What is the Requirement?
Ref 145.A.30(e) and associated AMC/GM. Appendix IV to AMC 145.A.30(e) and 145.B.10(3). & AMC 20-22.
In the Case of EASA Part 145 – The organisation shall establish and control the competence of personnel involved in any maintenance, management and/or quality audits in accordance with a procedure and to a standard agreed by the competent authority.
In addition to the necessary expertise related to the job function, competence must include an understanding of the application of human factors and human performance issues appropriate to that person’s function in the organisation.
This should include also:
Fuel Tank Safety training (Appendix IV to AMC 145.A.30(e) and 145.B.10(3)).
EWIS training (AMC 20-22)
In the case of EASA Part M – AMC M.A.706 Personnel requirements
3. To enable the competent authority to accept the number of persons and their qualifications, an organisation should make an analysis of the tasks to be performed, the way in which it intends to divide and/or combine these tasks, indicate how it intends to assign responsibilities and establish the number of man/hours and the qualifications needed to perform the tasks. With significant changes in the aspects relevant to the number and qualifications of persons needed, this analysis should be updated.
How should the Organisation Assess the Competence of Quality Audit Professionals?
So in both of the above requirements the focus is on the organisation “managing” the competence and being in a position to demonstrate to the competent authority that this is being done in an acceptable way.
We the need to develop an organisational standard, this is just the beginning because we also need to make sure that we attain and retain the chosen standard –s o how do we measure?
We can see from the below item 4.1 to 4.9 an example of the basic criteria – however please note that for each item we should have an Organisational standard (what does a particular requirement look like in “our” organisation
AMC M.A.706 Personnel requirements
1. However, if a quality system is in place it should be independent from the other functions.
Note this comment is made because a small CAMO does not necessarily need to have a separate Quality Assurance Process (“in company”)
3. To enable the competent authority to accept the number of persons and their qualifications, an organisation should make an analysis of the tasks to be performed, the way in which it intends to divide and/or combine these tasks, indicate how it intends to assign responsibilities and establish the number of man/hours and the qualifications needed to perform the tasks. With significant changes in the aspects relevant to the number and qualifications of persons needed, this analysis should be updated.
4. Nominated person or group of persons should have:
4.1. practical experience and expertise in the application of aviation safety standards and safe operating practices;
Demonstrated by previous roles and responsibilities showing a senior level of involvement within the Industry
4.2. a comprehensive knowledge of:
(a) relevant parts of operational requirements and procedures;
(b) the AOC holder’s operations specifications when applicable;
(c) the need for, and content of, the relevant parts of the AOC holder’s operations manual when applicable;
The above item 4.2 is clearly generic as an EASA Part 145 or Part M QM clearly will not be expected to show compliance with “b” & “c” however in the case if “a” it would be expected that the potential QM would have a deep understanding and appreciation of the applicable requirements and procedures appropriate to the organisation.
4.3. knowledge of quality systems;
Cleary for our QM this will require a significant level of understanding appropriate to the nature of the role again with a deep understanding of different elements of the QA process – the expectations and the challenge of delivering an EASA compliant Quality Assurance System.
Typically we would expect to see the difference between ISO systems and EASA systems and the difference between the different types of audit which may be undertaken together with the various process for managing the audit program.
4.4. five years relevant work experience of which at least two years should be from the aeronautical industry in an appropriate position;
What do we mean by appropriate – it is a very special word with the potential to mean different things to different people accident or design?
Of course design! – To permit a degree of flexibility – however please consider the following
The Quality Assurance people are extremely important to the organisation as they are the “guiding light” and will show us where we are deviating (hopefully across a myriad of exposures) – which is why the more experienced the better.
Many organisation would not consider appointing a quality manager until he has worked as a Quality Auditor – Lead auditor / Training and Deputy Quality Manager (such exposure provides for a fundamental grounding, however note the earlier use of the word appropriate it is not written down)
4.5. a relevant engineering degree or an aircraft maintenance technician qualification with additional education acceptable to the competent authority. ‘relevant engineering degree’ means an engineering degree from aeronautical, mechanical, electrical, electronic, avionic or other studies relevant to the maintenance and continuing airworthiness of aircraft/aircraft components;
The above recommendation may be replaced by 5 years of experience additional to those already recommended by paragraph 4.4 above. These 5 years should cover an appropriate combination of experience in tasks related to aircraft maintenance and/or continuing airworthiness management and/or surveillance of such tasks;
So clearly the expectations relates to a fundamental knowledge of the “environment” you are going to be working in – a good “all rounder” will have significant experience across a line, base and workshop environment as well as Technical Services / Engineering , Planning & Tech Records.
4.6. thorough knowledge with the organisation’s continuing airworthiness management exposition;
Yes as well as the Maintenance Organisation Exposition MOE as appropriate essentially it boils down to the fact that you must be able to comfortable swim in the Organisation’s “waters”
4.7. knowledge of a relevant sample of the type(s) of aircraft gained through a formalised training course. These courses should be at least at a level equivalent to Part-66 Appendix III Level 1 General Familiarisation and could be imparted by a Part-147 organisation, by the manufacturer, or by any other organisation accepted by the competent authority.
‘Relevant sample’ means that these courses should cover typical systems embodied in those aircraft being within the scope of approval.
Very much depends on the circumstances off course however to manage the Quality System of an organisation managing maintaining or operating aircraft clearly requires that you should have a deep understanding of the nature of the aviation system and how the various components interact.
For all balloons and any other aircraft of 2 730 kg MTOM and below the formalised training courses may be replaced by demonstration of knowledge. This knowledge may be demonstrated by documented evidence or by an assessment performed by the competent authority. This assessment should be recorded.
4.8. knowledge of maintenance methods.
Again to be defined as an organisational standard – the term knowledge may simply indicate awareness – it should be specified and measured for consistency
4.9. knowledge of applicable regulations.
Again to be defined as an organisational standard – the term knowledge may simply indicate awareness – it should be specified and measured for consistency
Sofema Aviation Services offers over 40 Quality Audit related and Quality System courses please see https://sassofia.com/aviation-quality/ for further information to email office@sassofia.com
