The 14 CFR Part 121 Internal Audit Checklist

14 CFR Part 121 has long served as the backbone of American air transportation law, setting stringent performance and safety standards across every aspect of airline operations. It’s been in force for over half a century! Part 121 governs every aspect of airline operation with strict standards set for performance and safety compliance.

Before beginning an on-site audit, the Audit Officer must make sure the Air Operator Certificate/Operations Specification is up-to-date and list all fleets (excluding dry lease out aircraft ) to be audited on Audit Details section of audit software.

1. Organizational Structure
14 CFR Part 121 serves as the cornerstone of US airline industry operations, outlining strict standards for performance and safety. But this not just an unchanging set of laws – rather, it represents a longstanding, ongoing operational philosophy.

Every audit should conclude with an on-site meeting conducted by the Lead Auditor, including all key staff, managers and the auditor himself/herself. Attendance must be recorded.

Determine whether any of your operator’s aircraft/fleet are wet-leased aircraft. A wet leased aircraft belongs to one operator (Lessee), while it operates under an AOC issued by another (Operator A). To record wet lease operations accurately and report them for reporting purposes. Please see 2.5.3 Wet Lease Operations for further discussion.

2. Safety Director
Part 121 represents the highest and most rigorous standard for commercial air travel safety standards in the US. These regulations impose stringent standards on pilots as well as providing detailed procedures for operational compliance; they are frequently updated to enhance aviation safety.

A valid AOC/Ops Specs is essential to successfully conducting an audit. They should verify that all fleets listed on their AOC fall within its scope for the audit; any out of scope aircraft should be excluded or exempted accordingly.

The Audit Officer also verifies that Mandatory Observation Checklists are pertinent to the scope of audit by checking workflow stage changes to ‘Audit in Progress’. This is essential in order to reduce errors that could compromise its integrity and validity.

3. Maintenance Director
An air carrier maintenance director oversees the aircraft maintenance program at a Part 121 airline, as well as developing, implementing and maintaining an Air Carrier Maintenance Safety Management System (AMSS).

The Airline Safety and Federal Aviation Administration Extension Act of 2010 mandates that holders of Part 121 certificates implement an AMSS. This AMSS should include an Aviation Safety Action Program, Flight Operational Quality Assurance program and Line Operations Safety Audit program.

AMSS regulation was intended to be flexible, accommodating different business models with their own individual systems in place. This makes it simpler for directors of safety departments to tailor the regulations to their airlines safely and responsibly.

4. Operations Director
Operations directors are in charge of overseeing the daily operations of an airline, ensuring its aircraft are operating safely, crews are properly trained and equipped, flight data analysis occurs without issues and that 14 CFR Part 121 requirements are fulfilled by meeting every aspect of operations management requirements.

Notes for Air Operator Certificate/Ops Specifics should include details regarding wet-leased aircraft that fall outside their AOC/Ops Specifics. Any wet leased aircraft should also be listed under ‘Fleet(s) and/or Aircraft Exempt From Assessment” with reasons such as lease duration, aircraft owner and country provided.

Before concluding the IOSA audit on site, an auditor should record both the date and results of its on-site portion. They must also note any CARs raised during that audit session.

5. Chief Pilot
As is evident with airlines, they must comply with many regulations to operate legally and obtain an air carrier certificate. Therefore, it’s essential that adequate oversight managers are in place in each department – Part 121 requirements stipulate an airline must employ safety directors, maintenance directors, operations directors and chief pilots in order to operate legally.

Establish whether the operator has any aircraft that are no longer part of its operation due to being wet-leased out (wet lease operations). If they remain listed on their AOC, these must be approved as wet-leasing operations by IATA; an audit officer shall record these aircraft as exempt in their audit software and add comments accordingly.