier for CASS improvement

3. Overview General role of the FAA Principal roles of an Inspector
Evaluating a CASS

4. General Role of the FAA
Operator has primary responsibility for compliance
The FAA
Does not design CASS
Ensures proper policies and procedures are in place
FAA Expectations
Identify who is responsible for CASS
Process for selecting data sets for CASS
Periodically re-evaluate appropriateness of data
Justification for data selection

5. Role of the FAA Inspector
You, the inspector, are here to mitigate risk of Air Transportation to an acceptable level for the flying public. There is NO one else. If you don’t do it, it won’t get done.
Share your knowledge and support the development of an operator’s CASS
Review the collected information to evaluate the overall CASS
Meet with personnel responsible for the development and execution of CASS
LISTEN! This sounds easy but do you do it well? It’s amazing what you can learn!
YOU ARE THE CHANGE AGENT whether you like it or not

6. Evaluating an Operator’s CASS
Other possible inputs that may go into the CAS system- ASAP, reports, VDRP, IEP findings,
The carrier needs to establish a plan , look at the system safety process, the first block identifies a Plan, the carrier should establish a plan and you should review it and see if the plan is feasible. Take the position of “are you (the carrier) sure you can meet this plan because that’s what are expectations will be”. Ask the question do you have the resources to complete the plan in the timeframe you have identified.
We have our scheduled EPI’s , I cannot stress enough that ANY finding while completing either the SAI or EPI needs to be evaluated for hazards and risks. You may ask “Why” I stress this, a change either with the CAS system or a change from a CAS finding can change the organization.
CASS needs to be evaluated periodically
Operator must be certain that it is performing and being effective
A primary task of a FAA inspector
At what timeframe will the system be evaluated?
CASS is not solely based on results of maintenance programs
Common misconception with PI’s is that their operator has the best program in the world
System-oriented: Where else may the carrier get valuable information that may be considered “inputs” into CASS?
Designed: Structured approach & Consistent execution

7. Evaluating an Operator’s CASS
Each carrier may have a different approach, but the results will be very close. The
CAS system does not have to be complex, but well structured.
Personnel with CASS oversight
Different approach
Operator has defined CASS policies and procedures
Must be documented
Communication across the maintenance organization
Regulations require
Maintenance programs
Separate system to monitor those programs

8. Focus of CASS Evaluation
The carrier should/must identify who is responsible for CASS, In your discussions with him/her ask them how they are going to determine the systems performance and effectiveness. The responsible person should assure the system has identified what is going to be measured and how they will demonstrate compliance.
Question: Ask the carrier: How do you demonstrate that your CASS is meeting the intent of the regulation for performance and effectiveness.
REMEMBER:
It is an FAA responsibility to DETERMINE adequacy and a Carrier’s responsibility to DEMONSTRATE it.
YOU, THE FAA INSPECTOR, MUST BE ENGAGED AT A LEVEL THAT ALLOWS YOU TO SEE THE OVERALL PRODUCT AND NOT JUST THE PIECES.
Operator develops methods for evaluating CASS
Specific to its own scope and operation
How do they show that the CASS system is performing and being effective?
This should include who and what.
CASS should focus on the following:
System safety/risk management
System safety attributes
Indicators/measurements of performance and effectiveness

9. System Safety Process
To understand system safety and its relationship to CAS one must assure the carrier has well defined systems and processes. If you look at the system safety diagram the second block identifies a system description, without well defined systems and processes within the system it is very difficult to be able to identify hazards or perform meaningful audits. Remember this is the carriers responsibility, but you should be asking the question, do they have either. If you conclude they do then what are they auditing within the processes of their system. From inspectors input carriers generally do not have well defined processes, therefore how do they do a meaningful audit. From the system description they should be able to identify the real or potential hazards and the carrier should manage the associated hazards. They can do this by possibly re-engineering the process, or build in controls. But they need to identify and manage the hazards for effective system safety. The CAS process to be effective needs to start from the beginning of a new or altered process, with the identification of hazards as you will see below.

10. Indicators CASS should produce findings Is anything changing
High number is not necessarily negative
Could indicate CASS is working properly
Is anything changing
Going up and down, just up, just down
No Change???

11. Periodic Review of CASS
All of the review should be identified in the CASS, the carrier may have a separate CASS manual, within the manual a review process should be included.
The review should ensure performance and effectiveness
Senior management and all employees should:
understand what CASS is and support it
jointly review the issues
ensure appropriate personnel should discuss findings
know who identifies and who address’s trends

12. An approach for working with the air carrier for CASS improvement
I believe we all know a carrier does not have sufficient resources to address all issues at once
An approach for working with the air carrier for CASS improvement
ATA ref

13. Benefits of a Good CASS Opportunity For The Air Carrier To Increase:
Three air carriers that have that we are aware of have instituted the concepts of system safety and process improvement. From the process design or redesign work groups that were established we have seen a greater understanding and benefits of process improvement.
Opportunity For The Air Carrier To Increase:
Performance/Economic Efficiencies
Reduces crisis management
Enhances Safety
Increase in Morale
Higher Job Satisfaction
Do Job Right The First Time
Saves Dollars
Planned Proactive Management
Provides senior management time to do their jobs and have time to think about where they want to take the organization

14. Cost of a Bad CASS Performance/Economic Deficiencies
Three air carriers that have that we are aware of have instituted the concepts of system safety and process improvement. From the process design or redesign work groups that were established we have seen a greater understanding and benefits of process improvement.
Performance/Economic Deficiencies
Jeopardizes Safety
Decline of Morale
Low Job Satisfaction
Redoing Work/Poor Troubleshooting
Cost Dollars
Crisis Management

15. How do you get air carrier involvement?
Suggest your carrier attend system safety course
Is the carrier and principal inspectors in agreement that CASS needs to be improved?
If not, then gather sufficient data to raise questions on how the carrier meets (or did not meet) the intent of the regulation and discuss with the carrier.
Communicate to the person responsible for the air carrier’s CASS that you are willing to share your knowledge
Build a productive working relationship
Speak in terms of “Organization failure,” not individuals

16. Actions you can take, Ideas you can use
Know what your role in this is, see if the air carriers personnel know what their role is in regards to CASS.
Process owners are identified by the carrier. This might be at the ten element level or at the process level. What are the benefits of each approach?
Ask the carriers auditors or management, process owners if their processes are well defined.
When your CMT has identified an issue, either regulatory or not, work with the air carrier to identify hazards and to develop mitigations actions to address the risk(s). What will this do? What will you see?
What else do we use/follow that is very similar ?

17. Knowledge Sharing Meeting
Hopefully from the past the carrier is aware of what system safety/risk management is and are somewhat knowledgeable about it. If they are not share your knowledge, take small steps at a time, look for opportunities to demonstrate to them that both system safety and risk management may have been an easier more fruit full path. Do not expect perfection at the start, and don’t give up, another opportunity will come along soon.
Principal inspectors work with the person responsible for
CASS to establish a date where both the air carrier and the FAA can attend.
At least a day and a half
Participants must include:
The carrier’s decision makers
All principal inspectors (PI).
(Any other FAA personnel must support the PI’s lead)
The carrier’s individual with CASS responsibility
Do your Homework
How many things is the carrier doing that could support their CASS system that they are not taking credit for?

18. Knowledge Sharing Meeting
Do your Homework (con’t)
Identification Of Your Requirements
Standard Format
Collection: Who, How, When
The carrier will ask, “What Value Is Added” in each requirement.
Resources
CASS development and improvement takes resources.
Culture
How can you address the safety culture of the maintenance organization?

19. Caution:
When discussing risk management be care full- a person that may only hear part of what risk management is all about, yet think he has the authority to make a decision that he/she thinks is based on risk.
Make sure the carrier is well aware that this event is NOT punitive,
They may perceive this if the FAA is calling a meeting. You need to try and dispel this.
This effort is not quick and easy.
Process development takes time to get the desired result.
When discussing risk management, make sure any decision made is made by the proper decision maker.

20. What’s the Future of CASS at Your Carrier?
You need to stress to the senior management of the maintenance organization that they are or should be the forward thinker and they are the ones responsible, and if they don’t do it who does. No one else can make the changes in the organization.
Make sure senior management supports and understands
what CASS is and what it can do for their organization.
Who Owns CASS: The Carrier - who will be responsible for CASS?
Carrier Charters Working Groups
Teams Being Established And Supported
Goals Identified
Time Lines To Be Determined
How Will This Be Documented And Shared
Updates, How Often
Future Development (Documentation Reduces Future Timelines For Development)

21. A Human Factor Who makes the presentation to the air carrier and CMT ?
A knowledgeable person on system safety/risk management and process development and CASS

22. Presentation Preparation
Develop a presentation that supports CASS guidance
Must follow the guidance
Tie it back to the regulation throughout the presentation
Recommend displaying a large poster during the presentation
Discuss and share your knowledge with the carrier
Stress that CASS is the carrier’s system and its what they need for their maintenance program to meet the intent of the regulation
Interoffice presentations are encouraged to help ensure support and understanding of a standardized approach to CASS
Conduct the Meeting

23. Evaluation of CASS
Discuss how it should be evaluated and the criteria both the carrier and the FAA should use
Can both parties agree the system and processes within the system are well defined, should include who the process owners are?
The carrier should identify what methodologies will be used for hazard identification and root cause analysis.
How will this be documented and how will it be communicated?

24. What’s next? Where do you and where do we go from here?
The Air Carrier
You need to commit to develop clear, well-defined processes
You need to get ALL process owners on board- you may need to identify process owners
Develop a CASS System
The FAA
We help
We need to monitor and assist
We need to evaluate your system for CASS

25. Actions/Implementation
The plan needs to be well thought out and the timelines needs to be based on risk
The air carrier and the FAA need to plan together.
The carrier needs to complete a risk management exercise.
The carrier needs to be ready to identify hazards that the FAA perceives as real or potential.
From these hazards, the group will identify the associated risks.
From that, the FAA will hopefully understand the other entities perception of that risk.
From that, the carrier will work the identified hazards to see how they might be managed.

26. Actions/Implementation
In process development the success of it is enhanced if the requirements of the process are well identified before process development starts, this is really the first step in process development.
The FAA may also want to:
Discuss with the carrier the basics of process development, input, process, output, logic and what this can do for them.
This should aid in identifying audit points and data points
Start with a simple system from the beginning with a system description and work your way through the system safety logic, small steps at a time
Try to get the carrier to give system safety/risk management process development training to all process owners

27. Why do this? System Safety/Risk management
There is a difference between trust and coziness; do not get complacent or comfortable.
System Safety/Risk management
To work correctly it is built on trust
It should make you more comfortable in that the carrier will address higher risk issues first. This gives them the ability to prioritize. It will give the decision maker a better picture of why this needs to be done.
Air carrier and the CMT must have a level of trust
This means that both the air carrier and the assigned FAA inspectors will trust each other to do the right thing.
This does not mean that we can neglect our regulatory duties, but that our actions are the right actions

28. How a Carrier Addressed a Cultural Issue
The above was submitted by a carrier, after a PI collected all the data and information to identify that the carrier’s organization had a weak safety cultural issue. The Pi used data form the EPI’s, recent accidents, occurrences, ASAP events and VDRP’s. When the PI met with senior management/CEO the PI did not make it optional, but expected a plan to address the organizational failure. At the end of the meeting the CEO committed to a plan and admitted there are cultural issues, he was aware of the costs the carrier had incurred because of the cultural issues.
Training for all maintenance personnel:
Review Air Lines “B” Safety Policy as signed by the President and CEO
Review of Maintenance Management Safety Pledge.
Responsibility for promoting a safe work environment and fostering maintenance teamwork.
“Challenge and Response” training (similar to CRM)
Emphasis will be placed on Safety Procedures and Work Interruption Procedures.
Daily Shift Briefings with all mechanics:
General safety procedure and GMM Volume 1 topics
Tailored safety procedure for the work being accomplished on that shift.

29. How a Carrier Addressed a Cultural Issue
The above was submitted by a carrier, after a PI collected all the data and information to identify that the carrier’s organization had a weak safety cultural issue. The Pi used data form the EPI’s, recent accidents, occurrences, ASAP events and VDRP’s. When the PI met with senior management/CEO the PI did not make it optional, but expected a plan to address the organizational failure. At the end of the meeting the CEO committed to a plan and admitted there are cultural issues, he was aware of the costs the carrier had incurred because of the cultural issues.
Daily Maintenance Department conference call:
Each maintenance facility will outline the previous day’s safety briefing topics
Review all new safety-related issues from prior day’s activities
Develop action plans for all safety-related issues presented
Status update of open action items from previously identified safety concerns.

30. Remember… Operator has primary responsibility for compliance The FAA
Evaluates the overall CASS to ensure procedures and standards are adequate in meeting the requirements of the regulation for performance and effectiveness. The FAA Inspector
Evaluates the overall CASS to ensure consistent execution and effectiveness

31. Practice Exercise

32. Objectives
Describe general roles and responsibilities of the FAA Inspector
Evaluate the operators CASS through the assessment of well-defined process measures
Identify CASS health indicators while working with the Carrier for CASS improvement

33. QUESTIONS ?