Sofema Aviation Services www.sassofia.com offers EASA Part M training for industry and the regulator to cover all elements essential to the delivery, management and understanding regarding the operators responsibility in respect of Continued Airworthiness.
It is important to understand the difference between Contractual and Sub Contractual Relationships in an EASA Aviation context, particularly in respect of a Part M organisation who may have both relationships at the same time with a EASA Part 145 organisation.
Contract Relationship
A contract relationship makes the contracted organisation (The organisation awarded the contract) responsible for the compliances associated with the contract activity.
For example, where an operator awards a contract to a EASA Part 145 approved maintenance provider, the responsibility for the certification of the activity.
It should be noted of course that this is not always allowed, for example it is not possible for an operator to transfer its responsibility for mandatory oversight of its obligation to deliver and ensure compliance with regulatory requirements.
Sub-Contract Relationship
In a Subcontract relationship the responsibility remains with the organisation issuing the contract.
For example an Operator awarding a contract for ground service support during turn arounds.
Considering the Quality and Safety Issues
There are two issues to consider in respect of Quality and one in respect of Safety
Quality Control
The operator is responsible for Quality Control procedures and process where it has a direct and specific responsibility, so in the case of Sub-Contract Relationships this places an obligation on the Operator to ensure the process is fully compliant with all regulations even though the activity is performed by another organisation.
Quality Assurance
The operator should ensure that both Contract Relationships and Sub Contract Relationships are included in the operators audit schedule. The scope, depth and periodicity of the audit should be appropriate for the activities being performed or services delivered.
The operator will also audit its own internal processes including the management, documentation and delivery of its own Safety Management System (SMS).
Note that there is a standing obligation to ensure the Quality System covers all elements of the Organisations activities once per year.
Safety Management
The Operator is expected to have in place a Safety Management System this should extend to any organisation providing a Sub-Contract Service to the operator. For Contract Services the contract organisation will have its own SMS system.
Please contact Sofema Aviation Services if you would like to find out more about the availability of both open and in company regulatory trainings. www.sassofia.com or email office@sassofia.com.
