Review of Regulations PCAR Part 9

This report aims to present an evaluation of the regulatory requirements and its application to the
establishment of a Quality System and Management of an AOC in the Philippines.
Quality System: A Simultaneous NEED and a MUST
Simplifying PCAR 9.2.2.3, an operator must have a Quality System for the following function:
MONITOR COMPLIANCE WITH PROCEDURES (approved, required, and used by the operator as well)

TO ENSURE SAFE OPERATION OF AIRCRAFT

This is based on the first section as shown in the following reference.
Ref: PCAR 9.2.2.3.(a)

To further justify, the phrase safe operation of aircraft in its fullest sense elaborates already
that aircraft cannot be operated safely if it is first, not airworthy. Therefore it will be the objective of the
AOCs Quality System to MONITOR that required Maintenance Services are being done on the aircraft in
accordance with approved manuals and requirements (i.e. MCM, AMM, AMP, ADs) which result to an
airworthy fleet.
On the aspect of operations, the Quality System also MONITORS the Ground Ops, Flight Ops,
Inflight Svcs, and all other processes being done prior to, during, and after each flight to make sure that
all these respective departments, personnel, and service providers of the AOC follow their procedures
and policies as granted approval by the Authority. These collective compliance efforts result to safe
operations.
Safe Operations + Airworthy Fleet = Regulatory-Compliant AOC
= Quality Air Transportation from AOC
= Happy customers (passengers)
= Successful Airline
This is what CAAP basically wants. No incidents, no overruns, no delays and cancellations (as
far as controllable factors are concerned), no negative remarks from passengers and complaints, no
malpractice, no violation of policies and procedures, and lastly, no accident.
How does this start? A Quality Systems MONITORING is led by a Quality Manager (in our case,
the QSS Director) who directly reports to the Accountable Manager (Sir Mike Shau).

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The process is simple. The Qua. Mgr designs his feedback system (reporting) and may
coordinate with the Acc. Mgr to ensure corrective action is implemented if ever one of the AOCs
branches fail to deliver compliance.
Shown next is the whole reference.
Ref: PCAR 9.2.2.3

To strengthen further, section (b) highlights what the Quality System must equip itself with: its
Quality Assurance Program. This is what the Quality System will use in carrying out its MONITORING of
compliance. Procedures with this must be designed strongly to provide due verification that all the
AOCs elements discussed in the previous page are compliant to all applicable standards and
requirements. In addition to necessary Corrective Actions, Preventive Actions shall also aid in
maintaining the quality of every aspect which might have failed, to ensure recovery and continuity in
compliance.
The remaining sections are simple reinforcements to section (a) as far as the Quality Systems
objective is concerned. Section (e) may not be applicable since one Director can effectively suffice as
the Quality Manager while (f) is not applicable also since Cebgo certainly has no AMO approval.

Quality System Reiterated: A Redundancy DUE TO 9.4.1.2 Maintenance Responsibility

The Quality System is again highlighted in PCAR 9.4.1.16, because of the Maintenance
Responsibility (PCAR 9.4.1.2) of an AOC in maintaining the airworthiness of its fleet. The Quality System
bases its MONITORING of the AOCs Aircraft Maintenance Requirements by verifying compliance with
the principles of this Subpart (the catch : has to be in accordance with straightforward Implementing
Standards PCAR IS 9.2.2.3 2.0)
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Shown next are the references.

Ref: PCAR 9.4.1.16

Ref: PCAR IS 9.2.2.3 2.0 (a)

Sub-contracting Quality Assurance: Is it ALLOWED?

Yes, as per the provisions of PCAR IS 9.2.2.3 4.0, the Carrier has the option to avail of third-party
auditors in providing the services and actions required to fulfill the objective of the Quality System.
Reference is shown straightforward below.
Ref: PCAR IS 9.2.2.3 4.0

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This is also supported by PCAR IS 9.2.2.3 3.5, stating that the Quality System of an AOC can
avail of Auditors belonging to a separate Quality System of another organization (external) as long as
the Authoritys requirements of the criteria are satisfied.
Ref: PCAR IS 9.2.2.3 3.5

As far as sub-contracting Quality Auditors to satisfy PCAR 9.2.2.3, an operators Quality System
should still adhere to its core objective. Thus, by availing of external auditors to undertake the activities
needed for Quality Assurance, the Quality Systems responsibility will always remain with it similar to
Cebgos Engineering and Management teams accountability to its Maintenance Responsibilities to the
Authority even if A+ / SIAEC / SIAEP fails in their deliverables. This is shown in the next statement and
reference, PCAR 9.2.2.3 IS 6.3.4
THE OPERATOR CARRIES ULTIMATE RESPONSIBILITY for the QUALITY SYSTEM,

whatever arrangements may be made if sub-contracting Quality Assurance services is concerned.

Ref: PCAR IS 9.2.2.3 6.3

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It is also interesting to note that this sub-contracting may also be done in parallel with subcontracting maintenance services with an AMO. PCAR 9.4.1.5 supports sub-contracting maintenance
requirements of an AMO to enable the Operator in complying with its responsibilities through a written
maintenance contract agreement between them. Though as highlighted in this subpart, the Quality
function support which may be included in the agreement, implies that personnel can also be subcontracted from the AMO to sustain/ensure functioning of the Operators Quality System.
Ref: PCAR 9.4.1.5

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