There is a document that almost every CIAC (Brazilian flight training center) has and almost none uses: the Quality Assurance Manual (MGQ). It was written once, approved, printed — and ever since it has lived in a folder that only gets opened when the audit date comes around.
The problem is not the manual. It is that quality assurance has been treated as a document, when it is a cycle that runs all year long. And the difference between the two readings shows up on inspection day, when the question is not "do you have the manual?" but "show me the last cycle".
The five elements, and what each one asks of you
IS 141-006A, which guides the application of section 141.29 of RBAC 141 (Brazil's flight training regulation), organizes the MGQ into five elements. Read each one as a question someone is going to ask:
I — Quality policy. "What has management committed to sustaining?" One page, signed by whoever is in charge. It is short on purpose: its value lies in existing and being known, not in being long.
II — Scope. "What exactly is being assured?" Which courses, which bases, which processes are part of the system. A vague scope is the start of every confusing audit — if nobody knows what was supposed to be audited, nobody knows what was left out.
III — Independent audit program. The element that raises the most questions, and for that reason deserves its own section (right below).
IV — Management review. "Did management look at the results and decide anything?" This is the meeting where findings and indicators become decisions — with a date, attendees, an agenda and what was decided. Without a record of it, the cycle doesn't close: you're left with the impression that quality happens at the technical level and never rises above it.
V — Records. "Where is the evidence?" It is not an appendix to the system: it is the system. An audit doesn't assess intent — it assesses traces.
"Independent" does not mean "outsourced"
The most common confusion about element III. Independence here is about the person auditing not being the person performing the work: the instructor doesn't audit their own instruction, the coordinator doesn't audit the process they coordinate themselves.
This can be solved in-house — a person from another area, a designated professional, someone from another base — as long as the separation is real and demonstrable. Hiring from outside is one way of ensuring independence, not a requirement that it come from outside.
What the audit will want to see: a program (not an event), with a defined periodic cycle, a scope declared for each audit, an identified lead and a conclusion recorded at the end.
What fails you is not the finding — it's the finding left untreated
Here is the inversion that changes the whole CIAC's posture.
An audit that finds nothing reassures no one: it suggests it didn't look hard. A finding is a sign of a system working. What compromises you is the finding that sits still.
That is why it's worth separating the three types honestly, because each calls for a different response:
| Type | What it is | What it requires |
|---|---|---|
| Nonconformity | Failure to meet a requirement | Corrective action with an owner and a deadline |
| Observation | Still compliant, but at risk of no longer being so | Follow-up and a decision |
| Improvement opportunity | Compliant, but could be better | Evaluation — not an obligation |
Calling everything a "nonconformity" bloats the system and kills its credibility. Calling a nonconformity an "observation" to soften it is worse: it makes the deadline and the owner disappear, which are exactly the two things the inspection looks for.
A well-handled finding has four things attached to it: description, corrective action, owner and deadline — plus evidence that it was done. If one is missing, the cycle has a hole.
Indicators: what isn't measured becomes opinion
The MGQ asks management to analyze results — and results need numbers. There is no universal mandatory list, and that is exactly where most people get stuck, waiting for the regulation to say which indicator to use.
A better question is: what, if it got worse, would you want to find out about before the student complains? Pass rate, average training time, recurring findings, average time to resolve findings, mission cancellations. A few true indicators are worth more than a big table nobody fills in.
What the regulation requires is not the perfect indicator: it is that there be a target, a current value and a period — and that someone has looked at it.
How Alis solves this
The CIAC module has the entire QMS structured — not as a text attachment, but with each element in its place:
- Policy, scope and the Quality Manager live in the system configuration, with an audit cycle defined in months — Element III is born on the calendar, not in someone's memory;
- Audits with scope, lead, planned and actual dates, status and a recorded conclusion;
- Findings classified as nonconformity, observation or opportunity, each with corrective action, owner, deadline, status and evidence;
- Indicators with target, unit, current value and period;
- Management review with date, attendees, agenda and decisions;
- Records gathered and exportable — what the audit asks for, in the order it asks for it.
It is the same design as the SMS (SGSO), applied to the world of instruction: the system exists to produce evidence day to day, not to be filled in the night before.
And because it lives alongside the rest of the school's operation — FIPs, missions and training flights —, the data feeding the indicator is the same data already entered in the routine. Nobody types anything twice.
The two-minute test
If you want to know where your CIAC stands before someone asks, answer five things:
- Who is the Quality Manager, and do they know they are?
- What was the date of the last independent audit — and is the next one scheduled?
- How many findings are open, and has any gone past its deadline?
- When was the last management review, and what did it decide?
- Are the records for the last twelve months gathered, or scattered?
Five quick answers mean a living system. Five silences mean the manual is doing what an idle manual does: nothing.
If the second description sounds more like your reality, the conversation is quick — and it starts with exactly these five points.
This article is informational and does not replace reading the applicable regulations. Quality assurance requirements for CIACs follow RBAC 141 and the guidance of IS 141-006A — confirm the current version and its applicability to your certification in ANAC's publications.