22. EXHIBIT XXII - Quality Assurance Surveillance Plan (QASP)_-DRAFT.pdf
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- Total Aviation Support Services (TASS) - DEA
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- 15DDHQ24R00000041
About this file
This document is the Quality Assurance Surveillance Plan (QASP) for a federal contract to provide total aviation support services to the Drug Enforcement Administration (DEA) Office of Aviation Operations.
The QASP outlines the government's methods for monitoring and evaluating the contractor's performance in providing aircraft maintenance, pilot training, administrative support, and other required services. It defines the roles and responsibilities of government officials, the types of work to be performed, and the acceptable quality levels for each performance standard. The QASP describes scheduled and random surveillance inspections, review of contractor documentation, and the use of Deficiency Report Forms to document performance issues. Payment deductions or withholdings may be applied for unacceptable performance. The QASP also requires the contractor to develop and implement a comprehensive Quality Control Plan to ensure compliance with the performance standards.
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EXHIBIT XXII
QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)
DRUG ENFORCEMENT ADMINISTRATION (DEA)
OFFICE OF AVIATION OPERATIONS (OA)
1. INTRODUCTION
The Government's Quality Assurance Surveillance Plan (QASP) is based on the premise that the
Contractor, and not the Government, is responsible for the day-to-day operations, the delivery of aircraft maintenance, pilot training, administrative support and all management and quality control actions required to meet the terms of the contract. The role of the Government in quality assurance is to ensure performance standards are achieved and maintained. The Contract is required to develop a comprehensive program of inspections and monitoring actions and to document its approach in a Quality
Control Plan (QCP). The Contractor's QCP, upon approval by the Government, will be made a part of the resultant contract.
This QASP is designed to provide the Drug Enforcement Administration (DEA) with an effective surveillance method of monitoring and evaluating the Contractor's performance for aircraft maintenance and support services.
This QASP is based on the principle that the Government must validate that the Contractor is complying with DEA and Federal Aviation Administration (FAA) mandated quality standards in providing aircraft maintenance, pilot training, and administrative support. Efficient management by the Contractor and use of an approved QCP will ensure that the services provided are within acceptable quality levels.
2. PURPOSE OF THE OASP
The QASP is intended to accomplish the following:
• Define the roles and responsibilities of participating Government o f f i c i a l s .
• Identify the performance quality level standards in accordance with Federal Acquisition
Regulation (FAR) Part 37.601(a) (2).
• Describe the methods of surveillance for DEA to identify quality levels in accordance with FAR
Part 46.401(a) (2).
• Establish a method to provide feedback to the Contractor regarding quality and timeliness of the service performance.
• Establish timeframes for communication and performance improvement if n e e d e d .
• Ensure the Contractor has developed and implemented a QCP establishing procedures and responsibilities for controlling the quality of work performed.
3. ROLES AND RESPONSIBILITIES OF GOVERNMENT O F F I C I A L S
The following Government officials will participate in assessing the quality of the Contractor's performance. Their roles and responsibilities are described as follows:
1. The Contracting Officer's Representative (COR) is responsible for monitoring, assessing, recording, and reporting on the performance of the Contractor. The COR shall have the primary responsibility for completing forms that will be used to evaluate the Contractor's performance. In addition, the COR shall document the Contractor's performance using the accepted Government database for contractor performance assessments.
2. The Contracting Officer (CO) will have overall responsibility for overseeing the Contractor's performance. The CO, in conjunction with the COR, shall be responsible for monitoring the
Contractor's performance in the areas of contract compliance and contract administration.
The CO will review the COR's written assessments of the Contractor's performance and assist in resolving any discrepancies that may arise between the Contractor and COR. In addition, the CO shall use the accepted Government database for contractor performance assessments to document the Contractor’s performance.
4. TYPES OF WORK TO BE PERFORMED
The Contractor's performance in providing the following operation and maintenance services shall be evaluated by the Government:
a. Program management
b. Quality control
c. Aircraft maintenance
d. Aircraft availability and safety
e. Risk management
f. Recruitment and retention
g. Special operations support
h. Training
i. Operational Pilot support
j. Aircraft lease support
k. Aviation Communication Center support
I. Accounting support
m. Inventory management
n. Acquisition support
o. Information Technology support
p. Industrial Environmental Health and Safety support
q. Other services as described in the Performance Work Statement.
5. DEFINITIONS
Acceptable Quality Level: The minimum level of quality that will be accepted by the Government in order to meet the performance standards.
Deduction: Funds may be deducted from a monthly invoice for an egregious act or event, or if the same deficiency continues to occur. The Contractor will be notified immediately if such a situation arises. The
Contracting Officer in consultation with the Program Office will determine the amount of the deduction.
Amounts deducted are not recoverable. The assessment of deductions does not preclude the Contracting
Officer from initiating other applicable contraction actions and remedies, if applicable.
Functional Area: A logical grouping of performance standards.
Measures: The method of evaluating compliance with the standards.
Performance Requirement Summary (Attachment A): The Performance Requirements Summary
(PRS) depicts what the Government intends to monitor and inspect. The PRS identifies performance standards grouped into seven functional areas, and quality levels essential for successful performance of each requirement. The PRS is used by the Government when conducting quality assurance surveillance as a guide for assessing compliance in meeting Government standards.
Withholding: Amount of monthly fee invoice payment withheld pending correction of a deficiency. See attachment A for information on percentage of invoice amount that may be withheld for each functional area. Funds withheld from payment are recoverable, if the COR and Contracting Officer confirm resolution/correction and approve in writing. The contractor is then authorized to bill for authorized costs in the billing cycle for the following month.
6. QUALITY CONTROL PLAN
As a part of its agreement with the Government, the Contractor is required to develop, implement, and maintain a Quality Control Plan (QCP) that describes the methods it will use to review its performance to ensure it conforms to the performance requirements. Such reviews are performed by the Contractor in order to validate its operations, and assure the Government that the services meet the performance standards.
The Contractor's QCP shall include monitoring methods that ensure and demonstrate its compliance with the performance standards. The reports and other results generated by the Contractor's QCP activities shall be provided to the COR.
The frequency and type of the Contractor's reviews should be consistent with what is necessary to ensure compliance with the performance standards. The Contractor is encouraged not to limit its inspections to only the processes outlined in the Government's surveillance plan.
However, certain key documents must be produced by the Contractor to assure the Government that the services meet the performance standards. Some of the documentation that must be generated and made available to the COR are listed below. The list is intended as illustrative and is not all-inclusive. The
Contractor must develop and implement a program that addresses the specific requirement of each standard and the means it will use to document compliance.
• Written policies and procedures to implement and assess requirements of the standard
• Documentation and record keeping ensuring ongoing compliance with the standards (e.g., inventories, logbooks, register of receipts, reports)
• Staff training records
• Deficiency Report Forms (DRF)
• Investigative reports
• Records of investigative actions taken
• Equipment inspections
7. METHODS OF SURVEILLANCE
The method of surveillance is based on the performance criteria of the contract terms and specifications.
The Government will evaluate the performance objectives through both periodic and random inspections during each month. The Government will also solicit various customer input to evaluate the Contractor's performance. Both outstanding and unacceptable performance will be recorded. Each requirement will describe the tasks to be performed and the standard for successful performance. DEA intends to monitor and evaluate the Contractor's performance based on any or all of the following surveillance methods:
7.1 Scheduled Surveillance Inspections: This method consists of selected surveillance tasks by the Government, with established areas for evaluation to be completed on a quarterly, bi-annual or annual basis.
7.2 Random Surveillance Inspections: This method consists of informal periodic surveillance that does not require I 00 percent inspection and/or performed on a random basis. The
Government will evaluate the Contractor's reports, surveys, work product, etc. on a daily, weekly, biweekly, monthly, or quarterly basis.
7.3 Review of Documentation: The Contractor must develop and maintain all documentation as prescribed in the performance standards (e.g. log books, technical publications, policies, and records of corrective actions). In addition to the documentation prescribed by the standards, the Contractor must also develop and maintain documentation that demonstrates the results of its own inspections as prescribed in its QCP. The Government will review both forms of documentation to affirm that the conditions, policies/procedures, and handling of contract requirements conform to the performance standards stated herein. When reviewing the
Contractor's documentation, the Government may review 100 percent of the documents, or a representative sample. Documentation may be reviewed at periodic points throughout the period of performance.
The Government reserves the right to periodically inspect all services and deliverables prior to acceptance regardless if it is shown on the Performance Requirements Summary.
8. FUNCTIONAL PERFORMANCE AREAS AND STANDARDS
To facilitate the performance review process, the required performance standards are organized into seven functional areas corresponding to the requirements in the Performance Work Statement (PWS).
Each functional area represents a proportionate share (i.e., weight) of the monthly invoice amount payable to the Contractor based on meeting the performance standards. Payment withholding will be based on these percentages and weight applied to the overall monthly invoice.
DEA may unilaterally change the functional areas and associated standards affiliated with a specific functional area. The Contracting Officer will notify the Contractor at least 30 calendar days in advance of implementation of the new standard(s). If the Contractor is not provided with the notification, adjustment to the new standards must be made within 30 calendar days after notification. If any changes affect pricing, the Contractor may submit a request for equitable price adjustment in accordance with
Federal Acquisition Regulation clause 52.243-2 Alternate II Changes - Cost Reimbursement. DEA reserves the right to develop and implement new inspection techniques and instructions at any time during performance without advance notice to the Contractor, so long as the standards are not more stringent.
9. FAILURE TO MEET PERFORMANCE STANDARDS
Performance of services in conformance with the QASP standards is essential. The Contracting Officer may take deductions against the monthly fixed fee invoices for unacceptable performance documented through surveillance of the Contractor's activities gained through scheduled inspections or periodic inspections. As a result of its surveillance, the Contractor will be assigned the following rating relative to each performance standard:
Acceptable Based on the measures, the performance standard is demonstrated
Deficient
Based on the measures, compliance with the performance standard is demonstrated and observed with some area(s) needing improvement. There are no critical areas of unacceptable performance.
At-Risk Based on the performance measures, the performance standards are not met.
Rather than withholding funds until a deficiency is corrected, there may be times when an event or a deficiency is so egregious that the Government deducts (vs. "withholds") amounts from the Contractor's monthly fixed fee invoice. This may happen when an event occurs, such as Contractor's negligence, when a particular deficiency is noted two or more times without correction, or when the Contractor has failed to take timely action on a deficiency about which the Contractor was properly and timely notified.
The amount deducted will be consistent with the relative weight of the performance area where the deficiency was noted. The deduction may
Be a one-time event, or may continue until the Contractor has either corrected the deficiency, or made substantial progress in the correction.
Deductions and incentives will be applied to the contractor's monthly fixed fee. The contractor shall invoice the monthly fixed fee amount separately from the reimbursable costs so as not to delay reimbursement of allowable costs under the contract. If the contractor's monthly fixed fee invoice is not correct based on the deductions and/or incentives for that month, the Government will reject the fixed fee invoice and the contractor shall resubmit with the correct amount.
10. NOTIFICATIONS
Based on the inspection of Contractor's performance, the Government will document instances of deficient performance using the Deficiency Report Form (DRF) located at Attachment A. This form will identify the level of severity pertaining to the deficiency notices issued. To the extent practicable, issues should be resolved informally, with the Government and Contractor working together. When documentation of an issue or deficiency is required, the procedures set forth in this section will be followed.
When an ORF is required to document performance issues, it will be submitted to the Contractor with a date when a response is due. Upon receipt of a DRF, the Contractor must immediately assess the situation and either correct the deficiency as quickly as possible or prepare a correction action plan. In either event, the Contractor must return the DRF with the action planned or taken noted. After the
Government reviews the Contractor's response, the Government will either accept the plan or correction or reject the correction or plan for revision and provide an explanation. This process should take no more than two weeks. The DRF should not be used as a substitute for quality control by the Contractor.
The COR will maintain a record of all open and resolved DRFs.
The types ORF indicating the level of severity that can be issued are:
1. Discrepancy Notices (DN): This method of surveillance consists of reporting to the Contractor a minor contract discrepancy that could be corrected immediately without major expenditure of time, manpower, or money. Examples of a minor discrepancy are minor housekeeping discrepancies or minor clerical errors in documents.
2. Contractor Deficiency Notices (CON): This method of surveillance consists of reporting to the
Contractor a major contract deficiency that could result in lost time, money or DEA's ability to provide mission support Examples of major deficiencies are missing an aircraft delivery date or inaccurate record keeping.
3. Quality Deficiency Reports (QDR): This method of surveillance consists of reporting to the Contractor a critical deficiency that could result in damage or loss of government property or equipment, violation of safety procedures, or negligence causing unnecessary cost to the government. Examples of critical deficiencies are improper use of equipment or neglecting to follow proper procedures causing a safety issue.
4. Quality Deficiency Report-Safety of Flight Issue (QDR-SFI): This method of surveillance consists of reporting to the Contractor a serious deficiency of contract performance that could result in loss of life or aircraft.
11. ATTACHMENTS
A. Surveillance Plan
B. Deficiency Report Form
Attachment 1
Surveillance Plan
C.12.1.3 Safety Management System and Quality Control Program
Hazard Severity and Mishap Probability
Likely Probable
May Unlikely
Does the Contractor have objective evidence supporting compliance to the requirements set forth in Section C.12.1.3 Safety Management System and Quality Control?
1) C.12.1.3.1 General
2) C.12.1.3.2 Scheduled of Inspections
3) C.12.1.3.3 Documentation and Reports
4) C.12.1.3.4 Contractor’s Performance Review
5) C.12.1.3.5 Administration and Technical Publication Library
6) C.12.1.3.5.1 Specialized Technical Drawings and Illustrations
7) C.12.1.3.5.2 Government Ownership
8) C.12.1.3.6 Documentation Support
9) C.12.1.3.6.1 General
10) C.12.1.3.6.2 Maintenance Data Collection and Reporting
11) C.12.1.3.6.3 Aircraft Records Management
12) C.12.1.3.6.4 Forms
13) C.12.1.3.6.5 Quality Inspection
14) C.12.1.3.6.6 Aircraft Inventory
15) C.12.1.3.6.7 Stamping & Other Identification
16) C.12.1.3.6.8 Technical Data, Drawings and Illustrations
17) C.12.1.3.6.9 Newly Acquired Aircraft
Total Findings
18) C.12.1.3.6.10 Aircraft Weight and balance
19) C.12.1.3.6.11 Aircraft Configuration Management
20) C.12.1.3.6.12 Flight Operations Quality Assurance (FOQA)
C.12.2 Aircraft Maintenance forth in Section C.12.2 Aircraft Maintenance Program?
1) C.12.2.1 Aircraft Maintenance Program Objectives
2) C.12.2.2 Aircraft Maintenance Standards
3) C.12.2.3 Aircraft Support
4) C.12.2.4 Aircraft Maintenance and Inspection
5) C.12.2.4.1 Scheduled Maintenance
6) C.12.2.4.2 Unscheduled Maintenance
7) C.12.2.4.3 Maintenance Tracking
8) C.12.2.5 Aircraft Special Inspection Support
9) C.12.2.6 Overhaul and Repair Support
10) C.12.2.7 Aircraft Battery Maintenance Support
11) C.12.2.8 Sheet Metal Support
12) C.12.2.9 Welding and Fabrication Support
13) C.12.2.10 Avionics and Specialized Mission Equipment Support
14) C.12.2.10.1 Special Mission Equipment Support
15) C.12.2.11 Aircraft Ground Handling and Operations Support
16) C.12.2.12 Ground Support Equipment (GSE) Maintenance Support
17) C.12.2.13 Aircraft Servicing Support
18) C.12.2.14 Preservation/De-preservation Support
19) C.12.2.15 Foreign Object Damage (FOD) Control Support
20) C.12.2.16 Aircraft Tool Control Support
21) C.12.2.17 Precision Measurement Equipment Calibration and Certification
22) C.12.2.18 Aircraft Maintenance Testing Support
23) C.12.2.18.1 Maintenance Operational Check
24) C.12.2.18.2 Maintenance testing Support
25) C.12.2.19 FAA Systems and Structural Engineering and Technical Support
26) C.12.2.20 Aircraft and Equipment Recovery and Transport Support
27) C.12.2.21 Seasonal/Special Operations Surge Support
28) C.12.2.22 Aircraft Enhancements
29) C.12.2.23 Transport Aircraft Support
30) C.12.2.23.1 Operational Support
31) C.12.2.23.2 Maintenance Support
Surveillance Plan
C.12.4.3 Inventory Management Support
Hazard Severity and Mishap Probability Likely Probable May Unlikely
Does the Contractor have objective evidence supporting compliance to the requirements set forth in Section C.12.4.3 Inventory management Support?
Total Findings
C.12.4.3 Inventory Management Support. All aspects of Inventory management to include:
1) Supply
2) Material control
3) Property management
4) Shipping/receiving
5) Stock replenishment
6) Inventory control
7) Freight and transportation management
8) Surplus property
9) Serialized parts
10) Core exchanges
11) Tool control, and warranty program
C.11.11 Contractor Employee Training & C.11.12 Contractor Personnel Training and Certification Records
Does the Contractor have objective evidence that supports the training requirements set forth in Sections C.11.11.1 Maintenance Formal Training, C.11.11.2 Informal (On-Site) Training and C.11.12 Contractor Personnel Training and Certification Records?
1) C.11.11 Contractor Employee Training
2) C.11.11.1 Maintenance formal Training
3) C.11.11.2 Informal (on-site) Training
4) C.11.11.2A Maintenance OJT
5) C.11.11.2B Administrative Training
6) C.11.11.2C Safety Training
7) C.11.11.2D Security Training
8) C.11.11.2E Hazardous Material Control Training
9) C.11.12 Contractor Personnel Training and Certification Records
C.12.4.9 Industrial and Environmental Health and Safety (IEH&S) Support forth in Section C.12.4.9 Industrial and Environmental Health and Safety (IEH&S) Support?
1) C.12.4.9.1 General
2) C.12.4.9.2 Safety
3) C.12.4.9.3 Hazardous Material Control Support
4) C.12.4.9.3.1 Hazardous Communication
5) C.12.4.9.3.2 Permits and Certificates
6) C.12.4.9.3.3 Hazardous Waste Transportation
7) C.12.4.9.3.4 Hazardous Waste Storage
8) C.12.4.9.3.5 Hazardous Waste Disposal
9) C.12.4.9.3.6 Hazardous Waste Inspection/Audits
10) C.12.4.9.3.7 Hazardous Waste Recordkeeping
11) C.12.4.9.4 IEH&S Training
12) C.12.4.10 Recycling Support
The following guidance outlines the recommended audit schedule. The auditing protocols are evaluated to existing Contractor requirements i.e. Factor 1 - Management Approach, DEA Aircraft Operations Handbook, Performance Work Statement, Repair Station – Quality Control Manual for FAA Certificated Repair Station, Policy, Programs and Regulations: NAS 412 Foreign Object Damage/Foreign Object Debris (FOD) Prevention, 14 Code of Federal Regulations (CFR,) Advisory Circular (AC) 43.13-1B, AC 43.13-2B, the IBAC IS-BAO/SMS audit protocols for the appropriate stage of registration, including the requirements of ICAO Annex 6 Part II and the appropriate OEM Repair and Maintenance Manuals.
Auditing Protocols Frequency Guidance
Safety Management System and Quality Control Program
C.12.1.3.1 General, C.12.1.3.2 Scheduled of Inspections, C.12.1.3.3 Documentation and Inspections, C.12.1.3.4 Contractors Performance Review, C.12.1.3.5 Administration and Technical Publication Library, C.12.1.3.5.1 Specialized Technical Drawings and Illustrations, C.12.1.3.5.2 Government Ownership, C.12.1.3.6 Documentation Support, C.12.1.3.6.1 General, C.12.1.3.6.2 Maintenance Data Collection and Reporting, C.12.1.3.6.3 Forms, C.12.1.3.6.4 Quality Inspection, C.12.1.3.6.5 Aircraft Inventory, C.12.1.3.6.6 Stamping and Other
Four to five per Quarter *See Note
PWS Section, C.12.1.3
Repair Station Manual
AOH, Section 7 Maintenance of DEA Aircraft
Management Approach
IS-BAO Audit Protocol Element 3 Safety Management System
Identification, C.12.1.3.6.7 Technical Data, Drawings and Illustrations, C.12.1.3.7 Newly Acquired Aircraft, C.12.1.3.8 Aircraft Weight and balance, C.12.1.3.9 Aircraft Configuration Management.
Aircraft Maintenance
C.12.2.1 Aircraft Program Maintenance Objectives, C.12.2.2 Aircraft Maintenance Standards, C.12.2.3 Aircraft Support, C.12.2.4 Aircraft Maintenance and Inspection, C.12.2.4.1 Scheduled Maintenance, C.12.2.4.2 Unscheduled Maintenance, C.12.2.4.3 Maintenance Tracking, C.12.2.5 Aircraft Special Inspection Support, C.12.2.6 Overhaul and Repair Support, C.12.2.7 Aircraft battery Maintenance Support, C.12.2.8 Sheet Metal Support, C.12.2.9 Welding and fabrication Support, C.12.2.10 Avionics and Specialized Mission Equipment Support, Seven to eight
PWS Section, C.12.1.3
AOH, Section 7 Maintenance of DEA Aircraft
Management Approach
IS-BAO Audit Protocol Element 9 Aircraft Maintenance Management
C.12.2.11 Aircraft Ground Handling and Operational Support, C.12.2.12 Ground Support Equipment Maintenance Support, C.12.2.13 Aircraft Servicing Support, C.12.2.14 Preservation/De-preservation Support, C.12.2.15 Foreign Object Damage Control Support, C.12.2.16 Aircraft Tool Control Support, C.12.2.17 Precision Measurement Equipment Calibration and Certification, C.12.2.18 Aircraft Maintenance Testing Support, C.12.2.18.1 Maintenance Operational Check, C.12.2.18.2 Maintenance testing Support, C.12.2.19 FAA Systems and Structural Engineering and Technical Support, C.12.2.20 Aircraft and Equipment Recovery and Transport Support, C.12.2.21 Seasonal/Special Operations Surge Support, C.12.2.22 Aircraft Enhancements, C.12.2.23 Transport Aircraft Support, C.12.2.23.1 Operational Support, Two to three
C.12.2.23.2 Maintenance Support.
Inventory Management Support
C.12.4.3 Inventory Management Support
All aspects of Inventory management to include:
Supply, Material control, Property management, Shipping/receiving, Stock replenishment, Inventory control, Freight and transportation management, Surplus property, Serialized parts, Core exchanges, Tool control, and warranty program
Ensuring compliance with contract requirements, standards and regulations specific in paragraph C.
5.
Training
C.11.11 Contractor Employee Training, C.11.11.1 Maintenance formal Training, C.11.11.2 Informal (on-site) Training, A. Maintenance OJT
B .Administrative Training
Two per Quarter
PWS Section C.12.4.3
Supply Manager
AOH, Section 7.6 Maintenance of DEA Aircraft
Management Approach
IS-BAO Audit Protocol Element 9 Aircraft Maintenance Management, 9.1.4, f, g
PWS Section, C.11.11 and paragraph C.5.
AAOC Repair Station Manual, Section IV Training and Employee Summary
AOH, no requirement
C. Safety Training
D. Security Training
E. Hazardous Material Control Training
Industrial and Environmental Health and Safety
C.12.4.9.1 General, C.12.4.9.2 Safety, C.12.4.9.3 Hazardous Material Control, C.12.4.9.3.1 Hazardous Communication, C.12.4.9.3.2 Permits and Certificates, C.12.4.9.3.3 Hazardous Waste Transportation, C.12.4.9.3.4 Hazardous Waste Storage, C.12.4.9.3.5 Hazardous Waste Disposal, l C.12.4.9.3.6 Hazardous Waste Inspection/Audits, C.12.4.9.3.7 Hazardous Waste Recordkeeping, C.12.4.9.4 IEH&S Training, C.12.4.10 Recycling Support.
Three per Quarter *See Note
Management Approach- Maintenance Formal Training, Maintenance Formal Training, Informal (On-Site) Training, Maintenance OJT
IS-BAO Audit Protocol Elements 4 Organizational and Personnel Requirements’,
4.4 Maintenance personnel requirements’ and
Element 9 Aircraft Maintenance Requirements
PWS Section, C.12.4.9 repair Station Manual- No requirement
AOH, no requirement
IS-BAO Audit Protocol Element 12 Environmental Management, Element 13 Occupational Health and Safety and Element 14 Transportation of Dangerous Goods
NOTE: The idea is for a random sampling conducted over a 12 month period of the Contractors operations, and the outcomes of these audits. These audits may occur coincidentally with the Contractors internal audit schedules and/or external audit schedules, such as an FAA annual or no notice inspection.
Above all, it is never the intention to over audit the Contractor, or unduly delay the Contractor by an overabundance of audits or inspections. As example: if it is known that a particular area was recently audited, particularly if an area in question requires improvement. That/those area(s) should be bypassed until an acceptable corrective action has been implemented or possibly the next quarter.
Additionally, reliance should not predominantly fall upon internal Contractor audits or FAA/regulatory oversight or a failure-induced event to act as a trigger for corrective action by a Contractor, the window of opportunity for improvement would have already past.
A list of the Contractors audit schedule is available as a separate document.
Risk Assessment Code and Definition
Identify Hazards (Step 1) - Begin with an outline or chart of the major steps in the operation (operational analysis). Next, conduct a Preliminary Hazard Analysis by listing all of the hazards associated with each step in the operational analysis along with possible causes for those hazards.
Assess Hazards (Step 2) - For each hazard identified, determine the associated degree of risk in terms of probability and severity. The following severity and probability definitions and derived risk matrix shall be used to assign a RAC to each hazard.
Hazard Severity - An assessment of the worst potential consequence, defined by degree of injury, aircraft or property damage, environmental damage. Hazard severity categories are assigned by Roman numerals according to the following criteria:
o Category I – Catastrophic impact: The hazard may cause death, loss of aircraft or facility, major environmental impact.
o Category II – Serious impact: The hazard may cause severe injury, significant localized environmental damage, and major damage to aircraft.
o Category III – Minor impact: The hazard may cause minor injury, minor environmental effect, and minor damage.
o Category IV – Minimal impact: The hazard presents a minimal threat to personnel safety or property, minimal environmental impact.
Mishap Probability - The probability that a hazard will result in a mishap causing damage or injury.
Mishap probability subcategories are assigned a letter designation according to the following criteria.
o Subcategory A – Likely to occur immediately or within a short period of time. Expected to occur frequently to a person or an individual item or continuously to a group of people or inventory.
o Subcategory B – Probably will occur in time. Expected to occur several times to a person or individual item or frequently to a group of people or inventory.
o Subcategory C – May occur in time. Can reasonably be expected to occur sometime to a person or individual item or several times to a group of people or inventory.
o Subcategory D – Unlikely to occur.
Risk Assessment Code (RAC) - The RAC is an expression of risk that combines the elements of hazard severity and mishap probability. Using the matrix shown below, the RAC is expressed as a single numeric value that can be used to help determine hazard abatement priorities. RACs range from 1 to 5 where 1 is the highest risk and 5 the least.
RAC Definitions:
i. Critical risk
ii. Serious risk
iii. Moderate risk
iv. Minor risk
v. Negligible risk
PROBABILITY
A Likely
B Probable
C May
D Unlikely
I Catastrophic impact
Critical
Critical
Serious
Moderate
SEVERITY II
Serious impact
Critical
Serious
Moderate
Minor
III
Minor impact
Serious
Moderate
Minor
Negligible
IV
Minimal impact
Moderate
Minor
Negligible
Negligible
Note: In some cases, the worst credible consequence of a hazard may not correspond to the highest RAC for that hazard. For example, one hazard may have two potential consequences. The severity of the worst consequence (I) may be unlikely (D), resulting in a RAC of 3. The severity of the lesser consequence (II) may be probable (B), resulting in a RAC of 2. Therefore, it is also important to consider less severe consequences of a hazard if they are more likely than the worst credible consequence, since this combination may actually present a greater overall risk.
Make Risk Decisions (Step 3) - First, develop risk control options. Start with the most serious risk first and select controls that will reduce the risk to a minimum consistent with mission accomplishment.
With selected controls in place, decide if the benefit of the operation outweighs the risk. If risk outweighs benefit or if assistance is required to implement controls, communicate with higher authority in the chain of command.
Implement Controls (Step 4) - The following measures can be used to eliminate hazards or reduce the degree of risk. These are listed by order of preference:
Engineering Controls - Controls that use engineering methods to reduce risks by design, material selection or substitution when technically or economically feasible.
Administrative Controls - Controls that reduce risks through specific administrative actions, such as:
o Providing suitable warnings, markings, placards, signs, and notices.
o Establishing written policies, programs instructions and standard operating procedures (SOP).
o Training personnel to recognize hazards and take appropriate precautionary measures.
o Limiting the exposure to a hazard (either by reducing the number of assets or personnel, or the length of time personnel is exposed).
o If risk cannot be mitigated to an acceptable level where the benefits outweigh the residual risk the recommendation to terminate or not participate in the mission/activity shall be forwarded.
Attachment 2
Deficiency Report Form
Discrepancy Notice (DN)
Contract Deficiency Notice (CDN)
Quality Deficiency Report (QDR)
Part I
1. Contractor: L-3 Technologies, Vertex Aerospace
2. Contract Number: 3. Report Number:
4. To:
QAS/ DR Signature Date
Supervisor Signature Date
6. Does this Deficiency affect Safety of Flight?
Concur Non-concur
Yes No
ASAC Operational Support Part II
7. A response to this Deficiency Report shall be submitted, by Memorandum, to the COR by the suspense date indicated, providing the following:
(a) Reason for the Contract Deficiency.
(b) Action taken to correct the specific Contract Deficiency.
(c) Action taken to prevent a recurrence of the Contract Deficiency.
(d) Date for implementation of corrective action.
(Note: Discrepancy Notice, DN, do not require a response)
Suspense Date:
COR Signature Date Part III
8. Acceptance of Contractor’s response.
QAS/ DR Signature Date
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