Maintenance
DA SMS Operations & Individual Responsibilities

Gold Aviation Services is a FAA Part 135 on-demand air charter operator based at KFLL, operating under South Florida FSDO-19. Our SMS is implemented under 14 CFR Part 5 — the FAA's mandatory SMS regulation for Part 135 certificate holders.

The SMS is structured around four key roles:

• Accountable Executive (AE) — ultimate accountability for the SMS. Has authority over resources required to implement and maintain the system. Signs the safety policy.
• Director of Safety (DOS) — day-to-day management of the SMS. Administers the reporting system, manages the corrective action process, conducts audits, and maintains SMS records.
• Director of Maintenance (DOM) — ultimate regulatory authority for maintenance. Participates in the SAG and ensures maintenance-related hazards are addressed.
• Department Representatives — designated individuals from Flight Ops, Maintenance, and Management who participate in the Safety Action Group.

Safety Action Group (SAG): Meets regularly to review safety reports, assess risk, recommend corrective actions, and monitor open corrective actions. The SAG is the operational heart of our Safety Assurance process.

Safety Board: Chaired by the Accountable Executive. Meets quarterly to review safety performance data, SPI trends, audit results, and SAG recommendations. Provides organizational direction on safety priorities and resource allocation.

The Gold Aviation voluntary safety reporting system is the primary mechanism for hazard identification. You can submit a report for any safety concern — near-miss, hazard observation, operational error, equipment issue, or unsafe condition — at any time.

How to submit: Reports are submitted through the Gold Safety SMS platform. The Director of Safety is your point of contact for all safety reports.

What to report:

• Any near-miss or unplanned event that could have resulted in injury, damage, or loss
• Any hazard you observe — in operations, maintenance, facilities, or process
• Errors you made or observed that could recur
• Organizational conditions (pressure, fatigue, communication failures) that are creating safety risk
• Anything that didn't feel right — even if nothing went wrong

What happens after you report:

1. The Director of Safety acknowledges your report
2. The report is classified by hazard type and risk level
3. If corrective action is required, a corrective action is opened and assigned in Gold Safety
4. The SAG reviews the report and monitors the corrective action to closure
5. You may be contacted for additional information — this is part of the process, not an investigation of you

Management of Change (MoC) is a systematic, documented approach to managing organizational or operational changes that may affect safety. It is a DOS-led process defined in Gold Aviation SMS Manual §5.8. For maintenance personnel, MoC is not an abstract concept — you are often closest to the changes that trigger it.

MoC triggers relevant to maintenance (SMS Manual §5.8):

• Introduction of new aircraft, aircraft types, or equipment
• Significant changes to the aircraft maintenance program or approved procedures
• Changes to maintenance providers, contract facilities, or key maintenance personnel
• Changes to tooling, test equipment, or maintenance methods
• New or revised Airworthiness Directives that materially alter maintenance scope

When a change you are involved in meets one of these triggers, your role is to flag it to the DOM and DOS so that a formal MoC review can be initiated. MoC is not paperwork for its own sake — it is the process that ensures risk is assessed before a change is implemented rather than after something goes wrong.

Your role in CASS (GMM §10): As a maintenance technician, you contribute to CASS through your day-to-day work. Accurate maintenance records, timely MEL entries, correct write-up of discrepancies, and prompt SDR filing are all CASS data inputs. When the DOM or DOS contacts you about a finding during a CASS review or IEP audit, respond completely and promptly. The CASS Committee reviews open findings at every meeting until they are closed.

Maintenance errors are a significant contributor to aviation accidents. The just culture framework exists specifically to encourage technicians to surface errors and safety concerns — because an unreported error that goes undetected is far more dangerous than a reported one that gets corrected.

In maintenance operations, just culture means:

• If you discover an error you made — report it immediately. Self-disclosure is protected. Concealment is not.
• If you observe a colleague taking a shortcut under schedule pressure — report it. Normalization of deviance in maintenance is a known accident precursor.
• If you are being pressured to release an aircraft you believe is not airworthy — that is a serious safety report. Document it and contact the DOM and DOS immediately.
• If a procedure or tool is creating conditions for error — report the systemic issue, not just the outcome.

As a maintenance technician at Gold Aviation Services, your SMS responsibilities under 14 CFR Part 5, Part 43, and the Gold Aviation SMS Manual include:

• Airworthiness first: Never release an aircraft you believe is not airworthy. If you have a concern, raise it with the DOM before signing off. The DOM is the ultimate regulatory authority for maintenance at Gold Aviation Services.
• NOTMX initiation: Initiate a Notice to Maintenance (NOTMX) for any finding, defect, or airworthiness concern that requires documentation and follow-up. Do not defer items without proper documentation. NOTMXs are tracked in Gold Safety and reviewed at SAG meetings.
• Deviation reporting: Any deviation from approved maintenance procedures, manufacturer limits, or airworthiness directives must be documented and reported to the DOM and DOS same-day. Deviations that meet SDR criteria must be filed with the FAA. Your prompt, accurate reporting is what allows the organization to catch systemic issues before they become accidents.
• MoC flag duty: If you are involved in a change that may affect the maintenance program — new equipment, new procedures, new contract facility, revised AD scope — flag it to the DOM. The DOS will initiate a formal Management of Change review. You do not need to conduct the MoC analysis; you need to raise the flag.
• CASS data quality: The CASS program depends on accurate maintenance records. Write-ups, MEL entries, corrective action documentation, and SDR filings are all CASS inputs. Complete them accurately and on time. Inaccurate records degrade the DOM's ability to identify systemic trends.
• Hazard and incident reporting: Submit safety reports for near-misses, maintenance errors, equipment deficiencies, and observations of unsafe practices. Reports go into the SMS corrective action process. Those with a systemic maintenance-program dimension are also reviewed at the next CASS meeting.
• Human factors awareness: Recognize when you are fatigued, distracted, or under pressure. These are the conditions that produce maintenance errors. Speak up before a task if you are not confident you can complete it safely.
• Safety meetings and training: Complete all assigned SMS training modules, participate in safety reviews and CASS-related briefings when invited.

Understanding what happens after a report is submitted helps reinforce why reporting matters — and what to expect if you are involved in a follow-up.

When a safety report or audit finding identifies a hazard that requires action, a corrective action is opened in the Gold Safety platform. Corrective actions are the mechanism Gold Aviation Services uses to document, assign, track, and close the response to identified safety risks. This is distinct from the Continuing Analysis and Surveillance System (CASS), which is a maintenance quality program under AC 120-79A led by the Director of Maintenance.

The corrective action process:

1. Initiation: DOS opens a corrective action in Gold Safety, assigns a number, links it to the originating report or finding, and documents the hazard and risk level
2. Investigation — root cause is identified. Contributing factors are documented.
3. Corrective action — a specific action is assigned to a responsible party with a due date
4. Implementation — the assigned party completes the corrective action
5. Verification — DOS verifies the action was completed and effective
6. Closure: The corrective action is closed with documentation of the action taken and effectiveness verification. The SAG reviews and concurs.

You may be contacted by the DOS during the investigation phase for additional information. This is a normal part of the process — it is not an investigation of you personally, and it does not affect your just culture protections.