This Blog – offered by Steven Bentley MD of Sofema Aviation Services (www.sassofia.com) looks at some of the issues associated with the maintenance of Competence within the Subpart G & J organisation.
21.A.143 states – (a) with regard to general approval requirements, facilities, working conditions, equipment and tools, processes and associated materials, number and competence of staff, and general organisation are adequate to discharge obligations under point 21.A.165;
GM 21.A.165(a) Obligations of the holder – Compliance with the production organisation exposition (POE) is a prerequisite for obtaining and retaining a production organisation approval. The organisation should ensure that personnel have access to and are familiar with that part of the content of the POE or the referenced documents, which covers their activities.
Monitoring of compliance with the POE is normally the responsibility of the quality assurance function.
GM 21.A.145(a) Approval Requirements – Sufficient personnel means that the organisation has for each function according to the nature of the work and the production rate, a sufficient quantity of qualified personnel to accomplish all specified manufacturing tasks and to attest the conformity. Their number should be such that airworthiness consideration may be applied in all areas without undue pressure.
An evaluation of the competence of personnel is performed as part of the quality system. This should include, where appropriate, verification that specific qualification standards have been implemented, for example NDT, welding, etc. Training should be organised to establish and maintain the personal competence levels determined by the organisation to be necessary.
How to manage Competence in an organisation? Consider the following Step by Step plan !
Have the Training Needs of every position been Identified and Agreed ?
Perform an analysis to ensure that each position has been assessed for the appropriate training, In respect of basic, current and ongoing training needs.
Who will do this in your organisation.? The Goal is to ensure a common standard throughout the organisation.
The Training needs analysis and management process shall be subject to audit so needs to be a controlled and repeatable process so should be documented in a way which supports effective oversight.
Depending on the size of the organisation this may be performed centrally or by Department Heads and Managers. In the case where It is done locally by the departments it should be done to a common organisational standard – Where and How Documented ?
How is a person assessed against the necessary skills, knowledge and experience requirements?
How is the ability of the person assessed and / or evaluated to perform the job?
Are there nominated assessors?
Have the assessors been trained?
Does the assessor have any guidance / procedures to follow?
How is the assessment recorded ?
How does the Quality department monitor the Competence Assessment System?
Quality Auditing essentially looks at the following areas
1/ Conformity with the Regulatory requirements.
2/ Audit of the Concerned Process (System Audit)
3/ Audit of Product in the case – Management of Competency
4/ On Going Surveillance of the Concerned Process
Has the Organisation documented in an effective way a process that satisfies all the Regulatory Requirements. ?
Is this process documented in a clear way with the information available to all concerned persons – POE procedure – Other Controlled Organisation Manual. ?
Who is responsible for the Procedure & Process ?
How is it kept up to date and managed ?
Follow the process through, from identification of selected personnel
To the completion of the Competence Assessment form.
Are all elements being performed correctly in accordance with the following Check list
Competency Audit Check list contents
1/ Identification and management of personnel to be assessed
2/Assessment Procedures
3/ Evaluation system
4/ Training Process Driven from Competency Assessment
5/ Management of Qualifications
6/ On going Supervision of the Competence Assessment Process
7/ Selection and Approval of Assessors
8/ Effective Implementation
9/ Examination
10 / Overall Management of the Competency System
11/ Review of Assessment Records for completeness and conformity
12/ Review of all Documentation used to manage Competence
Sofema Aviation Services offers a range of EASA regulatory compliant training courses including EASA Part 21 and Gulf Civil Aviation Authority (GCAA) Civil Aviation Regulation (CAR 21) for details please see www.sassofia.com or emailoffice@sassofia.com
