Steve Bentley MD of SAS (www.sassofia.com) takes a long hard look at the subject of Competence within the EASA 145 organisation.
How well is your competence management process working within your 145 Organisation?
ED Decision 2011/011/R 28/11/2011 GM 2 145.A.30
(e) – Competence assessment procedure (Are you familiar with your organisations Procedure?)
The organisation should develop a procedure describing the process of competence assessment of personnel. The procedure should specify:
Persons responsible for this process / When the assessment should take place.
Credits from previous assessments / Validation of qualification records.
Means and methods for the initial assessment / Means and methods for the continuous control of competence including feedback on personnel performance (It is a typical procedure to document within the employees personal file to understand any training need and timeline to achieve)
********Personal Action Point********
Some people incorrectly consider competence assessment as a “negative” that someone is checking up on you – a kind of “Big Brother” situation. So clear this right out of your mind – Competence Assessment is directly connected to “Training Needs Analysis” TNA – It is an opportunity to benchmark where you are on your journey and support you going forward and this is it. The best part? It is a Win/Win for both the Employee & Employer – Why do you think this is?
Competences to be observed during the assessment in relation with each job function.
Actions to be taken when assessment is not satisfactory / Recording of assessment results.
So lets agree what we mean by competence
Well typically we are talking about people being “competent” to fulfil the role, That the employee has the necessary background, experience, and knowledge appropriate to the job role, In addition the employee also understands the company process and procedures which are relevant to the job role. Remember this is not a tick the box situation there is a continuing need for the employer to engage with the employee in the area of Competence.
Cleary then we can see that there are 2 elements to this process:
– The level of competence expectation placed on the employee, together with
– The obligations placed on the organisation to provide an appropriate level of training to ensure the employee has the necessary organisational knowledge. (Training Needs Analysis).
To complete the picture we need a process to assess the compliance with the various objectives which we need to consider to show effective management of the Competence Management Process.
So let’s consider how we can measure the effectiveness of the Competence Process
A competent employee will usually be an efficient employee – people who know what they are doing and how to do it in the correct way. So measuring the efficiency of our EASA Part 145 organisation in respect of the number of man hours to achieve our organisational objectives.
A low level of audit findings around the business areas will serve to identify that “in general” people are familiar with their obligations and they are performing in accordance with the documented process and procedures.
Low level of incident and accidents also provide an indication that things are running smoothly. There is a significant connection between competence and human factor error, where often the lack of competence becomes a pre-cursor to a particular event.
Employees who are treated with respect and provided with support, guidance and training tend to be more productive and to stay longer with the organisation.
Is competence important?
You bet ! Consider this – that more than 99% of things which go wrong where not supposed to have happened – They happened because people fall into traps – and on examination we are one way or another knocking on the door of competence. ( we should also understand that Effective and robust procedures will go a long way to eliminate traps and protect the employee ,however the employees must also contribute to this to achieve the maximum success.
So its all the responsibility of the Employer – Right ?
Wrong ! Consider that no one knows “you” in the way that “you” do – so therefore no one knows the potential gaps in the way you do. Sure the Employer can develop tests and processes to determine you weakness and exposure – but you already know many of the areas where you could possibly deliver personal improvements!
However we have to balance this against the effect of unknown – unknowns (what are unknown unknowns!) essentially we do not know what is essentially outside of our knowledge envelope. (In reality this is a smaller part of the overall issue)
Now consider the following points which are directly connected to “Your” competence
Can you answer “Yes” to the following?
a) Do you know in sufficient detail the purpose and content of the maintenance organisation procedures – this is not a learning exercise but you should be sufficiently familiar to know what is available and how to engage with it?
b) Do you know the meaning of the term complacency related to Aviation Human Factors?
Could you describe complacency and provide an example? How do you believe we can protect the organisation against complacency?
c) Are you able to understand all maintenance data to a level whereby you are able to assess the quality of the data and determine if there are any anomalies or mistakes?
d) Are you able explain Inspection Standards to a third party? From where are these standards taken?
e) Are you familiar with any customer specific procedures for example related to Fuel Tank Safety (FTS) or Critical Inspections Activities I.A.W EASA 145.A.48
********Personal Action Point********
Never forget if you do not have the information you need It is your responsibility to ask for it – never assume and never leave it until it is too late.
f) Have you been trained to perform EWIS Inspections I.A.W AMC 20-21
g) Are you familiar with EASA Part 145 & Part M to the level whereby you can interact with the regulation to determine requirements and obligations?
h) Are you sufficient knowledgeable regarding your organisations process for occurrence reporting system and the understanding of the importance of your obligations to report occurrences, incorrect maintenance data and existing or potential defects.
j) There is a direct obligation on you regarding professional integrity, behaviour and attitude towards safety – How does can you demonstrate you understand this? – Can you give an example?
k) Are you familiar with your companies SMS Policy ?
Can you explain the following Terms
i/ Hazard
ii/ Risk
iii/ Mitigation
iv/ Safety Assurance
v/ Root Cause
l) How would you describe your engagement with your companies SMS?
i/ Strong
ii/ Moderate
iii/ Weak
j) Do you know how to manage work sign offs and hand overs?
********Personal Action Point********
One of the biggest exposures we face in our Aviation Industry relates to issues related to Work Sign Off’s. Can you put your hand on your heart and say that you are “Clean”……….and if not why not !
What happens with you personally when you see issues related to competency?
Do you report into your Organisations Quality System – if not why not
********Personal Action Point********
All Maintenance and in particular Certifying Staff have both a “personal” and “organisational” obligation to report into the organisation system receive information. Are you personally fulfilling this obligation? (The information below if reported and acted on could possibly prevent a re-occurrence or save the organisation unnecessary loss)
When you become aware of an issue or event try answering the following questions
a) Is this the first time that this has happened?
b) Was it officially reported?
c) Was corrective action recorded?
d) Could it happen again?
e) Was it a routine task?
f) Was the person distracted? –would their actions have been correct in other circumstances?
g) Was there a standard set of rules to deal with this problem?
h) Why do you think the problem / Incident happened?
Is it related to any of the following Core Areas
People / Equipment / Environment / Task
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