Understanding SAS & the Data Collection Tools and Developing a Part 145 Internal Audit

Get in touch with us

Blue Tuna’s Internal Audit  An internal audit involves much more than reviewing your manual against Part 145 CFRs.  It involves a much more detailed understanding of how New Part 145 documentation is now designed with Element Design Data Collection Tools (ED DCT) and how a repair station is evaluated over time with Element Performance Data Collection Tools (EP DCT).  For a basic understanding of the use of DCTs and how they fit into the scheme of Safety Assurance Systems (aka SAS) begin by going to FSIMS Volume 10 Safety Assurance System Policy and Procedures, Chapter 1 General, Section 1 Safety Assurance.

DCTs use for Internal Audits:

New Part 145 manuals, Repair Station Quality Control Manuals (aka RSQCM) and Repair Station Training Program manuals (aka RSTP) are initially evaluated with the use of the ED DCTs.  Your FSDO will use will use EP DCTs to evaluate the performance of the repair station and its’ use of their own manuals/procedures.

Your FSDO will use these tools and it makes sense for you to do the same in preparation for audits.

SAS & DCTs:We will break down info from FSIMS to provide you with a basic understanding to equip you to use the DCTs as a tool for auditing.


(Element Design DCTs)




(Performance Design DCTs)

ED 1.4.1 Personnel Records EP DCT 1.4.1
ED 1.4.2 Certificate Requirements (Org Charts Capability List) EP DCT 1.4.2
ED 1.4.3 Manuals EP DCT 1.4.3
ED 1.4.4 Quality Control System EP DCT 1.4.4
ED 4.1.4 Training and Qualifications EP DCT 4.1.4
ED 4.2.6 Technical Data EP DCT 4.2.6
ED 4.2.7* Air Carrier and Air Operator EP DCT 4.2.7
ED 4.3.7 Work Away From Station EP DCT 4.3.7
ED 4.4.6 Record Systems EP DCT 4.4.6
ED 4.5.4 Housing and Facilities EP DCT 4.5.4
ED 4.5.5* Contract Work Certificated EP DCT 4.5.5
ED 4.5.6* Contract Work Non-Certificated EP DCT 4.5.6
ED 4.7.3 Tools and Equipment EP DCT 4.7.3
ED 4.7.4 Parts and Materials EP DCT 4.7.4


Safety Attributes provide a foundation for the DCTs.  There are Six identified Safety Attributes.

Safety Attributes Description
Responsibility A clearly identifiable, qualified, and knowledgeable person who is accountable for the quality of a process.
Authority A clearly identifiable, qualified, and knowledgeable person who has the authority to set up and change a process.
Procedures Written or unwritten methods, regulatory or non-regulatory, which a certificate holder/applicant uses to accomplish a particular process. (Found in manuals and attached procedures, an example would be a procedure for calibrating tooling and equipment.)
Controls Checks and restraints designed into a process to ensure a desired result.  Step to assure procedures are working check list in process inspection double inspection.  (An example of a Capabilities Self Evaluation or perhaps a sign off on an in-process check point.)
Process Measures Used to validate a process and identify problems or potential problems in order to correct them. (An example an Internal Audit or perhaps a vendor audit or corrective action report)
Interfaces Interactions between processes that must be managed in order to ensure desired outcomes. (An example of interactions may be manuals or forms.)

The foundation of DCTs are derived from the six safety attributes identified above.

  1. ED DCTs are used to design your manuals and procedures
  2. Your manual(s) and repair station operations are evaluated using these DCTs.
  3. You should know where these quality attributes can be found in your Repair Station system.
  4. We will use EP DCTs to evaluate your manual(s), your procedures and your performance

For more information on Internal Audits contact Blue Tuna.

To download a complete copy of Blue Tuna’s Part 145 Internal Audit click here.