EASA is becoming more focused on its expectations of how Civil Aviation Authorities (CAA’s) regulate and will require the “Regulatory Authority” (Competent Authorities) to develop oversight systems which look very much like those to be found within the European Aviation Industry.
Comments by Steve Bentley – CEO of Sofema Aviation Services (SAS)
Introduction
With the requirements of CAMO.B.200 Management system, EASA requires the following of the regulatory authorities – To establish and maintain a management system, including as a minimum (abridged):
A sufficient number of personnel to perform their tasks and discharge its responsibilities.
A system shall be in place to plan the availability of personnel, in order to ensure the proper completion of all tasks;
Note – the use of the word sufficient! – this is a favorite term used by EASA to bestow a degree of flexibility and subjectivity within the process- never the less it does mean that there is an obligation to be able to demonstrate an effective “benchmarking” of the status of the decision and determination made by the Competent Authority (CA).
For example, see the following and note the similarities with Industry:-
To demonstrate that the safety risk management process is operational, competent authorities should be able to provide evidence that:
(1) the persons involved in internal safety risk management activities are properly trained;
(2) hazards that could impact the authority’s capabilities to perform its tasks and discharge its responsibilities have been identified and the related risk assessment is documented;
Note – this would include for example the ability of the CA to effectively engage in dialogue with Industry with an appropriate level of support & due diligence.
(3) regular meetings take place at appropriate levels of management of the competent authority to discuss the risks identified, and to decide on the tolerability of risks and possible risk mitigations;
(4) in addition to the initial hazard identification exercise, the risk management process is triggered as a minimum whenever changes occur that may affect the competent authority’s capability to perform any of the tasks required by Part-CAMO;
(5) a record of the actions taken to mitigate risks is maintained, showing the status of each action and the owner of the action;
(6) there is a follow-up on the implementation of all risk mitigation actions;
(7) risk mitigation actions are assessed for their effectiveness; and
(8) the results of risk assessments are periodically reviewed to check whet.
Personnel qualified to perform their allocated tasks and have the necessary knowledge, experience, initial and recurrent training to ensure continuing competency;
Qualification and Training — General
It is essential for the competent authority to have the full capability to adequately assess the compliance and performance of an organisation by ensuring that the whole range of activities is assessed by appropriately qualified personnel.
Competent authority inspectors should have:
(1) practical experience and expertise in the application of aviation safety standards and safe operating practices;
(2) comprehensive knowledge of:
(a) the relevant parts of the implementing rules, certification specifications and guidance material;
(b) the competent authority’s procedures;
(c) the rights and obligations of an inspector;
(d) safety management systems based on the EU management system requirements (including compliance monitoring) and ICAO Annex 19;
(e) continuing airworthiness management including maintenance programme development and control;
(f) operational procedures that affect the continuing airworthiness management of the aircraft or its maintenance; and
(g) maintenance-related HF and human performance principles;
(3) training on auditing techniques and assessing and evaluating management systems and safety risk management processes.
(4) 5 years of relevant work experience for them to be allowed to work independently as inspectors. This may include experience gained during training to obtain the qualification mentioned below in point (a)(5).
Note – also the use of the word relevant! – this is another favorite term used by EASA to also bestow a degree of flexibility and subjectivity within the process- never the less it also means that there is an obligation to be able to demonstrate an effective “benchmarking” of the status of the decision and determination made by the Competent Authority (CA).
Additional Training Objectives Include –
Knowledge of a relevant sample of the type(s) of aircraft gained through a formalized training course. These courses should be at least at a level equivalent to Part-66 Appendix III Level 1 General Familiarisation.
Knowledge of maintenance standards, including fuel tank safety (FTS) training as described in Appendix III to AMC4 CAMO.A.305(g).
Personal Attributes In addition to technical competency, inspectors should have a high degree of integrity, be impartial in carrying out their tasks, be tactful, and have a good understanding of human nature.
Initial Training Programme:
The initial training programme for inspectors should include, as appropriate to their role, current knowledge, experience and skills in at least all of the following:
(1) aviation legislation, organisation, and structure;
(2) the Chicago Convention, the relevant ICAO Annexes and Documents;
(3) Regulation (EU) No 376/2014 on the reporting, analysis and follow-up of occurrences in civil aviation;
(4) overview of Regulation (EU) 2018/1139, its delegated and implementing acts and the related AMC, CS, and GM;
(5) Regulation (EU) No 1321/2014 as well as any other applicable requirements;
(6) management systems, including the assessment of the effectiveness of a management system, in particular, hazard identification and risk assessment, and non-punitive reporting techniques in the context of the implementation of a ‘just culture’;
(7) auditing techniques;
(8) procedures of the competent authority that are relevant to the inspectors’ tasks;
(9) HF principles;
(10) the rights and obligations of inspecting personnel of the competent authority;
(11) on-the-job training that is relevant to the inspector’s tasks; and
(12) technical training, including training on aircraft-specific subjects, that is appropriate to the role and tasks of the inspector, in particular for those areas that require approvals.
General Notes:
The duration of the on-the-job training should take into account the scope and complexity of the inspector’s tasks.
The competent authority should assess whether the required competency has been achieved before an inspector is authorized to perform a task without supervision.
Recurrent Training
(c) A programme for recurrent training should be developed that ensures that the inspectors remain competent to perform their allocated tasks.
The recurrent training programme for inspectors should include, as appropriate to their role, at least the following topics:
(1) changes in aviation legislation, the operational environment and technologies;
(2) procedures of the competent authority that are relevant to the inspector’s tasks;
(3) technical training, including training on aircraft-specific subjects, that is appropriate to the role and tasks of the inspector; and
(4) results from past oversight.
EASA observes the following – As a general policy, it is not desirable for the inspectors to obtain technical qualifications from those entities that are under their direct regulatory oversight.
Note – Sofema Aviation Services – Holds no Regulatory Approval and is able to provide independent training & consultancy support through our consultants and Instructors with many years of relevant experience including Regulatory Authority Inspectors.
Next Steps
Sofema Aviation Services is currently offering a number of courses that are specifically configured for Competent Authority Inspectors – all such courses are delivered by experienced persons with direct CA experience.
For further details and to enquire regarding specific professional and cost-effective support please email office@sassofia.com
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EASA Continuing Airworthiness, European Aviation Industry, Civil Aviation Authorities, Part CAMO, EASA Regulatory, sasblogs, SAS training, Regulatory Authority, Regulatory Authority Competence
