Unscoped DCT Report (Standard DCT)

MLF Label: 4.6 Maintenance Special Requirements DCT Type: SP DCT Specialty: Airworthiness Peer Group: A - Part 121 Air Operators DCT Revision: 27.0 on 12/28/21 (Released)

Summary Information

Purpose (Certificate Holder Responsibility): The CH is responsible to manage the safety of the Maintenance Special Requirements processes within its operation.

The FAA objective is to determine if the CH; (1) Met regulatory requirements, guidance, and safety performance objectives of its
Objective (FAA Responsibility): Maintenance Special Requirements processes, and; (2) Managed safety of the Maintenance Special Requirements processes by
incorporating system safety principles which include safety attributes.

The Maintenance Special Requirements Subsystem includes the following Element(s)

4.6 Maintenance Special Requirements

4.6.1 (AW) Avionic Systems/Programs

4.6.2 (AW) Continued Airworthiness and Safety Programs

Questions Answers Comments

4.6.1 (AW) Avionics Special Emphasis Programs

1 Did the certificate holder meet its regulatory and guidance requirements for Avionics Systems/Programs?
◯ Met regulatory and guidance
requirements
REFERENCES: AC-91-85, AC-120-102, AC-120-28, AC-120-29, AC-120-59, AC-120-94, AC-20-141, 91.227, ◯ Isolated instance(s) when
8900.1 Vol 3 Ch 18 Sec 5, C048, D097, D301, A061, 8900.1 Vol 3 Ch 61 Sec 1, AC-120-76, 8900.1 Vol 4 Ch guidance requirements were
10 Sec 1, AC-20-165, 8900.1 Vol 4 Ch 14 Sec 8, 8900.1 Vol 4 Ch 14 Sec 9, 8900.1 Vol 4 Ch 15 Sec 1, 8900.1 not met
Vol 4 Ch 2 Sec 10, 121.1111, 121.1111(b), 121.1111(c), 121.1111(d), 121.1111(e), 121.344, 121.344a, ◯ Several instances when
121.346, 121.359, 121.359(h), 121.359(i), 121.359(k), 121.367, 121.369(b), 121.375, AC-119-1, 8900.1 Vol 6 guidance requirements were
Ch 11 Sec 24, 91 Appendix G, 91.180, 91.413, 91.413(a), 121.343 not met
◯ Regulatory noncompliance
Safety Attribute: Procedures, Question Type: Process Observation, ◯ Not Observable

Scoping Attribute: (FAR PART = "121" ) , Rev. 23 6/28/2021 11:19:32 AM,

QID: 00017498, Response Details: Procedures SP DCTs (Both OP and AW), Status: Released

2 Did the certificate holder's controls effectively mitigate unacceptable levels of risk(s) for the Avionics
◯ Controls were effective
Systems/Programs process?
◯ Isolated instance(s) when
controls were not effective
REFERENCES: 5.53, 5.55, 5.51 ◯ Several instances when
controls were not effective
Safety Attribute: Controls, Question Type: Process Observation, ◯ Systemic, significant issues, or
regulatory non-compliance
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:31 AM, ◯ Not Observable

QID: 00017499, Response Details: Controls ED/EP/SP DCTs (Both OP and AW), Status: Released

3 Did the certificate holder's Avionics Systems/Programs process ensure consistency of related processes
◯ Interfaces were effective
between departments and employees (interfaces)?
◯ Isolated instance(s) when
interfaces were ineffective
Safety Attribute: Interfaces, Question Type: Process Observation, ◯ Several instances when
interfaces were ineffective
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:31 AM, ◯ Systemic or significant issues
◯ Not Observable
QID: 00017500, Response Details: Interfaces ED/EP/SP DCTs (Both OP and AW), Status: Released

4 Were financial and human resources provided to ensure the safety and quality performance for the Avionics
◯ Management of the process
Systems/Programs process?
was effective
◯ Isolated instance(s) where
REFERENCES: 5.21, 5.23(a), 5.25(a), 5.25(b), 5.25(c) management of the process
was ineffective
Safety Attribute: Responsibility, Question Type: Process Observation, ◯ Several instances where
management of the process
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:31 AM, was ineffective
◯ Systemic, significant issues, or
QID: 00017501, Response Details: Responsibility ED/EP/SP DCTs (Both OP and AW), Status: Released regulatory non-compliance
◯ Not Observable

5 Did the person with authority over the certificate holder's Avionics Systems/Programs process effectively
◯ Management of the process
plan, direct, control, or change procedures, and make key determinations, including safety risk acceptance
was effective
decisions?
◯ Isolated instance(s) where
management of the process

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 Questions Answers Comments

REFERENCES: 5.23(a), 5.23(b), 5.25(c) was ineffective

◯ Several instances where
Safety Attribute: Authority, Question Type: Process Observation, management of the process
was ineffective
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:30 AM, ◯ Systemic, significant issues, or
regulatory non-compliance
QID: 00017502, Response Details: Authority ED/EP/SP DCTs (Both OP and AW), Status: Released ◯ Not Observable

6 Were the certificate holder's process measurement(s) used to evaluate the performance of the Avionics
◯ Process measurements were
Systems/Programs process and if necessary, implement corrective action?
effective
◯ Isolated instance(s) when
REFERENCES: 5.71, 5.73, 5.75 process measurements were
not used or ineffective
Safety Attribute: Process Measurement, Question Type: Process Observation, ◯ Several instances when
process measurements were
Scoping Attribute: (FAR PART = "121" ) , Rev. 6 6/28/2021 11:19:31 AM, not used or ineffective
◯ Systemic, significant issues, or
QID: 00017503, Response Details: Process Measurement ED/EP/SP DCTs (Both OP and AW), regulatory non-compliance
Status: Released ◯ Not Observable

7 Did the certificate holder's personnel understand their role and contribute to the safety performance of the
◯ Individuals were
Avionics Systems/Programs process?
knowledgeable
◯ Isolated instances where
REFERENCES: 5.23(a), 5.91, 5.93 knowledge was lacking
◯ Several instances where
Safety Attribute: Safety Ownership, Question Type: Process Observation, knowledge was lacking
◯ Systemic, significant issues, or
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:30 AM, regulatory non-compliance
◯ Not Observable
QID: 00017504, Response Details: Safety Ownership ED/EP/SP DCTs (Both OP and AW), Status: Released

4.6.2 (AW) Maintenance Special Emphasis Programs

8 Did the certificate holder meet its regulatory and guidance requirements for Continued Airworthiness and
◯ Met regulatory and guidance
Safety Programs?
requirements
◯ Isolated instance(s) when
REFERENCES: AC-120-102, AC-120-104, AC-120-73, AC-120-93, AC-120-94, AC-120-97, AC-120-98, AC- guidance requirements were
25.1529-1, D097, D105, AC-43-208, 119.51, 8900.1 Vol 4 Ch 6 Sec 4, 121.1105(b), 121.1105(c), not met
121.1105(d), 121.1105(e), 121.1107(a), 121.1109, 121.1109(c), 121.1111, 121.1111(b), 121.1111(c), ◯ Several instances when
121.1111(d), 121.1111(e), 121.1113, 121.1113(b), 121.1113(c), 121.1113(d), 121.1113(e), 121.1113(f), guidance requirements were
121.1115(b), 121.1115(c), 121.1115(d), 121.1115(e), 121.1115(f), 121.1117(b), 121.1117(c), 121.1117(f), not met
121.1117(h), 121.309(b), 121.369(c), 121.380(a), 121.703, 121.703(a), 121.703(c), 8900.1 Vol 6 Ch 11 Sec ◯ Regulatory noncompliance
23, 8900.1 Vol 6 Ch 11 Sec 24, 25.981, 26.33, 26.35(d), 39.11, 39.7, 91.403(c) ◯ Not Observable

Safety Attribute: Procedures, Question Type: Process Observation,

Scoping Attribute: (FAR PART = "121" ) , Rev. 19 12/28/2021 9:34:02 AM,

QID: 00017505, Response Details: Procedures SP DCTs (Both OP and AW), Status: Released

9 Did the certificate holder's controls effectively mitigate unacceptable levels of risk(s) for the Continued
◯ Controls were effective
Airworthiness and Safety Programs process?
◯ Isolated instance(s) when
controls were not effective
REFERENCES: 5.53, 5.55, 5.51 ◯ Several instances when
controls were not effective
Safety Attribute: Controls, Question Type: Process Observation, ◯ Systemic, significant issues, or
regulatory non-compliance
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:28 AM, ◯ Not Observable

QID: 00017506, Response Details: Controls ED/EP/SP DCTs (Both OP and AW), Status: Released

10 Did the certificate holder's Continued Airworthiness and Safety Programs process ensure consistency of
◯ Interfaces were effective
related processes between departments and employees (interfaces)?
◯ Isolated instance(s) when
interfaces were ineffective
Safety Attribute: Interfaces, Question Type: Process Observation, ◯ Several instances when
interfaces were ineffective
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:28 AM, ◯ Systemic or significant issues
◯ Not Observable
QID: 00017507, Response Details: Interfaces ED/EP/SP DCTs (Both OP and AW), Status: Released

11 Were financial and human resources provided to ensure the safety and quality performance for the
◯ Management of the process
Continued Airworthiness and Safety Programs process?
was effective
◯ Isolated instance(s) where
REFERENCES: 5.21, 5.23(a), 5.25(a), 5.25(b), 5.25(c) management of the process
was ineffective

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 Questions Answers Comments
Safety Attribute: Responsibility, Question Type: Process Observation, ◯ Several instances where
management of the process
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:28 AM, was ineffective
◯ Systemic, significant issues, or
QID: 00017508, Response Details: Responsibility ED/EP/SP DCTs (Both OP and AW), Status: Released regulatory non-compliance
◯ Not Observable

12 Did the person with authority over the certificate holder's Continued Airworthiness and Safety Programs
◯ Management of the process
process effectively plan, direct, control, or change procedures, and make key determinations, including
was effective
safety risk acceptance decisions?
◯ Isolated instance(s) where
management of the process
REFERENCES: 5.23(a), 5.23(b), 5.25(c) was ineffective
◯ Several instances where
Safety Attribute: Authority, Question Type: Process Observation, management of the process
was ineffective
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:27 AM, ◯ Systemic, significant issues, or
regulatory non-compliance
QID: 00017509, Response Details: Authority ED/EP/SP DCTs (Both OP and AW), Status: Released ◯ Not Observable

13 Were the certificate holder's process measurement(s) used to evaluate the performance of the Continued
◯ Process measurements were
Airworthiness and Safety Programs process and if necessary, implement corrective action?
effective
◯ Isolated instance(s) when
REFERENCES: 5.71, 5.73, 5.75 process measurements were
not used or ineffective
Safety Attribute: Process Measurement, Question Type: Process Observation, ◯ Several instances when
process measurements were
Scoping Attribute: (FAR PART = "121" ) , Rev. 6 6/28/2021 11:19:27 AM, not used or ineffective
◯ Systemic, significant issues, or
QID: 00017510, Response Details: Process Measurement ED/EP/SP DCTs (Both OP and AW), regulatory non-compliance
Status: Released ◯ Not Observable

14 Did the certificate holder's personnel understand their role and contribute to the safety performance of the
◯ Individuals were
Continued Airworthiness and Safety Programs process?
knowledgeable
◯ Isolated instances where
REFERENCES: 5.23(a), 5.91, 5.93 knowledge was lacking
◯ Several instances where
Safety Attribute: Safety Ownership, Question Type: Process Observation, knowledge was lacking
◯ Systemic, significant issues, or
Scoping Attribute: (FAR PART = "121" ) , Rev. 5 6/28/2021 11:19:27 AM, regulatory non-compliance
◯ Not Observable
QID: 00017511, Response Details: Safety Ownership ED/EP/SP DCTs (Both OP and AW), Status: Released

Response Details List Authority ED/EP/SP DCTs (Both OP and AW) (Released, 1.0)

1 Process oversight failure

2 Unacceptable safety risk acceptance

3 Ineffective planning of resources

4 Ineffective use of resources

5 Ineffective control of resources

6 Failure to implement safety risk processes

7 Process owner not clearly identified

8 Unqualified

9 Other

Response Details List Controls ED/EP/SP DCTs (Both OP and AW) (Released, 1.0)

1 Failure to identify hazards or ineffective risk controls

2 Failure to develop and maintain risk controls

3 Failure to effectively mitigate risk before applying risk controls
4 Risk controls ineffective
5 Unclear risk controls

6 Failure to assess risk for a new system

7 Failure to assess risk when revising an existing system
8 Failure to assess risk when developing operational procedures
9 Failure to maintain records of outputs of risk control assessments

10 Other

Response Details List Interfaces ED/EP/SP DCTs (Both OP and AW) (Released, 1.0)

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1 Internal communication failure(s)
2 External communication failure(s)
3 Lack of interfaces

4 Inconsistent interfaces
5 Poor coordination between departments and employees
6 Failure of interfaces between processes or procedures
7 Other

Response Details List Procedures SP DCTs (Both OP and AW) (Released, 1.0)

1 Unclear procedure(s)
2 Conflicting procedure(s)
3 Used workaround(s)
4 Skipped process step(s)

5 Personnel failed to follow process (procedures, guidance, etc)

6 Procedures/guidance not available
7 Procedures/guidance not current
8 Inconsistent procedure(s)

9 Undocumented procedure(s)
10 Minor typographical error(s) (i.e. record entries)
11 Information missing
12 Communication failure(s)

13 Personnel failed to perform task

14 Process failed to meet desired outcome
15 Process oversight failure

16 Equipment/tools not available

17 Equipment/tools not adequate
18 Equipment/tools not calibrated

19 Facilities not adequate

20 Other

Response Details List Process Measurement ED/EP/SP DCTs (Both OP and AW) (Released, 1.0)

1 Inadequate monitoring of operations processes

2 Ineffective evaluations of processes or systems

3 Undocumented or insufficient investigations

4 Failure to conduct audits

5 Ineffective audits
6 Failure to detect changes in the operational environment

7 Personnel failed to perform/follow process (procedures, guidance, etc.)

8 Process failed to meet desired outcome

9 Process oversight failure

10 Other

Response Details List Responsibility ED/EP/SP DCTs (Both OP and AW) (Released, 1.0)

1 Failed to provide financial resources

2 Failed to provide sufficient human resources

3 Individual not clearly identified

4 Failure to ensure safety of process
5 Failure to oversee operations conducted under the certificate

6 Failed to ensure quality performance of process

7 Process oversight failure
8 Communication failure(s)

9 Other

Response Details List N/O Response Detail (Released, 2.0)

1 Personnel (e.g., key certificate holder personnel not present/available)

2 Equipment (e.g., equipment not present/available/in serviceable condition)

3 Event did not occur (e.g., did not observe an intoxicated passenger on the flight)
4 Time Constraints (e.g., resources/workload)

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5 Weather (e.g., weather needed for observation not present or weather made observation impossible)
6 Other

Response Details List Safety Ownership ED/EP/SP DCTs (Both OP and AW) (Released, 3.0)

1 Unaware of or ineffective safety policies or processes

2 Unaware of or ineffective safety related reporting tools
3 Unclear safety policy
4 Ineffective safety related training
5 Lack of safety culture
6 Unclear safety objectives
7 Other

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