Managing the Quality process within an EASA Part 147 organisation brings with it a number of challenges, which essentially focus on both the role of the independent audit together with a number of additional activities, which may be considered under the umbrella of “Quality Control”.
Consider the difference between Quality Assurance and Quality Control, Whilst QC process are embedded in the production process (which in the our case is the successful delivery of Basic and or Type Training, QA process deliver an independent audit, which looks at compliance with the regulations (external compliance) as well as compliance with all our 147 procedures (Internal Compliance).
During the acceptance process It is a requirement that when the regulator formally accepts the MTOE that all Procedures are also deemed to be acceptable to the competent authority. Procedures shall ensure that correct and proper training standards together with full compliance with all relevant requirements in EASA Part 147. (Changes to the MTOE should be notified and accepted by the regulatory authority)
So in summary we can say that an EASA 147 quality system includes:
a) An independent audit function to monitor training standards (QA);
b) A process to ensure the integrity of knowledge examinations and practical assessments (QC);
c) Compliance with and adequacy of the procedures, and (QA & QC);
d) A feedback system of audit findings to the person(s) “Nominated Person / Post Holder and ultimately to the accountable manager to ensure, as necessary, corrective action (QA);
e) All aspects of Part-147 compliance should normally be checked every 12 months (QA);
f) Audits may be carried out as one complete single exercise (In the case of a small maintenance training organisation) or subdivided over the year period i.a.w. a scheduled plan. (QA note that stronger Quality Assurance Programs demonstrate multiple audits;
g) In larger organisations it is Possible to combine different quality systems (as applicable this could be for example in the case of EASA 145 / EASA 147 Organisation);
h) When training or examination is carried out under a sub-contract control system the following is required;
i) Pre-audit procedure – Part-147 MTO auditing prospective subcontractors to determine whether their services meet the intent of Part 147;
ii) A renewal audit of each subcontractor at least once every 12 months to ensure continuous compliance with the Part-147 standard;
iii) The sub-contract control procedure should record audits of the subcontractor and have a corrective action follow-up plan.
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