AS9110 and Part 145 Internal Audit Program (combined)

Hello, first post but long-time reader of other posts, please be gentle

For many years now I've been developing internal audit Programs for MRO's in Australia and I've generally accepted that there is not 'clean' way to cover all Internal Audit requirements that come from AS9110 (i.e. think process approach and risk-based) and Part 145 (in our case CASA/DASA but not wildly dissimilar to EASA).

The regulatory side does not care about processes, it wants us to audit our exposition and procedures (including sampling product) in entirety each 12 months, as they've been approved by the regulator. The exposition is also not written in a process approach. AS9110C allows for the risk-based approach and you can spread audit frequency out over multiple years based on priority of risk.

This to me creates a conundrum, because AS9110 is designed to supplement/complement Part 145 yet the regulations contradict the AS9110 requirements for internal audit frequency. I'm aware that AS9110 states that the regulations take precedence, however; there is additional content in AS9110 to audit (i.e. objectives, management review, context of the organisation etc.).

My question to the brains trust:
Is there a 'best practice' approach to merging all audit requirements of Part 145 and AS9110 into a nicely packaged audit program, whereby you're not duplicating effort and you're able to use standardised audit checklists that cover all requirements? I'm very interested in learning from anyone who has achieved a good level of success in the MRO internal audit environment.

*Note: I'm aware of many resources online that promise to cover AS internal audit but they are all born out of the AS9100 and the manufacturing environment, which in my view is much more achievable for internal audit when compared to MRO.

Thank you

Hi Trav99
I'm in a similar position trying to align EASA/CASA exposition and ISO9001 audits and used AS9110 to try align the different requirements. We are not AS9110 accredited but the IAQG published resources include a comprehensive cross reference between Part 145 and AS9110 which is useful to establish a compliance matrix. I schedule an annual audit to pick the ISO9001 topics not covered by the Part 145 audits.
The EASA user guide for Foreign part 145 MOE (UG.CAO.00024-009) has a good cross reference between your MOE and the Part 145 regs. The EASA and CASA MOE headings have the same order but CASA added one extra heading halfway through the MOE so the numbers don't align exactly.
Hope that helps

• Correlation of 9110:2016 mapped against EASA Commission Regulation (EU) 1321-2014 Part 145

AEOS_QA said:

Hi Trav99
I'm in a similar position trying to align EASA/CASA exposition and ISO9001 audits and used AS9110 to try align the different requirements. We are not AS9110 accredited but the IAQG published resources include a comprehensive cross reference between Part 145 and AS9110 which is useful to establish a compliance matrix. I schedule an annual audit to pick the ISO9001 topics not covered by the Part 145 audits.
The EASA user guide for Foreign part 145 MOE (UG.CAO.00024-009) has a good cross reference between your MOE and the Part 145 regs. The EASA and CASA MOE headings have the same order but CASA added one extra heading halfway through the MOE so the numbers don't align exactly.
Hope that helps

Click to expand...

Thank you very much, some excellent resources within that EASA User Guide that I had not come across before!

I was aware of the IAQG resources, although they are often not the best for AS9110 vs AS9100. Only around 5% of AS91XX series certified organisations globally are AS9110 MRO's, which I suppose is a contributing factor to the lack of guidance material specific to AS9110.

Currently we use the AS9110 standard to drive our audit schedule design (we have not fully adopted the 'process approach' though), rather than Part 145, which I'm thinking of flipping for next year. I think this would then likely allow us to do a similar thing to what you describe whereby we then cover any AS9110 'delta' as another audit to compliment the Part 145 audits. At the end of the day the regulatory requirements should drive the focus for auditing, which then helps compliance with the 'risk-based approach' in the standard.

We do also have the added complexity of being a larger organisation with split auditor resources between 'Programs' and the 'System' level, which makes it hard to define boundaries and cross-over between audit responsibilities without duplication.

However, I'll certainly make use of that EASA cross reference approach, so thank you again.