The FAA System would not work !
Going back in time at the inception of EASA it was recognized that a direct approval system similar to the FAA system would require far too much in the way of oversight. with so many different countries and jurisdictions it would be very challenging to manage in the same way the FAA operates.
What is Plan B?
With some 30 countries involved each of which is directly responsible for its own business – the thought turned to creating a standard which was harmonized against the FAA but which operated in a different way:
a) The Organisation is approved (licensed) to deliver a regulated service.
b) The Organisation and its accountable manager are legally responsible to comply with the regulations, and to be able to demonstrate this on a continuous basis.
c) The role of Quality Assurance (QA) now called compliance is to ensure that the organisation is fully aware of any gaps between the regulations and the actual situation.
So the Organisation is responsible for itself – why no licensed regulatory training organisations?
Because it is not relevant – when we are talking about organisational compliance we are focused on how to do it in the correct way, means it is an organisational obligation.
So it is not possible to approve an “external” organisation as a third party to be licensed to deliver regulatory and competence related training. Such a process would be detrimental and would reinforce the misunderstanding that in some way the organisation is removed from its standards of delivery.
Lets be clear who is responsible
a) The organisation is 100% responsible for compliance with the regulations and for competence management of its staff.
b) It is not possible for an external regulatory training organisation to affect this obligation rather the external Regulatory training organisation is a “service provider” and it is up to the receiving organisation to ensure the service meets its needs and expectations.
c) Such approval therefore can only come from the receiving organisation
Each time a third country organisation asks for an EASA issued license to accept a regulatory training company as a service provider, they are sharing that they do not understand the above or the role of indirect approval where the organisation is 100% self responsible (and there are no EASA issued licences for such activities).
Why is EASA part of the problem?
Simply because they allow so much misunderstanding to exist without providing the appropriate clarification as would normally be expected from such a prestigious organisation as EASA.
The reality is not only does the EASA system work exceptionally well it is being voluntarily embraced by many countries around the world.
The Bottom Line
Making Organisations 100% responsible for their own destiny which of course includes compliance and competence as a safe way of managing aviation is without equal.
To empower the regulator as a competent authority to oversee this process is also correct as long as the Competent authority are trained to audit in the correct way.
The Challenges
1) For Organisations operating with an EASA environment to understand totally their obligations
2) For Regulatory Authority Auditors to be competent to audit the organisation in a meaningful and not just “tick the box” way (Do not just ask the organisation how they do ABC, ask how they measure the effectiveness of the choice to do ABC!)
Essentially challenging the “why” to understand
And never forget Regulatory Compliance is Minimum Compliance
Steve Bentley is MD of SAS www.sassofia.com with 45 years commercial aviation experience.
