Internal

Evaluation
Program
Manual

Uncontrolled copy when downloaded or printed from an electronic document. IEP

Uncontrolled copy when downloaded or printed from an electronic document.

IEP
 Internal Evaluation Program Manual
Preface

Preface

PRF.1 Intent
This manual is intended to stress self audit responsibilities of individual employees as well as the
evaluation responsibilities of top management to ensure that company policies and procedures
provide for safety and regulatory compliance and allow individuals to work safely and efficiently.

PRF.2 Compliance
The procedures and policies in this manual are to be followed by all company and contracted per-
sonnel.

PRF.3 Proposing Manual Changes

The Director of Safety has the authority to make changes to this manual. Forward all requested
changes to this manual via email or telephone to the Director of Safety. Reference the SME list on
the company intranet for the SMEs name and phone number, or submit the change to your super-
visor or company contact.

PRF.4 Manual Revision Status

The effective date of the current revision to this manual will be tracked on the Manual Status
Report. Each page of this manual will have a revision number and date on it. The manual may be
verified for currency and completeness, by referencing the List of Controlled Pages (LCP).

PRF.5 Classification of this Publication

Non-Regulated
This publication is classified as Non-Regulated.

PRF.6 Proprietary Company Information

The information contained herein is considered proprietary to Chautauqua Airlines. Any reproduc-
tion or release of this information without the express written consent of Chautauqua Airlines is pro-
hibited.

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 Internal Evaluation Program Manual
Record of Revisions

Record of Revisions

Record the revision number and date of insertion on this page. All additions, corrections, or
changes to manuals will be issued as manual revisions and will be numbered in ascending numer-
ical sequence. Revisions shall be incorporated into the manual as soon as possible, but no later
than the published effective date, and shall not be inserted out of numerical sequence unless so
instructed on the Instruction page that accompanies the revision.

Rev. No. Date Inserted Initials Rev. No. Date Inserted Initials
00 Original - 15 JAN 2004 TR 25

01 03/15/04 TR 26

02 05/01/04 TR 27

03 08/15/04 CC 28

04 11/01/04 TR 29

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14 03/01/08 KB 39

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 Internal Evaluation Program Manual
Record of Bulletins

Record of Bulletins

Bulletins are issued on an as needed basis to convey timely information. Bulletin information may
supersede current information found in this manual or introduce new procedures due to changes
in the regulatory or operating environment. Bulletins are inserted in the area so designated in the
“Placement” section, at the top of the page, for each part of the bulletin. Their insertion or removal
is recorded below. CD-ROM versions of this manual will have the bulletin inserted, the bulletin
Record page updated, and a list of all active bulletins will be printed on the CD. Bulletins will be
removed once the material covered is incorporated into a manual revision (usually the next revi-
sion), or is no longer valid. Bulletins will be numbered consecutively unless otherwise noted. It is
the responsibility of the manual holder to insert bulletins by the date specified on the Manual Status
Report..

Bulletin Date Chapter/Page Date

Subject
Number Issued Location Removed

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Location

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Revision Highlights

Revision Highlights

Revision 15 is a reissue of the Internal Evaluation Program Manual in V2 format.

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List of Controlled Pages

List of Controlled Pages

Page Revision Number/Date Page Revision Number/Date

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Non-Regulated

This manual is not part of the controlled manual

system as defined in 14 CFR 121.133.

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 Internal Evaluation Program Manual
Table of Contents

Table of Contents

Preface.........................................................................................................PRF-1
PRF.1 Intent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PRF-1
PRF.2 Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PRF-1
PRF.3 Proposing Manual Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PRF-1
PRF.4 Manual Revision Status. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PRF-1
PRF.5 Classification of this Publication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PRF-1
PRF.6 Proprietary Company Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PRF-1

Record of Revisions..................................................................................ROR-1
Record of Bulletins....................................................................................ROB-1
Revision Highlights ...................................................................................HGH-1
List of Controlled Pages ............................................................................LCP-1
Table of Contents ...................................................................................... TOC-1

Chapter 1. Definitions
1.1 Terminology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-1
1.1.1 Internal Evaluation Safety Program: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-1
1.1.2 Comprehensive Evaluations: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-1
1.1.3 Ongoing Evaluations: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-1
1.1.4 Special Evaluations: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-1
1.1.5 Control: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-2
1.1.6 Corrective Action: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-2
1.1.7 Satisfactory Fix: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-2
1.1.8 Evidence: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-2
1.1.9 Inspections: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-2
1.1.10 Audits: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-2
1.1.11 Evaluation: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-3
1.1.12 Class A Findings:. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-3
1.1.13 Class B Findings:. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-3
1.1.14 Concerns: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-3
1.1.15 Repeat Findings: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-3
1.1.16 Follow up Inspections: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-3
1.1.17 Safety Coordinator/Specialist Qualifications:. . . . . . . . . . . . . . . . . . . . . . . .1-4
1.1.18 Safety Coordinator/Specialist Training . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-4

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Chapter 2. Internal Evaluation Program Elements

2.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-1
2.2 Program Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-1
2.3 Audit Schedules . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-2
2.3.1 Department Audit Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-2
2.3.2 Station Audit Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-2
2.3.3 Safety Department Audit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-2
2.3.4 Drug and Alcohol Testing Program, Publications and System
Controls Audits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-2
2.4 Auditing Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-2
2.4.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-2
2.5 Responding to Findings/Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-4
2.5.1 Resolving Discrepancies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-4
2.5.2 Internal Evaluation Program Modifications: . . . . . . . . . . . . . . . . . . . . . . . . . .2-4
2.6 Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-5

Chapter 3. Areas Covered During Evaluations

3.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-1
3.2 Areas Evaluated . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-1
3.2.1 Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-1
3.2.2 Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-2
3.2.3 Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-2
3.3 Checklists . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-3

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Chapter 1 Definitions
1.1 Terminology

Chapter 1
Definitions

1.1 Terminology
The following pages identify certain terminology, phrases and acronyms that the Safety and Com-
pliance Department use throughout this manual and in its daily activities.

1.1.1 Internal Evaluation Safety Program:

The definition of the Internal Evaluation Safety Program is recognized by the FAA and through-
out the industry as follows:
- A continual process incorporating audits, evaluations and inspections that assesses the
adequacy of managerial controls within the key programs and systems of the airline.
- A review that extends beyond regulatory compliance to determine the cause of deficiencies
and detect needed enhancements to company operating practices before deficiencies
occur.
- An ongoing function that identifies deficiencies, develops corrective action
recommendations to correct these deficiencies, and performs follow-up evaluations.
- An autonomous function that has straight-line reporting responsibility to top management.
The Internal Evaluation Program should not be misunderstood as a program that replaces
existing regulatory auditing requirements. The internal evaluation concept stresses self-audit
responsibilities of individual employees as well as the evaluation responsibilities of top man-
agement to ensure that company policies and procedures provide for safety and regulatory
compliance and allow individuals to work safely and efficiently.

1.1.2 Comprehensive Evaluations:

A Comprehensive Evaluation is a periodic review, analysis and inspection of maintenance,
flight operations, customer service, security, ground support and administration departments.

1.1.3 Ongoing Evaluations:

An Ongoing Evaluation consists of continual day-to-day reviews and audits performed by the
maintenance, flight operations, customer service, security, ground support and administration
departments. Because the airline's Vice Presidents, Directors, Managers and Supervisors are
in the best position to properly identify and correct deficiencies, the responsibility for ongoing
evaluation rests with them.

1.1.4 Special Evaluations:

A Special Evaluation normally consists of unannounced audits and/or inspections of specific
areas within the maintenance, flight operations, customer service, ground support and/or
administration departments. There are a wide variety of reasons an evaluation of this sort may
be conducted, including:
- FAA/NTSB/DoD concerns.
- President & CEO and/or Department VP priorities.
- Industry identified hazards and trends.
- Voluntary Disclosures.
- Follow up on previous inspections or evaluations, either internal or external.
- Trends and/or concerns communicated to the department via an associate's report.
- A random selection of certain locations or departments within areas of concern.

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1.1.5 Control:
A control is a key procedure, responsibility or decision-making process within the company
organization. Comprehensive evaluations will focus on verifying and testing the controls within
the maintenance, flight operations, customer service and ground support and administration
departments.

1.1.6 Corrective Action:

A corrective action is an action, or the actions, taken to prevent the recurrence of a finding.
Management from the involved departments proposes a corrective action with the Safety and
Compliance Department.

1.1.7 Satisfactory Fix:

A satisfactory fix is a corrective action in which all corrective measures identified in the fix have
been completed by the effective department to the satisfaction of the Safety and Compliance
Department within a predetermined amount of time.

1.1.8 Evidence:
Evidence is a statement of fact prepared by a Coordinator/Specialist that is based on obser-
vations, measurements or tests that can be verified. Evidence should generally be in the form
of a written document or report that supports the Safety and Compliance Department's anal-
ysis and review. This data is necessary to substantiate findings or concerns and to enable
management or evaluators to determine the root cause of any reported finding. Objective evi-
dence generally comes from the following elements:
- Documents or manuals reviewed.
- Equipment examined.
- Activities observed.
- Interview data.

1.1.9 Inspections:
An inspection consists of observing a particular event or action to ensure that correct policy,
procedures and requirements are followed. The primary purpose of an inspection is to verify
that established standards are followed during the observed event or action.

1.1.10 Audits:
An audit is a methodical, planned review of actual business practices compared with estab-
lished policy and procedures. A Coordinator/Specialist may:
- Interview Personnel
- Review Documents
- Observe Operations
- Select Samples
- Inspect activities
- Document results
An audit builds on the principles of inspection. The results of inspection assist in the audit
objective of determining whether business is being conducted in accordance with established
policies and procedures. During an audit, qualified personnel look for the existence of a sys-
temic problem, but do not estimate the size of a problem, and will keep in mind the company’s
“Risk Assessment Program” which is outlined in the Safety Policies and Procedures Manual,
SPPM, when assigning levels of concern. The results (findings and concerns) of an audit
should be documented and presented to Management who then decides how to address the
audit results.
NOTE: The information gathered in the audit will be confidential and is considered privileged under
Chautauqua Airlines Safety Department policy. If you should choose to share this information with
any third party, you do so at your own accord.

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Chapter 1 Definitions
1.1 Terminology

1.1.11 Evaluation:
An evaluation is an independent review of company policies, procedures and systems. An
evaluation should be a comprehensive and continual process that considers the results of
audits, overall effectiveness of the management organization in achieving stated objectives,
and the ability of management to respond to new challenges. The evaluation process builds
on the concept of audits and inspections. An evaluation is a predictable process and is
designed to identify and correct potential findings before they occur.

1.1.12 Class A Findings:

Class A findings are the most severe level of finding. This type of finding may pertain to con-
ditions that are in direct violation of an FAR or another federal, state or local regulation, or to
conditions that contain high risk of injury to personnel or damage to equipment. Such findings
must be corrected immediately.

1.1.13 Class B Findings:

Class B findings may pertain to conditions that are contrary to IOSA standards or Company
Policies and/or Procedures, or to conditions that contain a moderate risk of injury to personnel
or damage to equipment. Such findings should be addressed and monitored for timely resolu-
tion.

1.1.14 Concerns:
Concerns pertain to conditions that do not meet Department of Defense Commercial Air Car-
rier Quality and Safety Requirements, or to conditions that if left uncorrected, could lead to
increased risk of injury to personnel or damage to equipment. Concerns should be addressed
and monitored for timely resolution.

1.1.15 Repeat Findings:

Repeat findings are items which were found during a previous audit and were found on the
subsequent audit. The prior checklist and written report are reviewed before the audit is con-
ducted and concerns are noted to ensure these items have been remedied. Items found not
to be corrected, will elevate the finding to the next level of concern or higher depending on the
nature of the finding and will be noted on the report with, “This is a repeat finding,” or “This is
considered to be a repeat finding due to a similar problem being noted on the previous audit.”

1.1.16 Follow up Inspections:

A Follow up Inspection is an inspection performed to determine that a corrective action sub-
mitted by a Department in fact provides a remedy to a Finding. The Safety and Compliance
Department will perform this inspection within 30 days of receipt. Follow up Inspections deter-
mine continued compliance and are scheduled at an interval determined by the Vice Presi-
dent, Safety and Compliance. Discrepancies found during Follow up Inspections shall be
addressed as if they were Class A Findings. A Follow up Inspection may also renew additional
Class A or Class B Findings.

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1.1 Terminology

1.1.17 Safety Coordinator/Specialist Qualifications:

- Safety Coordinator/Specialist(s) must be analytical, highly organized, and detail oriented.
- They must have strong verbal and written communication skills, and be able to
communicate effectively with senior management, other internal staff, and external
professional contacts. They must be able to defend audit positions with senior management
and external professional contacts. They must be able to influence others without direct
authority.
- They must have proficiency with Word, Access, Excel, Microsoft Windows and Microsoft
Office programs applications.
- They must be available for extensive overnight travel (approximately 60% to 70%),
traveling alone and working under minimal supervision as audits necessitate.
- Strong administrative skills are necessary to manage audit activities. They should possess
the ability to work with and sometimes lead audit teams.
- They must be readily adaptable to change, and possess a strong ability to grasp new
materials and concepts.
- They must have good math and reading skills, and understand Material Safety Data
Sheets.
- They must be diplomatic when pointing out deficiencies or deviations from regulations or
company policies and procedures to other personnel. They must be able to deal with
adversity and confrontations. They must conduct themselves with an attitude and manner
that promote quality service from other associates.
- They must have strong research and problem solving skills, and effective interpersonal
skills within all levels of the organization.
- They must have a strong working knowledge of applicable federal and state regulations and
company policies and procedures. The ability to stay aware of changes in legal standards
and legal applications is key.
- A Bachelor’s degree in a related field is desired.
- Previous airline related experience is a plus.

1.1.18 Safety Coordinator/Specialist Training

- The Manager, Safety & Regulatory Compliance will conduct initial training for all
Coordinator/Specialist(s) on company/department policies and procedures, which will
include a detailed review of all codeshare differences.
- Additionally, all Coordinator/Specialist(s) will attend the FAA System Safety Course and
any specialized training necessary for OSHA, Blood bourne Pathogen and Maintenance
Safety.
- During the first quarter of each calendar year, annual recurrent training for Coordinator/
Specialist(s) will include a review of all changes to policies, procedures and systems. This
will include, but not limited to, Federal Aviation Regulations, Chautauqua Airlines policy,
Department of Defense Commercial Air Carrier Quality and Safety Requirements, OSHA
and codeshare specific policies.
- However, at any time throughout the year, any significant changes to process or regulations
would prompt an immediate review of materials.

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Chapter 2 Internal Evaluation Program Elements
2.1 Introduction

Chapter 2
Internal Evaluation Program Elements

2.1 Introduction
Chautauqua Airlines’ Internal Evaluation Program (IEP) focuses on the continuing surveillance of
the Maintenance, Operations, and Flight departments. The objectives of this program are as fol-
lows:
• to assess the adequacy of managerial controls in key programs and systems
• to detect the root causes of deficiencies
• to detect needed improvements to company procedures before deficiencies occur
• to develop corrective action plans for identified deficiencies
• to perform followup evaluations when necessary
• Chautauqua Airlines’ IEP is designed to identify potential problem areas before accidents,
incidents, and findings occur, and to ensure upper management is involved with safety and
compliance issues. The IEP will be maintained and managed by the Director of Safety.
The Internal Evaluation Program does not relieve each department of its own responsibility to con-
duct ongoing evaluations of their own procedures to ensure compliance with Chautauqua Airlines
policy, Federal Aviation Regulations and other external requirements.

2.2 Program Overview

The following audit checklists have been developed to examine departments, policies, procedures
and equipment:
• Flight Operations
• System Control
• Drug and Alcohol Testing
• Crew Scheduling
• Inflight Services
• Pilot Training
• Safety and Regulatory Compliance
• Maintenance
• Materials
• Quality Control and Engineering
• Publications
• Stations
• Hazmat
• Occupational Safety and Health
• Production Control
Audits will be accomplished at intervals outlined in this chapter, and the results returned to the
Director of Safety. The Director of Safety will review each audit report to determine if a follow-up
audit is necessary. Audit reports are provided to appropriate department heads so they may
address deficiencies and make corrections where necessary.

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Chapter 2 Internal Evaluation Program Elements
2.3 Audit Schedules

2.3 Audit Schedules

2.3.1 Department Audit Schedule
Department audits will be completed according to the schedule posted on the Company Intra-
net site under the “Safety” Department. Based on audit results, this schedule may be adjusted
so that more or less time can be distributed to other areas of concern. This Department Audit
Schedule will also include the Hazmat/EPA/OSHA schedule for each maintenance facility.

2.3.2 Station Audit Schedule

Refer to the “Safety” page of the Company Intranet for the current station audit schedule. The
station audit schedule depicts when an audit is to occur within an 12 month period, as well as
the maintenance facilities and materials audits, and cargo audits.

2.3.3 Safety Department Audit

The Safety Department itself shall be audited biannually by someone from outside of the
Safety Department. An external auditor (IOSA or DOD) may conduct this biannual audit, or a
Chautauqua associate from another department who meets the Coordinator/Specialist(s)
requirements outlined in Chapter 1 of this manual. Safety Department Audits conducted by
Chautauqua associates must incorporate the Safety Department Audit Checklist. Since the
Safety Department Audit Checklist is an element of Chautauqua’s Internal Evaluation Pro-
gram, auditors from outside the Company can refer to the checklist, but may not use the
checklist for conducting their own audits.

2.3.4 Drug and Alcohol Testing Program, Publications and System Controls Audits
The Safety and Compliance Department will conduct a Drug and Alcohol Testing Program
Audit annually, tentatively scheduled in the month of April; the Publications Audit annually, ten-
tatively scheduled for the month of August; and the System Control Audit annually, tentatively
scheduled for the month of October.

2.4 Auditing Procedures

2.4.1 General
1. After scheduling an audit on the Safety Calendar in Microsoft Outlook, the Safety Coor-
dinator/Specialist(s) will coordinate flight arrangements with the Travel Department. All
travel information, including flight times, will be posted in the Safety Calendar.
2. They will contact the responsible party (i.e., Director, Manager or Supervisor) to inform
them of the upcoming audit. Due to uncontrollable circumstances, i.e., weather, flight,
available personnel, it may become necessary to reschedule an audit to a following
week or month. All parties scheduled to participate in the audit will be notified of this
change as soon as possible.
3. The Safety Coordinator/Specialist(s) will review the past audit findings or concerns
before the visit.
4. When practical, they should schedule a meeting to introduce him or herself to the
responsible party at the audit site prior to commencing the audit. During this meeting,
they should explain the purpose of the audit and answer any questions about how the
audit will be conducted. Any new safety concerns should be discussed, and deficiencies
and corrective action noted in previous audits should be reviewed.

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 Internal Evaluation Program Manual
Chapter 2 Internal Evaluation Program Elements
2.4 Auditing Procedures

5. Audits will be conducted in a professional manner with special effort to be non-intrusive

to daily operations.
6. Only audit checklists contained in the Internal Evaluation Program Manual will be used.
7. Audits should focus on identifying the root causes of problems.
8. The level of concern is determined by the specific findings during the audit. These are
broken down into three categories, Class A findings, Class B findings and concerns, as
outlined in Chapter 1 of this manual.
9. The Safety Coordinator/Specialist may document general concerns that are not
addressed by any particular audit checklist question.
10.They may also document general observations, not addressed by any particular audit
checklist question.
11.They may make recommendations to resolve discrepancies. Recommendations should
focus on corrective fixes that address root causes, to avoid recurrences of safety
concerns and to eliminate systemic problems.
12.They will mark the audit checklist with an "X" in the appropriate blocks. Audit questions
that are not applicable will be marked "N/A." Circumstances may prevent an audit from
being completed in its entirety. Checklist items that are not observed during the audit
will be marked "N/O" and an explanation will be noted under "General Comments."
13.At the completion of the audit, a verbal debriefing will be held where they will:
- Discuss findings, concerns, and recommendations, with emphasis on root causes
- Discuss similar findings from the previous audit
- Present documentation to substantiate all findings
- List all items that were corrected during the audit
- Brief management on all pertinent topics
- Schedule any required follow-up audits
14.A written audit report and completed audit checklist will be presented to the responsible
party at the time of the verbal debriefing, or e-mailed to the responsible party shortly
thereafter. In no case should the length of time between the verbal debrief and receipt
of the written report exceed seven business days.
15.Each audit report should include the dates and location of the audit, the name of the
Coordinator/Specialist, the name of the person who was debriefed, definitions and
response time frames for findings and concerns, the actual findings and concerns,
recommendations, and the completed audit checklist.
16.Follow-up audits, when required, should be used to verify elimination of deep-rooted
problems and ensure corrective action plans are effective.
17.The Safety Coordinator/Specialist(s) will track open audits under Microsoft Outlook
"Tasks." If the responsible party does not respond to the audit by the due date, they will
mail a reminder. Class A findings require a written response within five business days.
Class B findings require a written response within ten business days. Concerns require
a written response within fifteen business days.
18.When a response is received, they will review the response to ensure all findings or
concerns have been addressed, and any long term fix is included.
19.All completed audits, including audit forms, reports and the written responses to findings
and/or concerns, along with follow-up reports, will be maintained by the Safety Depart-
ment for a minimum of two years. All such documents will be stored electronically on the
Safety Department's hard drive.

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2.5 Responding to Findings/Concerns

2.5 Responding to Findings/Concerns

Class A findings require a written response within five business days. Class B findings require a
written response within ten business days. Concerns require a written response within fifteen busi-
ness days. The most severe of all the findings will determine the due date when the entire response
will be expected.
The manager to whom the audit report is sent is responsible for determining the root cause of each
discrepancy. All responses must list the “Root Cause” (don’t restate the finding- tell why it hap-
pened), include a corrective action that details “Immediate Action:” and follow with a “Corrective
Action:” which would address the long term fix for each item.
Responses that only address surface or superficial fixes will be rejected. When deficiencies cannot
be resolved quickly, corrective action plans and timelines should be developed. When required, the
Safety and Compliance Department will conduct follow-up audits to verify elimination of deep-
rooted problems and to ensure that corrective action plans are effective.
All responses will be reviewed, logged and filed by the Safety and Compliance Department.
Responses not in compliance with the guidelines above will be reported to the Vice President,
Safety and Compliance, who will attempt to resolve the issue at the Vice President level. If unsuc-
cessful, the Vice President, Safety and Compliance will forward all documents and his/her recom-
mendations to the President and CEO.

2.5.1 Resolving Discrepancies

The Director of Safety will track the following audits: Flight Operations, System Control, Crew
Scheduling, Inflight Services, Pilot Training, Occupational Safety and Health, and Hazardous
Materials, Production Control, Maintenance, Materials, Quality Control, Station, and Publica-
tions.
Microsoft Outlook is used to track and alert the Director of Safety of audit response due dates
and the follow up actions that are required
Reports submitted by the Safety and Compliance Department may include recommendations
to help facilitate the closure of findings or concerns.
NOTE: These recommendations are only suggestions and should not be construed as the required fix or
solution.
Department heads that receive a report commenting on a finding or concern are encouraged
to speak with the Director of Safety. Communication and cooperation between all departments
will help ensure that Chautauqua Airlines offers the safest and most efficient product possible.
One of the main goals of the IEP program is to prevent concerns from escalating into Class B
or Class A findings.
The status of open audit findings and concerns will be reviewed by the Safety and Compliance
Department at the weekly Safety Staff Meeting.

2.5.2 Internal Evaluation Program Modifications:

1. The Director of Safety will review Internal Evaluation Program audit checklists at least
semiannually to ensure they reflect current FARs, other rules and regulations, and
industry best practices.
2. Modifications to Internal Evaluation Program audit checklists, the frequency of audits,
and other aspects of the Internal Evaluation Program must be approved by the Director
of Safety.

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Chapter 2 Internal Evaluation Program Elements
2.6 Records

2.6 Records
All completed audits, including audit forms, reports and the written responses to finding(s) and/or
concerns, along with follow-up reports, will be maintained by the Safety Department for a minimum
of two years. All such documents dated after October 2001 will be stored electronically on the
Safety Department's hard drive, "corporate\corpdocs\Safety" under "Completed Audits."

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 Internal Evaluation Program Manual
Chapter 3 Areas Covered During Evaluations
3.1 Introduction

Chapter 3
Areas Covered During Evaluations

3.1 Introduction
The Safety and Compliance Department will conduct comprehensive evaluations of the functional
areas within the airline on a continuing basis. The basic operating departments that will be audited
are the Maintenance, Flight Operations, Inflight Services and Customer Service departments.
These evaluations will focus on the effectiveness of controls and ongoing evaluations within each
department, communication within and between departments, and the effect that company policy
and developments have on departmental objectives, and shall include areas not reviewed during
other evaluations.
Functional areas within the airline, such as Maintenance, Flight Operations, Customer Service,
Inflight Services, Security and Ground Support will be audited on a continuing basis. Individual
managers within the departments are responsible for periodically conducting evaluations of their
functional areas.
To effectively identify potential problem areas and correct discrepancies before actual findings
occur, the Safety and Compliance Department will enforce a continual evaluation program. A con-
tinual evaluation program is needed to verify whether findings are isolated instances or actual
symptoms of policy, procedural or managerial problems. The continual evaluation program will be
conducted on annual review cycle. Special evaluations will be conducted when trends are identi-
fied.

3.2 Areas Evaluated

3.2.1 Maintenance
- Maintenance/Inspection responsibilities
- Parts Acceptance/Inventory Control
- Vendor Audit Methods and Procedures
- Deferred Maintenance Management.
- Fuel Quality Control Management
- Training Programs and Record Keeping

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3.2 Areas Evaluated

3.2.2 Operations
1. Training Programs and Record keeping
a) Pilot
b) Flight Attendant
c) Dispatcher
d) Customer Service
e) Maintenance
f) Security
2. Crew qualification
a) Pilot, Flight Attendant and Dispatcher qualification records
b) Crew and Dispatcher scheduling and assignments
c) Crew and Dispatcher duty records
3. Manuals, Policies and Procedures
a) General Operations Manual
b) General Policies Manual
c) Aircraft Minimum Equipment Lists
d) Pilot Operating Handbooks
e) Flight Attendant Manual
f) Read and Initial file system and control
g) Dispatcher and Crew scheduling manual
4. System Operational Control
a) Communication systems
b) Crew briefing, alert system
5. Station Operations
a) Station flight records retention
b) Radio logs
c) Customer Service
d) Security
a. Ground Support
1) Facility and Housekeeping.
2) Motorized Equipment Program.
3) Non-motorized Equipment Program.
4) Ramp Service Vehicle Lockout Program.
5) Ramp Housekeeping and vehicle condition.

3.2.3 Safety
1. Internal Evaluation Program
2. Safety Reporting System
3. Emergency Response Plan

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 Internal Evaluation Program Manual
Chapter 3 Areas Covered During Evaluations
3.3 Checklists

3.3 Checklists
Checklists developed to aid in performing audits and evaluations are located with the Internal Eval-
uation Manual, under the ‘Tech Pubs’ tab, ‘Electronic Manuals Library’, on the company Intranet.
These checklists may also be obtained from the Safety Department upon request. The checklists
posted on the Intranet include the following:
• 01_ Safety Internal Audit Checklist
• 02_Pilot Training
• 03_Crew Scheduling
• 04_Enroute Operations
• 05_System Control
• 06_Flight Operations Audit Checklist
• 07_Drug & Alcohol Testing Program
• 08_Inflight Services
• 20_Quality Control and Engineering Internal Audit Checklist
• 21_Materials Internal Audit Checklist
• 22_Maintenance Internal Audit Checklist
• 22_Maintenance Internal Audit (G & H)
• 23_Production Control
• 24_Station Internal Audit Checklist
• 25_Publications Internal Audit Checklist
• 26_Hazmat and Dangerous Goods
• 27_Occupational Safety and Health

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3.3 Checklists

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 Internal Evaluation Program Manual
Appendix A References

Appendix A
References
References and Guidance Material
Aviation Safety Programs: A Management Handbook, Chaps. 4, 11, 18, Wood, Richard H., Jeppe-
sen Sanderson, 1997.
Flight Safety Digest, Consensus on Need for FAA Guidance Helps Propel Era of Director of Safety,
Flight Safety Foundation, January, 2000.
Joint Flight Standards Handbook Bulletin for Air Transportation: HBAT 99-19: 14 CFR Part 121 and
135 Air Carrier Safety Departments, Programs, and the Director of Safety, FAA, 11/30/99.
The Practice of Aviation Safety: Pg. 8-11, Flight Safety Foundation. June 1990.
Incident Analysis Programs, in Air Line Pilot, APLA, Oct. 1999.
Operator's Flight Safety Handbook, Secs. 2, 3, Global Aviation Information Network (GAIN), Work-
ing Group A, June 2000, Issue 1.
The BASIS for Safety Management, Holton, Mike, FOCUS (British Airways Safety Services), Nov.
1991.

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