S.
No Findings
1. The organization was not in compliance with Facility Cleanliness i.a.w. 145.70 –
Housekeeping as demonstrated by the below;
1 a. In the strip area containers were left on the floor with fluid residue. When questioned they
were advised as waiting for disposal.
And many unmarked fluid containers and hazardous material lying around the facility.
b. Old Fluid Spills on the floor not cleaned up.
c. Lack of clear hazardous warning visual displays on entrance of the strip room and on acid
tanks within the tanks.
2. The organization was not in compliance with maintenance records i.a.w. 145.55 –
Maintenance Records.
2 Job Card witnessed no AAMC/EK/GP/349 for Emirates R.O: RO 3369930 has validated task
entry signatures.
However there is no traceability as to who the signatures belong to.
3. Job Card witnessed no AAMC/EK/GP/349(AAMC/Prod/GPP/001) is missing a verification
3 task as follows:
a. Authorised staff to Final release product on Certificate of Conformity (C of C).
4. The organization was not in compliance with Quality, Safety regulation i.a.w. 145.65 as
follows:
a. In the procedure for Authorisation of Staff, AAMC-CS-001, the minimum information for
4 authorised staff is not being met as follows:
No records available the 2 authorised staff (Sivaraja K & Parthiban R) for the following
when records were asked to be presented.
i. Basic training not available
ii. Qualifications relevant to approval not available.
a. The organization was not in compliance with Quality, Safety regulation i.a.w. 145.65 &
Personnel requirements iaw 145. 30/145.30e / 145/35.
5 as follows:
b. In the procedure for Authorisation of Staff AAMC-CS-001 there is no mention or details of
what the scope of the approval covers for authorised staff. This procedure only covers
certifying staff history details such as experience, name , education etc..
The scopes should cover where applicable who can conduct In-process inspection/ Final
Inspection & generate the C of C release certificate, as a minimum.
c. There is no mention of the authorised staff mandatory training or what competency
requirements for staff.
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5. The organization was not in compliance with Certifying & Support Staff regulation i.a.w.
6 145.35 as follows:
a. No record of HF training was available for authorised staff Sivajara and other members of
staff.
6. The organization was not in compliance with Certifying & Support Staff regulation i.a.w.
145.35 as follows:
7 a. 2 members of staff were introduced as in-process inspectors located in a separate room on
the mezzanine floor of the building (Mr Kannan and Mr Nojir)
Neither staff member was listed on the company training skills matrix which
identifies all staff for training purpose
7. The organization was not in compliance with Personnel requirements regulation i.a.w.
145.30 as follows
8 a. There is no mention of training on company procedures. The skills matrix (covering
training) requires updating and detailed entries for all training with dates required plus
continuation dates.
8. The organization was not in compliance with Quality, Safety regulation i.a.w. 145.65 as
9 follows:
a. The QHSE Manual states in para 11.7 that periodic assessments of skills carried out.
No evidence was available of competency or skills assessments.
9. The organization was not in compliance with Quality, Safety regulation i.a.w. 145.65 as
follows:
10 SOP QA/Doc/286 R00 – plating of non critical cabin interior parts states in Para 1.5.5 that the
format of the C of C shall be in the Quality Manual. However no evidence of the format of the
C of C was found in the QM.
10. The organization was not in compliance with maintenance records i.a.w. 145.55 –
Maintenance Records as follows
Job cards do not define extent of acceptable/unacceptable ‘defects’.
11 No procedure covers what is an acceptable defect, however the ASTM B488-18 defines
defects in detail within Para 6.2.2. This definition should be transferred to AMC procedures
and consideration on a visual standard may be best practice in the future. This will provide
standardization.
There was no evidence of any training covering defects also.
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11. The organization was not in compliance with maintenance records i.a.w. 145.55 –
Maintenance Records
12 a. The last entry on job card AAMC/EK/GP/349 covers performing Final QC. And ensure
thickness of 2-3 microns of hard gold is achieved. The reference to the thickness is ASTM
B488-9.4.1. The actual thickness measurement process is in ref: 9.4.2 and should be added to
this job card reference.
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Root Cause
a) The residue chemical has been left due to delay in
disposal.
b) The area was cleaned up and fluid spills occurred
due to minor leakage in the storage containers
c) Hazardous warnings available are not sufficient
No Separate Signature record was available to trace the
task entry signature
Verification of final release of C of C is not recorded in
the Job Card
Training has been provided but Records for Basic
training and qualification relevant to the approval is not
recorded
Authorsiation procedure doesn’t cover the scope of the
approval of the authorised staff and the mandatory
training requirement such as basic training and training
needed for qualifying the product
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HF training was not taken by authorised staff Mr.
Sivaraja K due to the unavailability of the training
schedule from Emirates Engineering
Visual inspectors name was missed in the company
training skill matrix
Skill Matrix covers employees skill rating alone and it
does not covers the employee training requirement and
its continuation dates
Skill Matrix defines the employee skill level and the
respective competency assessment record was
unavailble
Unable to locate and link the format C of C in the QM
Detailed characteristics of the defects was not covered
in the Job card and no separate Visual aid is available to
illustrate the unacceptable defect
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ASTM B488.9.4.1 covers the basic principle of coating
thickness measurement and the procedure to measure
the thickness was mentioned in 9.4.2
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Corrective Action Implemented Date
a)containers were removed and the fluid residue were
disposed
b) Storage containers were replaced and the fluid spills 28.11.2020, 08.12.2020
were cleaned up
c) Hazardous warning signs were kept in all the
recommended area. Refer attached file
A separate signature record was created to record the
master signatures of all the staff . Ref: AAMC-SR-01-F1 28.11.2020
Employee Signature register
A verification check task has been added in all the Job
cards to ensure the final release product on Certificate of 28.11.2020
Conformity . Ref updated attached Job Cards
Basic training and the training under qualification under
approval has been provided to the authorised staff and 5/12/2020
its been recorded . Refer attached read and sign
Authorisation procedure has been revised including the
scope of authorised staff and the mandatory training
5.12.2020
requirements of the staff to be taken by the authorised
staff . Refer attached updated authorisation procedure
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Authorised staff has attended the HF course conducted
by an organization approved to the requirement of IR 4.12.2020
Part -147 by the UK Civil Aviation Authority which meets
the requirements for Part 145. a. 30 . Refer Attached
Certificate
Both the staffs name has been added in the updated skill
matrix and their continuation training date has been 5.12.2020
added in the training schedule. Refer updated skill matrix
A detailed training schedule for all the employee with
their mandatory training requirement and its
5.12.2020
continuation date has been added in the in training
schedule . Refer Training Schedule
Action in progress Action in progress
As suggested by the auditor, format of C of C has been
added in the SOPs of each process. Updated document 28.11.2020
attached . Refer attached updated SOP
Unacceptable defects types are transferred from ASTM
B488-18 para 6.2.2 to JC and SOPs and a Separate visual
aid illustration covering the unacceptable defects (AAMC- 6.12.2020
VA-01) has been added to JC. Training on the same is
taken by the visual inspectors and the certifying staffs.
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The reference entry was changed from 9.4.1 to 9.4.2 and 28.11.2020
the job card was revised . Refer attached JC
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Preventive Action Implemented date
A training was given to the staffs
working in the stripping area to create
28,11.2020 and 08.12.2020
an awareness and to report and to take
actions. Refer attached file
Periodic revision /updation is added for 28.11.2020
every two years
One time implementation 28.11.2020
The training requirement has been
added in the training schedule and its
5/12/2020
continuation training schedule has been
added.
One time implementation 5.12.2020
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HF training requirement was added in
the employee training record and its
5.12.2020
continuation training date has been
added.
One time implementation 5.12.2020
One time implementation 5.12.2020
Action in progress Action in progress
One time implementation 28.11.2020
Training for the identification of
unacceptable defects has been added in
6.12.2020
the training schedules and its
continuation date has been added
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One time implementation 28.11.2020
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Dear Sivaraja, Mrs Gupta,
Thank you for the documents sent yesterday and support during the audit yesterday.
Kindly find below all actions, as agreed last night.
For each Finding please provide the following by completing the below email and sending back to me to verify. There are som
A. Root Cause – what was the root reason for the problem
B. Corrective action. – What you did to immediately fix the problem.
C. Preventative action – what has been changed or improved to prevent the problem from reoccurring in the
Once done ill review your replies.
1. The organisation was not in compliance with Facility Cleanliness i.a.w. 145.70 – Housekeeping as demon
a. In the strip area containers were left on the floor with fluid residue. When questioned they were advised a
And many unmarked fluid containers and hazardous material lying around the facility.
b. Old Fluid Spills on the floor not cleaned up.
c. Lack of clear hazardous warning visual displays on entrance of the strip room and on acid tanks within the
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
2. The organisation was not in compliance with maintenance records i.a.w. 145.55 – Maintenance Records.
Job Card witnessed no AAMC/EK/GP/349 for Emirates R.O: RO 3369930 has validated task entry signatures.
However there is no traceability as to who the signatures belong to.
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
3. Job Card witnessed no AAMC/EK/GP/349(AAMC/Prod/GPP/001) is missing a verification task as follows:
a. Authorised staff to Final release product on Certificate of Conformity (C of C).
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
4. The organisation was not in compliance with Quality, Safety regulation i.a.w. 145.65 as follows:
a. In the procedure for Authorisation of Staff, AAMC-CS-001, the minimum information for aut
No records available the 2 authorised staff (Sivaraja K & Parthiban R) for the following when records we
i. Basic training not available
ii. Qualifications relevant to approval not available.
Root Cause:
Corrective action: Date of implementation:
# BUSINESS DOCUMENT This document is intended for business use and should be distributed to intended recipients only.
Preventative action: Date of implementation:
a. The organisation was not in compliance with Quality, Safety regulation i.a.w. 145.65 & Per
as follows:
b. In the procedure for Authorisation of Staff AAMC-CS-001 there is no mention or details of w
The scopes should cover where applicable who can conduct In-process inspection/ Final Inspecti
c. There is no mention of the authorised staff mandatory training or what competency require
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
5. The organisation was not in compliance with Certifying & Support Staff regulation i.a.w. 145.35 as follow
a. No record of HF training was available for authorised staff Sivajara and other members of st
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
6. The organisation was not in compliance with Certifying & Support Staff regulation i.a.w. 145.35 as follow
a. 2 members of staff were introduced as in-process inspectors located in a separate room on
Neither staff member was listed on the company training skills matrix which identifies all staff for train
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
7. The organisation was not in compliance with Personnel requirements regulation i.a.w. 145.30 as follows
a. There is no mention of training on company procedures. The skills matrix (covering training)
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
8. The organisation was not in compliance with Quality, Safety regulation i.a.w. 145.65 as follows:
a. The QHSE Manual states in para 11.7 that periodic assessments of skills carried out.
No evidence was available of competency or skills assessments.
# BUSINESS DOCUMENT This document is intended for business use and should be distributed to intended recipients only.
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
9. The organisation was not in compliance with Quality, Safety regulation i.a.w. 145.65 as follows:
SOP QA/Doc/286 R00 – plating of non critical cabin interior parts states in Para 1.5.5 that the format of the C of
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
10. The organisation was not in compliance with maintenance records i.a.w. 145.55 – Maintenance Records a
Job cards do not define extent of acceptable/unacceptable ‘defects’.
No procedure covers what is an acceptable defect, however the ASTM B488-18 defines defects in detail within
There was no evidence of any training covering defects also.
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
11. The organisation was not in compliance with maintenance records i.a.w. 145.55 – Maintenance Records
a. The last entry on job card AAMC/EK/GP/349 covers performing Final QC. And ensure thickne
Root Cause:
Corrective action: Date of implementation:
Preventative action: Date of implementation:
Other business Improvements identified worth considering as discussed in the closure meeting:
1. Use of magnifying glass for visual inspection recommended
2. Visual inspection standard recommended
3. Eye tests for personnel doing visual inspection recommended
4. Generate Index of all your procedures
5. In the QHSE the org chart does not have independent Quality and Operation
Action: You have 20 days to provide robust Root Cause / Corrective action and Preventative actions – deadlin
Please expedite and close actions in red within 7 days.
Please work on completing draft replies well in advance so I can review them after the holiday with you on De
Any questions please don’t hesitate to ask
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o me to verify. There are some urgent issues and actions that are priority – in red. Please expedite these urgently.
oblem from reoccurring in the future.
70 – Housekeeping as demonstrated by the below;
uestioned they were advised as waiting for disposal.
and on acid tanks within the tanks.
5.55 – Maintenance Records.
signatures.
verification task as follows:
ormity (C of C).
w. 145.65 as follows:
minimum information for authorised staff is not being met as follows:
he following when records were asked to be presented.
to approval not available.
# BUSINESS DOCUMENT This document is intended for business use and should be distributed to intended recipients only.
regulation i.a.w. 145.65 & Personnel requirements iaw 145. 30/145.30e / 145/35.
e is no mention or details of what the scope of the approval covers for authorised staff. This procedure only covers certifying staff history
cess inspection/ Final Inspection & generate the C of C release certificate, as a minimum.
g or what competency requirements for staff.
ulation i.a.w. 145.35 as follows:
ajara and other members of staff.
ulation i.a.w. 145.35 as follows:
ocated in a separate room on the mezzanine floor of the building (Mr Kannan and Mr Nojir)
hich identifies all staff for training purpose.
ation i.a.w. 145.30 as follows
skills matrix (covering training) requires updating and detailed entries for all training with dates required plus continuation dates.
w. 145.65 as follows:
ts of skills carried out.
# BUSINESS DOCUMENT This document is intended for business use and should be distributed to intended recipients only.
w. 145.65 as follows:
5.5 that the format of the C of C shall be in the Quality Manual. However no evidence of the format of the C of C was found in the QM.
5.55 – Maintenance Records as follows
efines defects in detail within Para 6.2.2. This definition should be transferred to AMC procedures and consideration on a visual standard
5.55 – Maintenance Records
g Final QC. And ensure thickness of 2-3 microns of hard gold is achieved. The reference to the thickness is ASTM B488- 9.4.1. The actual th
ecommended
recommended
endent Quality and Operations function, and this was not clear as to who does what. It would be beneficial to clarify and update your m
Preventative actions – deadline date is 24 th Dec 2020
fter the holiday with you on Dec 8/9 th.
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covers certifying staff history details such as experience, name , education etc..
s continuation dates.
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of C was found in the QM.
ideration on a visual standard may be best practice in the future. This will provide standardisation.
STM B488- 9.4.1. The actual thickness measurement process is in ref: 9.4.2 and should be added to this job card reference.
al to clarify and update your manual at the next available opportunity.
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ard reference.
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