Sofema Aviation Services (SAS) www.sassofia.com considers the various activities associated with delivering the required oversight of an EASA Part 147 compliant organisation.
Concerning the Requirement to perform Quality Audits
147.A.130(b) states that the approved Part-147 organisation shall establish a quality system including:
- An independent audit function to
o Monitor training standards,
o Ensure the integrity of knowledge examinations and practical assessments,
o Ensure compliance with and adequacy of the procedures, and
- A feedback system of audit findings to the person(s) and ultimately to the accountable manager referred to in 147.A.105(a) to ensure, as necessary, corrective action.
The Quality Audit System is scalable means that for a larger organisation more audits will be assigned to the various business areas.
In the case of audits that are carried out by the Competent Authority (CA) any findings identified will be categorised as either level 1 or level 2.
On receipt of the finding the MTO must define an acceptable corrective action plan and demonstrate corrective action to the satisfaction of the competent authority within an agreed period, after receipt of notification of findings according to 147.B.130.
Failure to complete rectification of level 1 findings within three days of written notification shall entail revocation, suspension, or limitation by the competent authority, of the MTO approval in whole or in part.
It is of critical importance to ensure that all findings are actioned within the time scale granted by the competent authority, in the case of level 2 findings, the competent authority may give 6 months notice of the need for rectification or less, dependent upon the seriousness of the finding. When 6 months are allowed, initial notification = 3 months to the quality manager followed by the final 3 months notice to the accountable manager.
Note: This means that the quality system itself should be independently audited. The competent authority cannot perform this function on behalf of the organisation.
Within its approved procedures, the organisation has to monitor the quality system’s procedures.
This implies that quality system monitoring itself must be subject to internal audits with the following objectives:
- No conflict of interest is allowed – it is not permitted that such a function be performed by quality system’s staff;
- This activity can be also outsourced;
- Ensure the right level of the auditor(s)’ position within the organisation shall be met in order to assure the objective of 147.A.130(b)2. (e.g. conflict of hierarchy, which could hinder an efficient and transparent report to the accountable manager);
- In addition, the audit programme/plan needs to reflect this regulatory aspect.
Concerning the Difference Between Quality Control & Quality Assurance
Managing the Quality process within an EASA 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
o Whilst QC process are embedded in the production process which in fact should typically be found related to the successful delivery of Basic and or Type Training.
o 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 EASA 147 MTOA Approval 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).
Which EASA Part 147 Elements are considered Quality Assurance (QA) and which are Considered Quality Control (QC)
- In summary we can say that an EASA 147 quality system includes:
o An independent audit function to monitor training standards. (QA)
o A process to ensure the integrity of knowledge examinations and practical assessments. (QC)
o Compliance with and adequacy of the procedures, and (QA & QC)
o 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)
o All aspects of Part-147 compliance should normally be checked every 12 months. (QA)
o 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.
o 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).
o When training or examination is carried out under a sub-contract control system the following is required:
o Pre-audit procedure – Part-147 MTO auditing prospective subcontractors to determine whether their services meet the intent of Part 147. (QA)
o A renewal audit of each subcontractor at least once every 12 months to ensure continuous compliance with the Part-147 standard. (QA)
– The sub-contract control procedure should record audits of the subcontractor and have a corrective action follow-up plan.
The QA audit process must be independent which means the auditor is not involved in the day to deliver delivery of training or management of processes. (This includes the preparation of the TNA and required Validation which is a QC process)
It should also be understood that the audits do not replace the need for ongoing Quality Control (QC) activities.
The quality assurance audits which we will carry out are considered as “compliance audits” and essentially follow a prescriptive checklist ensuring that all elements of the process are delivering in accordance with both the regulatory and organisational requirements.
Concerning EASA Part 147 Quality Control (QC Function)
- A QC Function should also exist to ensure that the instructors are delivering training to the required standard. Such “Process” once documented and implemented are also subject to periodic QA audit.
- Audit reports will be produced for every audit and if necessary corrective actions will be raised to identify any discrepancies. It is important that all discrepancies are accepted by the relevant post holder and that the time to rectify the defect is mutually agreed between the auditor and the auditee.
EASA Part 147 Accountable Manager Responsibilities
- The Accountable Manager (AM) is to be kept aware of all audit findings so that he is able to monitor compliance as appropriate.
- It is not acceptable to contract this follow up process to outside persons it must be the AM and other responsible Post Holders (PH) / Nominated Persons (NP) who are actively aware of the status of any outstanding discrepancies.
Note: It is expected that there will be active involvement of the AM with regular meets being held between the AM and the various stake holders within the organisation to check on the progress of the rectification.
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Sofema Aviation Services (www.sassofia.com) offers Regulatory Compliant training related to the development of an EASA Part 147 Training Needs Assessments (TNA) please see the following course: EASA 147 Developing Training Needs Analysis (TNA) for Type Rating Training Courses – 2 – Days or email us at firstname.lastname@example.org
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