IEP Auditor Training
Internal Evaluation Program

The Internal Evaluation Program (IEP) provides the procedural guidance for auditing Gold Aviation Services' Safety Management System. While the SMS Manual establishes the regulatory requirements under 14 CFR Part 5, AC 120-92B, and ICAO 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 on a rolling 12-month cycle. These areas include SMS training and ERP training, safety performance indicators, risk controls (MOC and FRAT), the safety reporting system, contractor oversight, safety governance, evaluation of the four SMS components, operational departments, and compliance monitoring.

Audits run on a rolling 12-month cycle:

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

As an auditor, you should understand not only what you are auditing but also why that area appears on the schedule at that frequency.

Every IEP audit follows the same four-stage structure. This methodology ensures consistency, objectivity, and comprehensive coverage regardless of who is conducting the audit or which area is being reviewed.

Stage 1 – Planning: Risk-based focus areas are identified using safety data, hazard reports from the SAG, and prior audit findings. The annual audit schedule defines when each area will be reviewed.

Stage 2 – Execution: Standardized checklists and templates are used to ensure consistency. Objective evidence is gathered through interviews, record reviews, and direct observation. This is the core data-gathering phase of the audit.

Stage 3 – Reporting: Findings are documented in the SMS system. A risk assessment is completed for each finding, and corrective actions are issued where needed. Clear, factual reporting is essential so that findings can be understood and acted upon by others.

Stage 4 – Follow-Up: The responsible manager implements corrective actions. The Director of Safety verifies effectiveness before closure is documented in the SMS system. This stage closes the loop and confirms that the identified issue has been resolved.

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

Internal sources include IEP audit checklists, reviews of manuals for currency and accuracy, Safety Review Board oversight of findings and SPI trends, and CASS quarterly and biannual reviews of maintenance compliance.

External sources include FAA SAS Portal findings, third-party operator ratings, and FSDO surveillance activities. These are reviewed by the DOS and fed into the IEP CAPA process for tracking and closure.

When you identify a finding during an IEP audit, consider whether it also has implications for CASS. Flagging these connections helps avoid duplicate work and ensures proper triage.

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 are auditing a vendor, you must also demonstrate understanding of the applicable 14 CFR Part 135 and Part 145 requirements for that vendor's scope of work.

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