Comments by Steve Bentley Group CEO of Sofema Aviation Services
Introduction
When we consider a Subpart G Organisation, we are involving a range of skills in just the same way as we do within a Part 145 Maintenance Organisation.
Whilst there is a clear definition regarding competence expectations within the 145 regulatory requirements, it is still not so defined in a Part 21 Subpart G Production Organisation – however not to lose sight of the fact that Competence is just as important!
Regulatory Obligations Driving Competence
21.A.139(b)(1)(xi) The quality system shall contain …. control procedures for personnel competence and qualification.
21.A.145 The production organisation shall demonstrate, on the basis of the information submitted law the POE that:
With regard to general approval requirements .. number and competence of staff to discharge obligations under 21.A.165.
With regard to certifying staff, authorised to sign the documents issued under 21.A.163:
a) The knowledge, background and experience are appropriate to discharge their allocated responsibilities.
b) It is the approved organisation’s responsibility to ensure that their staff are competent to carry out the production activities they have been assigned. (This is accomplished through the assessment of each individual, against a certain level or standard.)
c) Competence should be assessed, for all staff that have a direct influence on the parts or products
- Production staff
- Production engineers
- Certifying staff
- Inspectors
- Specialist services (NDT)
- Painters/finishers
The Role of Certification & Competence
We do not have a Part 66 Aircraft Maintenance Engineers Licence (AMEL) within a Part 21 environment so the need to assess and manage competence sits directly with the Production Organisation
Certifying Staff (CS) are nominated by the Production Organisation (PO) to ensure that products, parts and/or appliances are suitable qualified related to the provision of Statements of Conformity or Release Certificates.
Moreover, the actual responsibility for the release of products, parts and appliances is placed on the nominated certifying staff.
Certifying Staff Responsibilities
Any actions required to be carried out by production certifying staff to confirm conformity with the applicable design data.
To enable the certifying staff to exercise their responsibilities adequately an effective release to service procedure should include the necessary checks either directly or by confirming that they have been addressed within the overall business management system
Note – The release to service procedure should describe in detail the completion of the EASA Form 1, stating all information which needs to be included in each block.
A Typical Procedure for ensuring conformity will include the following as a minimum
That the subject part number(s) is covered by current POA scope
That the subject part number(s) is covered by a DOA/POA arrangement
That the subject part number(s) is permitted for direct delivery to end users if applicable
Contract / Purchase Order requirements
That the subject part number(s) are in compliance with the applicable production documents and applicable design data
That the applicable design data is approved (e.g. via TC/STC/ETSO or minor change) for airworthiness purposes or will be subject to such approval for conformity purposes
Completeness of all specified and executed production operations
Approval and execution of any concessions
Note – Concessions that affect fit, form or function shall be stated in block 13 of the EASA Form 1
21.A.165 – Obligations of the Production Holder
It’s the organisation’s responsibility to ensure that their staff are ALWAYS competent to carry out the production activities.
An evaluation of the competence of personnel is performed as part of the quality system. This should include, where appropriate, verification that specific qualification standards have been implemented, for example NDT, welding, etc.
Training should be organised to establish and maintain the personal competence levels determined by the organisation to be necessary.
To do this, a program of update training should be developed:
An effective update training program needs to be developed alongside the competency assessment process and this should be tailored to the specific requirements of both the individual and the role.
The training should be influenced by the individual’s performance, new production machinery or changes to the production environment.
It should also include a mechanism, to establish the currency and validity of the minimum competency standard and that the individual can still attain that standard.
Such a procedure should be transparent and documented, thus allowing the competent authority to quickly determine the level of compliance and commitment to retaining standards.
Typical Contents of a Training Program should include:
a) Process Knowledge including Human Factors (HF)
b) Regulatory Knowledge appropriate to job role Part 21 / Part 145
c) Corporate Procedures required to ensure compliance with organisational requirements
d) Skills test, related to the use of specific tooling or machinery
Competence Process to Include
Theory review, which will give you an indication as to whether the person has retained the information from their training and the conviction to dictate the required course of events.
Practical review to assess whether they can undertake the task they’ll later be authorised to do or certify.
Competence Assessment Procedure to consider
a) Qualifications / Experience / Relevancy
b) Required Certificates (NDT?)
c) Previous Training / Industry relevant or upskilling
d) Is there a deficit in their qualifications or training? / Training Needs Analysis (TNA)
Competence Elements to Consider include:
knowledge of the System – Do they understand the equipment, are they comfortable with it?
Ability to Plan – Are they able to follow the work plan – evidence-based?
Ability to prioritise tasks within the production process?
Do they make the right decisions, regardless of outside influences?
Appropriate use of initiative -asking questions when necessary?
Able to demonstrate they are reliable within the workplace?
Able to deliver consistent and accurate results accurate, within tolerance?
Sofema Aviation Services www.sassofia.com and SofemaOnline www.sofemaonline.com provide classroom and online EASA Part 21 Training for details please see our websites or email office@sassofia.com or online@sassofia.com
