CASS (FAR 121.373)
Frequently ignored . . . source of violations
By Stephen P. Prentice
Some big name brand airlines have recently been nailed for failing to implement or maintain an active Continuous Analysis and Surveillance System (CASS) which is required of all FAR 121 air carriers and FAR 135 carriers operating aircraft with 10 or more seats. This not only brings violations against the carrier but in some cases could threaten chief inspectors, directors of maintenance, and company executives. When a CASS report is filed with the FAA there is always the threat of enforcement action where data was false or intentionally falsified.
FAR 121.373a —
"Each certificate holder shall establish and maintain a system for the continuing analysis and surveillance of the performance and effectiveness of its inspection program and the program covering other maintenance, preventive maintenance, and alterations and for the correction of any deficiency in those programs, regardless of whether those programs are carried out by the certificate holder or by another person."
All of us who work in the air carrier arena should be interested in this system because what we do directly impacts the data collected for inclusion in the system. Your company is mandated to provide such a system that watches over the total operation of inspection and maintenance. No matter how big or small the carrier, the requirements are the same.
The mandate, in effect, establishes a quality control and internal audit function that is very broad and will include such things as examination and analysis of powerplant teardown reports, pilot reports, and other significant data in order to adjust maintenance and operations practices. This is where technician and flight department input becomes important.
The CASS should bring together many departments including inspection, maintenance, operations, records and administration, and all are charged with the duty of putting together the gathered data for detailed analysis by the CASS staff.
The Continuous Analysis and Surveillance System (CASS) was created some 40 years ago as a mandatory FAR and left to languish without any substantial compliance by the air carriers or enforcement by the FAA. Even though a monthly report is usually required there was no significant enforcement reported. It was virtually ignored.
The Alaska Airlines accident case changed all this. It focused a spotlight on CASS because of the finding that it just did not exist or was improperly implemented. The horde of inspectors that descended on Alaska had to find a laundry list of violations. CASS was a likely suspect and easy to check on. The lack of a CASS program however, did not cause the accident. Simple maintenance negligence was more likely the culprit. The problem was found to have involved a lack of proper lubrication and excessive wear on the acme threaded stabilizer trim drive. FAA felt that a functioning CASS might have detected this fault before the accident occurred.
After that accident FAA inspectors at other air carriers were directed to pay special attention to FAR 121.373. A special inspection of some 25 major airlines was ordered to determine the status of their CASS. The results of these special inspections were so controversial and damming that the FAA refused to release them for almost two years. Now CASS has become a primary focus of FAA inspectors assigned to air carriers. The absence of any kind of system (frequently the case) or improper operation has been the source of many civil penalty cases.
The FARs give a lot of leeway to the carrier in the structure and procedures concerned with the program. But the FAA provides guidelines that are to be followed. However, the FAA retains the right to point out any deficiencies it deems require attention. It may force changes in your program if it doesn't like it.
Continuous Analysis and Surveillance FAR 121.373a: No surveillance ... no analysis
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