IEP Auditor Training
Internal Evaluation Program

The Internal Evaluation Program (IEP) provides the procedural guidance for auditing Gold Aviation's Safety Management System. The SMS Manual establishes the regulatory requirements under 14 CFR Part 5, AC 120-92B, and ICAO SMS standards — the IEP Manual specifies how audits are actually planned, executed, reported, and followed up.

The IEP exists to:

• Ensure compliance with regulatory and internal safety requirements
• Verify the effectiveness of implemented safety risk controls
• Identify and correct gaps in safety performance before incidents occur
• Support oversight of internal operations and contracted organizations
• Promote continual improvement of the SMS
• Provide senior management with data for accountability and informed decisions

Every IEP audit ultimately evaluates SMS implementation against ICAO's four foundational elements:

• Documentation — are policies, procedures, and records current?
• Monitoring — is safety performance data being collected on an ongoing basis?
• Measuring — are Safety Performance Indicators (SPIs) tracked effectively?
• Analysis — do audit results and data actually inform risk management decisions?

IEP oversight responsibilities:

• Accountable Executive (AE) — overall authority and approval of the IEP
• Director of Safety (DOS) — manages the IEP, administers the annual audit plan, oversees corrective action closure
• Audit Team Leads — assigned by the DOS; must complete Auditor Training before conducting audits independently
• Department Managers — ensure corrective actions in their area are implemented on schedule

The IEP covers ten distinct areas: employee training compliance, safety performance monitoring, risk controls (MOC/FRAT), the safety reporting system, safety governance, contractor oversight, SMS functional audits (Policy/SRM/Assurance/Promotion), evaluation of the SMS as a whole, operational departments, and compliance monitoring.

Audits run on a rolling 12-month cycle:

Each calendar year, the DOS develops an Annual Audit Plan with input from senior management, outlining which areas will be audited and when. The plan is presented to the Accountable Executive for approval before the start of each calendar year.

Every IEP audit follows the same four-stage structure, ensuring consistency, objectivity, and comprehensive coverage regardless of who's conducting it or what area is being reviewed.

1. Planning — defined by the annual audit schedule; risk-based focus areas are identified using safety data and hazard reports from the SAG and prior audit findings.
2. Execution — standardized checklists and templates are used for consistency. Objective evidence is gathered through interviews, record reviews, and direct observation.
3. Reporting — findings are documented in the SMS software; a risk assessment is completed across all applicable stages; corrective actions are issued where needed.
4. Follow-Up — the responsible manager implements corrective actions; the DOS verifies effectiveness; closure is documented in the SMS system.

Audit tools available to support this process include standardized audit checklists, vendor oversight checklists, root cause analysis tools, and SMS risk assessment templates.

Every audit finding gets a risk assessment — the same likelihood × severity logic used in Gold Aviation's Safety Risk Management (SRM) process for hazard reports. This is what connects IEP audit findings into the same SRM pipeline as voluntary safety reports.

The risk level assigned to a finding directly drives:

• CAPA priority — higher-risk findings get faster-tracked corrective action timelines
• Escalation — Serious/High findings are reported to the Safety Review Board regardless of normal reporting cycle
• Closure verification rigor — the DOS verifies effectiveness of corrective actions, with higher scrutiny for higher-risk findings

Gold Aviation's compliance monitoring draws from both internal and external sources — and IEP audits are one piece of a larger picture that includes the Continuous Analysis and Surveillance System (CASS).

Internal compliance monitoring sources:

• IEP audit checklists, covering both operational and safety topics
• Review of the GOM, GMM, SMS Manual, ERP, IEP, FRMP, and SOP Manual for currency and accuracy
• Safety Review Board review of audit findings, CAPA status, and SPI trends
• CASS quarterly and biannual reviews of maintenance compliance

External compliance monitoring sources:

• FAA SAS Portal — DCT findings and surveillance data from the Principal Inspector or FSDO, shared by the DO, reviewed by the DOS, and fed into the IEP CAPA process for tracking and closure
• Third-party operator ratings and gap analysis results, monitored by the DOS for compliance gaps
• FAA FSDO oversight activities, surveillance findings, and CHDO correspondence

When you identify a finding during an IEP audit, think about whether it also has implications for CASS — for example, a training records gap you find during an IEP audit might also be relevant to the next CASS review cycle. Flagging that connection helps the DOS triage and avoid duplicate work.

Auditor training requirements: all IEP auditors must complete this Auditor Training module before conducting audits independently. Refresher training is required every 24 months. If you're auditing a vendor, you also need to demonstrate understanding of the applicable 14 CFR Part 135 and Part 145 requirements for that vendor's scope of work. The DOS maintains training records for all IEP auditors.

Documentation and records:

• All audits, findings, and corrective actions are documented in the SMS system
• Records are retained for a minimum of five (5) years
• Summary reports are presented at Safety Review Board meetings
• Corrective action status is tracked through the CAPA process and reported to the Accountable Executive at each Safety Review Board

Continuous improvement:

• The DOS conducts an annual IEP Effectiveness Review
• The audit schedule and checklists are revised based on findings, safety data, and regulatory changes
• Lessons learned are shared with affected departments during SMS promotion activities
• The DOS presents IEP effectiveness findings to the Accountable Executive as part of the annual SMS review