CASS Program Administrator Training
Internal Evaluation Program

Gold Aviation Services operates under a Continuous Airworthiness Maintenance Program (CAMP) as required for aircraft with 10 or more passenger seats under 14 CFR Part 135.411(a)(2). The CAMP consists of ten interconnected elements. CASS is the tenth element and serves as the oversight mechanism for the entire program.

1. Airworthiness Responsibility: The company's primary obligation to ensure all maintenance and alterations are performed correctly and that aircraft are airworthy when released to service. This responsibility cannot be delegated away.
2. Air Carrier Maintenance Manual: The General Maintenance Manual (GMM) and all associated technical data, including manufacturer manuals, that define policies, procedures, and standards for maintenance.
3. Air Carrier Maintenance Organization: The organizational structure, reporting lines, and assignment of authority and responsibility for maintenance functions (GMM Chapter 2).
4. Accomplishment and Approval of Maintenance and Alterations: The processes, authorizations, and qualified personnel required to perform and approve maintenance and alterations, including Required Inspection Items (RII).
5. Maintenance Schedule: The approved inspection program, time limitations, and scheduling of inspections, overhauls, and other maintenance actions.
6. Required Inspection Items (RII): Specific maintenance tasks designated as critical that require independent inspection by a qualified person who did not perform the work.
7. Maintenance Recordkeeping System: The complete system for documenting all maintenance performed, including work packages, logbook entries, computerized tracking, and retention requirements.
8. Contract Maintenance: Policies and procedures for selecting, authorizing, overseeing, and auditing maintenance performed by outside Maintenance Providers (vendors and repair stations).
9. Personnel Training: Initial, recurrent, and revision training requirements for all personnel involved in maintenance activities.
10. CASS (Continuing Analysis and Surveillance System): The formal, ongoing process for monitoring, analyzing, and improving the effectiveness of the other nine elements.

CASS is required under 14 CFR §135.431. The regulation requires certificate holders to establish a continuing analysis and surveillance system that monitors the effectiveness of the maintenance program and corrects any deficiencies.

AC 120-79A provides FAA guidance on how to structure and implement an effective CASS program. It emphasizes that CASS is not just data collection; it is a closed-loop system of surveillance, analysis, corrective action, and verification of effectiveness.

GMM Chapter 10 contains Gold Aviation Services' specific CASS policies and procedures. As Program Administrator, you must be thoroughly familiar with Chapter 10 and ensure all CASS activities are conducted in accordance with it.

The purpose of CASS is to:

• Detect adverse trends before they result in incidents or accidents
• Identify systemic weaknesses in the maintenance program
• Verify that corrective actions are effective
• Support continuous improvement of the CAMP
• Provide data and analysis to senior management and the CASS Committee

The Director of Maintenance (DOM) holds overall authority and responsibility for the CASS program and for the effectiveness of the entire maintenance program.

As Director of Safety (DOS), you administer the CASS program day-to-day. Your responsibilities include:

• Coordinating data collection from multiple sources
• Entering and tracking safety reports in FOS
• Preparing materials and analysis for CASS Committee meetings
• Facilitating the 5-stage safety report process
• Conducting or coordinating root cause analysis
• Tracking corrective actions to closure and verifying effectiveness
• Maintaining CASS records and meeting documentation
• Supporting audits of maintenance providers
• Recommending manual and procedure changes based on CASS findings

GMM Chapter 10.7 establishes a formal 5-stage process for handling safety reports and CASS-related issues. You are responsible for managing reports through these stages:

Stage 1: Initial Processing: Receive the report, ensure it is complete, assign a tracking number in FOS, and perform initial risk assessment. Conduct preliminary root cause analysis if the issue is significant.

Stage 2: Risk Assessment: Evaluate the likelihood and severity of the reported condition using the company risk matrix. Determine the risk level (Low, Medium, High) and the urgency of response.

Stage 3: Hazard Identification: Clearly define the hazard or deficiency. Distinguish between the symptom (what was reported) and the underlying hazard.

Stage 4: Risk Control and Corrective Action Development: Work with the responsible manager to develop appropriate corrective or mitigating actions. Ensure actions are specific, measurable, and assigned with deadlines.

Stage 5: Risk Control Evaluation and Disposition: After corrective action is implemented, verify its effectiveness. This may involve follow-up audits, data review, or additional monitoring. Close the report only when effectiveness is confirmed. If the action was not effective, return to Stage 4.

When a significant event, repeat discrepancy, or systemic issue is identified, you must ensure a proper root cause analysis is performed. Gold Aviation Services uses the 5 Whys methodology as described in GMM Chapter 10.18.

The 5 Whys technique involves repeatedly asking "Why?" until the fundamental (root) cause is identified. Most problems have multiple contributing factors; the goal is to go beyond the immediate cause to the underlying process, procedure, training, or organizational issue.

Effective CASS requires systematic data collection from multiple sources. As Program Administrator, you are responsible for monitoring the following (per GMM 10.15 and 10.17):

• Aircraft Trip Logs and maintenance discrepancy reports
• MEL/CDL deferred discrepancies and extensions
• Service Difficulty Reports (SDRs)
• Mechanical Interruption Summary Reports
• Repeat discrepancies (defined as three or more events in a 30-day period)
• Audit findings from internal and maintenance provider audits
• Deviation reports
• Self-disclosures
• Suggestions for improvement

You must ensure that anomalies and adverse trends are identified and entered into FOS as safety reports for processing through the 5-stage system.

CASS includes an audit function to verify compliance and effectiveness of maintenance activities, both internally and with maintenance providers.

You support the planning and execution of audits, including:

• Internal audits of company maintenance processes
• Audits of contract maintenance facilities using Form 411 (Vendor Quality Self-Audit Checklist) and on-site audits when required
• Review of audit findings and ensuring they are processed through the 5-stage system

You are responsible for preparing for and supporting CASS Committee meetings (held twice per year per GMM 10.9). This includes:

• Compiling data and analysis for the meeting agenda
• Preparing trend reports and summaries of open items
• Documenting meeting records (minutes, decisions, and action items)
• Tracking action items from previous meetings to closure
• Presenting findings and recommendations to the committee

After each meeting, you generate the Continuing Analysis and Surveillance Summary report as required by GMM 10.20 and distribute it appropriately.

Typical CASS Committee Meeting Agenda (GMM Chapter 10.9.1):

1. Call to Order and Attendance
2. Review of Previous Meeting Minutes and Open Action Items
3. Safety Report Summary and Trends
4. Data Analysis and Performance Metrics (discrepancy trends, MEL/CDL, SDRs, MIS reports, repeat discrepancies)
5. Root Cause Analysis and Corrective Action Review
6. Audit Findings and Maintenance Provider Performance
7. Manual and Procedure Change Recommendations
8. New Business and Emerging Issues
9. Action Item Assignment and Due Dates
10. Next Meeting Date and Adjournment

Distribute the agenda and supporting materials to committee members in advance of each meeting to allow for proper preparation.

One of the key outputs of CASS is the identification of needed improvements to manuals and procedures (GMM 10.19). When CASS analysis shows that current guidance is inadequate, you are responsible for:

• Recommending specific changes to the General Maintenance Manual or other documents
• Ensuring proposed changes are reviewed by the appropriate manager
• Tracking approved revisions through the revision process
• Verifying that personnel are trained on significant changes

You also monitor FAA guidance (Directives, Advisory Circulars, Notices) and industry best practices for possible incorporation into company procedures.

Accurate and complete records are essential for CASS effectiveness and regulatory compliance. You are responsible for ensuring the following are properly maintained:

• Safety report records in FOS (including all 5 stages and root cause analysis)
• CASS Committee meeting records and minutes
• Corrective action tracking and effectiveness verification
• Audit reports and findings
• Data summaries and trend analyses presented to the committee

CASS depends on a healthy reporting culture. Gold Aviation Services operates under a Just Culture philosophy (GMM 10.2), which distinguishes between honest mistakes and willful misconduct.

As Program Administrator, you must:

• Encourage reporting without fear of punishment for honest errors
• Focus on systemic issues rather than individual blame when analyzing reports
• Protect the confidentiality of reporters when appropriate
• Ensure that the CASS process itself does not discourage future reporting

As CASS Program Administrator, your core responsibilities are to:

• Manage the flow of safety reports through the 5-stage process
• Ensure thorough root cause analysis using the 5 Whys method
• Monitor maintenance data for adverse trends
• Support audits and maintenance provider oversight
• Prepare for and document CASS Committee meetings
• Drive corrective actions to closure and verify effectiveness
• Recommend improvements to manuals and procedures
• Maintain complete and accurate CASS records

You are the central point of coordination for the CASS program. Your work directly supports the safety and reliability of Gold Aviation Services' maintenance operations and feeds critical information into the broader Safety Management System.