Egyptian Civil Aviation Supervisory Authority Egyptian Advisory Circular Number 00-2

INTERNAL EVALUATION PROGRAM

EAC00.2.1 Purpose
This Egyptian Advisory Circular (EAC) provides information and guidance material
that must be used for the development of an Internal Evaluation Program (IEP). All
certificate holders operating under Egyptian Civil Aviation Regulations (ECARs) Part 101,
121, 137, 141, 142, 145 and 147 shall implement this program within their organization.
The procedures and practices outlined in this EAC are applicable to maintenance
departments, flight operations departments, training programs, and all other related aspects
of a certificate holder’s organization.

EAC00.2.3 Background
The internal evaluation program is a mandatory program. As a matter of policy, the
ECASA has always encouraged certificate holders to identify, correct, and disclose
instances of noncompliance. Therefore, the development and implementation of an IEP
will benefit both the certificate holder and the flying public.

EAC00.2.5 General
Definitions of key terms and a description of the basic elements of an IEP are
incorporated in this EAC and are consistent with recognized quality auditing principles.
When appropriate, these terms have been tailored to conform to aviation standards and
practices.
The standards described herein are intended to help certificate holders develop their own
internal evaluation program.
In prescribing standards, rules, and regulations, and in issuing certificates under the
Egyptian Civil Aviation Regulations, the ECASA considers the duty resting upon
certificate holders to perform their services with the highest possible level of safety. The
validity of the air operator certificate or other certificate depends upon the ability to
conduct a safe operation in accordance with prescribed rules, regulations, and standards.
Through surveillance and oversight, the ECASA verifies that certificate holders are
upholding their responsibilities. The IEP is intended to facilitate the ECASA Inspector’s
advisory and cooperative capacity by providing a procedure for identifying and resolving
safety related issues.

EAC00.2.7 Definitions
The following key terms and phrases are defined to ensure a standard interpretation and
understanding of an IEP.
Note: An Airworthiness Directive (AD) compliance system, applicable to certificate
holders that own, operate, or maintain aircraft/equipment, has been used as an example
to further clarify each definition.
(One) Evidence: Evidence, as it relates to this EAC is documented statement of
fact, prepared by a certificate holder, that may be quantitative or qualitative and is
based on verifiable observations, measurements, or tests. Evidence must generally
be in the form of written documentation or reports that support the analysis and
review.
This data is necessary to substantiate findings/concerns and enables management or
evaluators to determine the root cause(s) of reported findings. Objective evidence
generally is determined from a review of appropriate documents or manuals,
equipment examination, observed activities, and data obtained during interviews.
(b) Controls: The key procedures, responsibilities, and decision-making positions
within an organization, department, division, or functional area.
Example:
A certificate holder who owns, operates, or maintains aircraft/equipment is tasked
with the determination of AD applicability. This responsibility is considered a
control of the AD compliance system and its design is critical to the overall
effectiveness of the system.
As part of an internal evaluation, the controls of the evaluated area must be verified
and tested. In some instances, personnel performing the internal evaluation may
have to first determine the features of a control. For example, evaluators must first
understand how the certificate holder verifies AD applicability before proceeding
with an evaluation of AD completion and associated records. In particular, the
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evaluation would focus on the effectiveness of procedures that would minimize the
risk of simple human error or oversight.
(c) Finding: A conclusion that confirms noncompliance with a specific standard.
Example:
Following a review of status records applicable to powerplant AD completion,
company evaluators concluded that two applicable ADs lacked appropriate
information substantiating compliance. Evidence to support this conclusion
included copies of the actual ADs and referenced service bulletins.
Note: This finding demonstrates noncompliance with an ECAR.
An internal evaluation may also produce a conclusion that is considered a finding,
but is not an ECAR compliance issue.
Example:
A Certificate holder has a procedure that requires AD applicability determination be
reviewed and signed by quality assurance, engineering, and the Vice President of
Maintenance. An internal evaluation of the AD system discovers that for five
newly applicable ADs, there is neither a record of the review nor a signature by the
Vice President of Maintenance.
Note: This finding demonstrates noncompliance with a standard, i.e. an approved
company procedure, rather than a specific ECAR.
(d) Concern: A conclusion, supported by objective evidence, which is not a
finding. However, it is a condition that may become a finding.
Example:
Through the use of its IEP, a certificate holder found that it was not scheduling
aircraft for AD completion until the AD was within 10 aircraft cycles of expiration.
While this procedure had not resulted in any findings, a review of scheduling logs
indicated that several aircraft had been flown to within one cycle before performing
the required AD work. Additionally, maintenance planners often had to
"frantically" reshuffle aircraft schedules to ensure timely AD completion. The
evaluators believed these circumstances had the potential to become a finding in the
future. Their analysis was documented as a concern and forwarded to management.

EAC00.2.9 Inspection:
The act of observing a particular event or action to ensure that correct procedures,
established standards, and appropriate requirements are followed.
Note: The term inspection is defined in this EAC within the context of quality auditing
principles. It does not address or define ECASA inspections.
(a) Audit: A methodical, planned review used to determine how effectively business is
being conducted. It compares present procedures with established company policies
and procedures. The various elements that comprise an effective audit are:
(1) Personnel interviews;
(2) Review of appropriate documents;
(3) Operational observations;
(4) Selection of various samples;
(5) Activity inspections; and
(6) Documentation of results.
An audit builds on the principles of inspection. The results of an 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 systemic problem but do not attempt to
estimate its extent. The results (findings or concerns) of an audit must be
documented and presented to management for corrective action decisions.
(b) Evaluation: An independent review of company policies, procedures, and systems.
An evaluation must be a comprehensive and continual process that considers the:
(1) Results of audits;
(2) Overall effectiveness of the management organization in achieving stated
objectives; and
(3) Ability of management to respond to new technologies, market strategies, and
social or environmental conditions.
The evaluation process builds on the concepts of audit and inspection. An
evaluation is an anticipatory process and is designed to identify and correct
potential findings before they occur. Written conclusions and
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recommendations made as a result of an evaluation must be submitted to Senior

Management for appropriate action.
Senior Management: Senior Management, as it relates to this EAC, is the
most senior company individual that is responsible for the daily operation of
the company. This person may be title as Chairman, Chief Executive Officer,
President or equivalent, who has the authority to resolve issues and take
appropriate action. The ECASA believes that Senior Management must be
aware of the plans, results (findings and concerns), and follow-up actions
associated with an IEP. Senior Management may appoint a Senior Management
representative and he must be given the responsibility of ensuring that the IEP
is properly developed, implemented, and maintained. This management
representative must be above the level that directly supervises work
accomplishment/procedural development and must have direct contact with
Senior Management. This representative does not relieve Senior Management
of their responsibilities under this program.

EAC00.2.11 Internal evaluation program

The internal evaluation program is based on the premise that certificate holders are
primarily responsible for continuously monitoring and ensuring that their operations are
safe and in compliance with the ECARs. The ECASA encourages certificate holders to
establish and conduct internal evaluations that embrace the following processes:
(1)A Continual Process incorporating the techniques of inspections, audits, and
evaluations to assess the adequacy of managerial controls in key programs and
systems. When deficiencies are identified, corrective action plans and follow-
up evaluations are developed and implemented;
(2)A Review Process, extending beyond regulatory compliance, to determine the
causes of deficiencies and detect needed enhancements to company operating
practices before deficiencies occur; and
(3) An Independent Process that has straight-line reporting responsibility to senior
management within the organization structure.
The internal evaluation concept stresses self-audit responsibilities of individual
employees. This concept also stresses the evaluation responsibility of senior
management to ensure that company policies and procedures provide for
enhanced safety and compliance within the organization.

EAC00.2.13 Program description

Certificate holders interested in developing an internal evaluation program, are
encouraged to include the following essential elements in their program:
(a) Independent/defined responsibilities;
(b) Management reviews;
(c) A process that is continual with prescribed schedules;
(d) Corrective action plans; and
(e) Records.
Note: Certificate holders developing an IEP must prepare a plan defining the
program’s procedures and functional responsibilities. The format for a typical
program plan is provided in the Appendix of this EAC.

EAC00.2.15 Independent/defined responsibility

An IEP must identify the person and/or group within the organization who has the
responsibility and authority to:
(a) Perform evaluations, audits, and inspections;
(b) Identify, record, and provide evidence of findings or concerns;
(c) Initiate, recommend, or provide solutions to findings/concerns through designated
reporting channels;
(d) Verify the implementation of solutions within a specified time; and
(e) Communicate and coordinate activities with ECASA personnel on a regular basis.
A certificate holder must identify resources and personnel dedicated to the IEP and
describe their organizational independence within the company. Individuals conducting
Internal Evaluations must not be responsible for managing work in the areas being
evaluated or the tasks being reviewed.
Note: This concept may have to be modified for small operations.
The operational size of many certificate holders may justify the costs associated with
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having full-time, dedicated resources and personnel in a separate IEP department or

group.
For very small operations, an appropriate IEP might consist of developing
checklists and a schedule (monthly, quarterly, semiannual, or annual) for accomplishing
evaluations. Even in such cases, the review must include a written statement
acknowledging the completion of the checklist items and the signature of Senior
Management.
Note: Occasional independent oversight of checklist item development and
accomplishment must be considered. Certificate holders, using outside resources or
independent consultants in support of an IEP, must ensure that these resources are
coordinated through a chain of command that reflects independence and contact
with Senior Management.

EAC00.2.17 Senior management review

Senior Management must review internal evaluation results to verify that satisfactory
corrective actions have been implemented.
The review of internal evaluation information by Senior Management must be
documented in reports or other appropriate records generated by the IEP. The
certificate holder must decide the frequency, format, and structure for informing Senior
Management of internal evaluation plans, results, and follow-up actions. The
program must include a diagram that depicts the independence of personnel who
perform or supervise internal evaluation functions, including some form of straight
line reporting authority to Senior Management. This reporting structure be documented
and included as part of the program plan.

EAC00.2.19 Continual process

In order to effectively anticipate potential problem areas and initiate corrections before
actual findings occur, an IEP must be a continual program, not merely spot check
inspections of operating practices. Stand alone, spot check inspections, will do little
more than identify symptoms of potential problems.
A continual process monitors and verifies whether findings are isolated instances or
symptoms of policy, procedural, or managerial problems. Scheduled, follow-up,
and special evaluations must be performed whenever negative trends are identified.

EAC00.2.21 Internal evaluation schedule

The continual process is a structured activity and it is essential to include a schedule of
activities. This planned schedule will serve to verify that the internal evaluation process is:
(a) Complete and detailed;
(b) Directed;
(c) Credible; and
(d) Recognized by Senior Management.
The schedule of activities must include a periodic review cycle for specific areas
covered by the certificate holder’s IEP. However, the scheduling process must also be
dynamic and allow for special evaluations when trends are identified. In addition, follow-
up evaluations must be performed, as necessary, to verify that corrective action
commitments were met and that they were effective in eliminating any reported findings or
concerns. Planned, Special, and Follow-Up evaluations all comprise an effective internal
evaluation schedule.
(1) Planned evaluation: Establishes a schedule of events that will be performed
during a prescribed calendar period and divides the complete schedule into
phases. This evaluation is scheduled to provide ample flexibility for resources
to initiate special or follow-up evaluations.

(2) Special evaluation: Conducted whenever Senior Management identifies special

concerns or priorities. May also be initiated based on a review of industry
trends, ECASA concerns, or identified internal trends.
(3) Follow-Up Evaluation: Ensures corrective actions were completed and the
reported finding or concern has been eliminated. May also be accomplished in
response to ECASA surveillance findings.

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EAC00.2.23 Corrective Action Plans

An IEP must include procedures ensuring that corrective action plans are developed in
response to findings or concerns. Additional procedures must be developed to ensure that
these action plans were implemented and effectively completed in a timely fashion.
As an option, Internal Evaluation personnel may participate in the development of
corrective action plans. However, organizational responsibility and accountability for the
development of these plans must reside with the technical departments cited in the finding
or concern. A proper corrective action plan must include the following elements:
(a) Identification of the finding or concern;
(b) Analysis of objective evidence to determine the systemic or root cause(s) of the
finding or concern;
(c) Identification of corrective steps that will prevent a recurrence of the finding or
concern;
(d) Implementation schedule, including a time frame for completion of identified
corrective steps; and
(e) Individuals or departments responsible for implementing the corrective steps.

EAC00.2.24 Individuals Responsibilities

The individuals responsible for managing an IEP must facilitate the corrective action
process by performing the following:
(a)Ensuring corrective action plans are developed in response to findings or concerns
and verifying that they include the elements outlined above;
(b)Monitoring implementation/completion of corrective action plans and providing
senior management with an independent assessment; and
(c)Initiating scheduled and/or unannounced follow-up evaluations to ensure the
effectiveness of the corrective action plans.

EAC00.2.25 Records
The certificate holder must maintain records documenting IEP performance and results.
Records are considered the principle form of evidence. Documented evidence is essential
in analyzing and determining the root causes of findings or concerns in order to identify
potential areas of noncompliance. It is important to maintain accurate, complete, and
reliable records that document the activities and results of an internal evaluation. IEP files
must include the following data:
(a) Scheduled evaluation reports;
(b) Special evaluation reports, including the trends or other reasons associated with
scheduling a special evaluation;
(c) Follow-up evaluation reports;
(d) Responses to findings or concerns; and
(e) Corrective action plans.

EAC00.2.27 Program plan outline

IEP procedures and responsibilities must be documented in a formal program plan.
Following are suggestions for the plan’s preparation and structure.
(a)Preparing a program plan
(1) The program plan must describe the duties, responsibilities, procedures, and
organization of the IEP.
(2) Copies of the plan must be distributed to appropriate company personnel to
enhance their awareness and familiarity with IEP procedures. In addition,
revisions must be made, as necessary, to ensure that the program plan continues
to reflect the certificate holder’s current internal evaluation procedures and
organization.

(b)Structuring a program plan

A sample outline of a typical program plan using the elements in this EAC is
provided in the Appendix. It must be viewed as a checklist of items
that warrant consideration during development of an IEP. The number of items
addressed and the manner in which they are documented will ultimately depend on
the complexity of each operation.

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EAC00.2.29 Program acceptance

The certificate holder shall submit their program to the ECASA for review and
acceptance. A prepared program will provide the ECASA with an opportunity to review
the proposed duties, responsibilities, procedures, and organization of the certificate holder’s
IEP. Additionally, the ECASA will provide support to any certificate holder requesting
assistance with program development and implementation.

EAC00.2.31 Conclusion
Development of internal evaluation programs must ensure that company policies and
procedures are responsive to growth/change and that certificate holders continually comply
with appropriate safety requirements.

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APPENDIX
TYPICAL PROGRAM PLAN OUTLINE

EAC00.2.app1.41 Objective and policy

The objective must be a statement that clearly defines the purpose and structure of the
certificate holder’s Internal Evaluation Program (IEP). Policy statements, following the
objective, must indicate that the internal evaluation process is independent, actively
involves Senior Management, and is a continual process designed to identify potential
problem areas.

EAC00.2.app1.43 Definition of terms

Terms that will be used consistently in the IEP must be defined. For example, a
certificate holder must define how results are categorized, i.e., a finding or concern. These
categories and other applicable terms must be defined and documented for clear
understanding and interpretation by company personnel. Definitions must be similar to
those specified in this EAC.

EAC00.2.app1.45 Duties and responsibilities

The certificate holder must specify which individuals are responsible for performing the
following tasks:
(One) Internal evaluation supervision;
(Two) Performance of evaluations, audits, and inspections;
(Three) Identification and documentation of findings or concerns;
(Four) Collection of objective evidence necessary to substantiate findings or
concerns;
(Five) Initiating and/or providing solutions to findings or concerns through
designated reporting channels;
(Six) Monitoring the development and implementation of corrective action plans;
(Seven) Maintaining and updating Internal Evaluation files;
(Eight) Verification of solution implementation; and
(Nine) Communication and coordination of IEP activities with ECASA personnel
on a regular basis.
Personnel performing the above tasks must not be responsible for work
accomplishment or management in the areas being evaluated. The supervisor of the
Internal Evaluation function must either be Senior Management or their
representative with straight-line reporting authority to Senior Management. When
full-time dedicated resources and personnel are not practical, procedures must
indicate that persons having direct responsibility for the areas to be evaluated are
not to be involved in the selection or supervision of the Internal Evaluation team.
In addition, identified personnel must be exempt from their other duties and
completely dedicated to the IEP while they participate as an evaluator.

EAC00.2.app1.47 Organization chart

An organization chart must be prepared that clearly illustrates the position of the IEP
within the certificate holder’s management structure. The chart must reflect the program’s
independence within the corporate structure and straight-line reporting to Senior
Management.

EAC00.2.app1.49 Reporting procedures

Reporting procedures must include requirements for Senior Management’s review of
internal evaluation information. They must be routinely apprised of schedules, plans,
results, and follow-up corrective actions. Additionally, this section of the plan must
specify the frequency, format, and structure for reporting information to Senior
Management and schedules to the ECASA.

EAC00.2.app1.51 Scope
A certificate holder must specify all areas within the scope of the IEP review. The
ECASA believes that the most effective IEP will encompass a complete review of the
certificate holder’s entire operation. However, a certificate holder has the option of
limiting an internal evaluation to selected systems or functional areas.

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EAC00.2.app1.53 Schedule process

The scheduling process must be comprised of the following elements:
(a) Scheduling evaluations over a predetermined calendar period;
(b) Performing special evaluations when trends are identified or priorities are set by
Senior Management; and
(c) Completion of follow-up evaluations that verify the effectiveness of corrective
actions.
Procedures and specific individuals responsible for planning, developing, and
coordinating the internal evaluation schedule must also be defined.

EAC00.2.app1.55 Records
The IEP must have a defined record-keeping process. Procedures must specify how
records are filed and maintained. Standard forms or formats for filing reports also must be
specified. IEP records must be comprised of the following:
(a) Scheduled evaluation reports;
(b) Special evaluation reports;
(c) Follow-up evaluation reports;
(d) Responses to findings or concerns;
(e) Corrective action plans; and
(f) Reports concerning completed corrective actions.

EAC00.2.app1.57 Training
The certificate holder must provide evaluators with training in recognized quality
auditing and evaluation principles/techniques. This training could be one or a combination
of the following:
(a) In-house courses;
(b) College courses;
(c) Home study materials; or
(d) Industry sponsored seminars and workshops.

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