Why do some Organisations and Indeed some Regulators incorrectly believe that EASA issues approvals to organisations to deliver Regulatory Training?
After 5 years of delivering EASA compliant regulatory training, we at Sofema Aviation Services www.sassofia.com are still being asked to supply (in support of our organizational capability to deliver regulatory training) evidence of either EASA approval as a Regulatory Training Organization, or even worse EASA Part 147 approval !
EASA Part 147 approval is only for the training of Part 66 licensed Engineers, It has no (direct) bearing on the responsibility of the EASA Part 145 Organization to meet its internal obligation.
Within a “145” Environment there is a need to provide training to a large group of staff, trainings including the following will typically be found.
“Stores Inspection”
“Production Planning”
“Fuel Tank Safety”
“EWIS”
“Human Factors”
“SMS”
Effective delivery of all of the above organizational training obligations are the DIRECT responsibility of the organization itself and not through any other company holding an approval issued by EASA (as mentioned there is NO EASA approval)
The ability of an Organization to manage its internal competence is in fact a fundamental element of its Operational or Maintenance Approval, and a key area which should be demonstrated during any Regulatory Audit or oversight visit.
Where does this confusion come from ? Is it Lack of Knowledge ? on behalf of Operators Maintainers and Third Country Regulators, or Lack of Communication on the part of EASA.
Possibly it is a combination of all of the above, what is certain however is that this situation persists even at a country level.
One of the reasons that the EASA Regulatory system is gaining prominence throughout the world is the fact that it (the EASA system) places responsibility to ensure compliance in the most appropriate area. – The Operator or Maintainer.
Under The EASA system the Operator or Maintainer is totally responsible for compliance with all regulatory requirements. Moreover there is an organizational responsibility to perform compliance oversight and auditing, this is the Quality Assurance QA function.
Additionally responsibility is placed on the Organization to ensure that Competence is maintained at all levels, this includes the need for internal training to ensure appropriate knowledge, which of course includes knowledge of regulations appropriate to the effective delivery of the Organisations Regulatory Obligations.
This training may in fact be performed internally or Sub Contracted to an External Organization. In the case of a Sub Contracted provider, It is the responsibility of the Organization (typically through the Quality System) that the provided service, meets the needs of the Organization.
So in essence the organization provides training to its staff, to ensure the knowledge element of the competence process, the Quality System maintains oversight which can be demonstrated to the Regulatory Authority.
It follows that the “standard” is managed by the Organization not the Regulator. (Off course the Regulator shall ensure that the process is delivered in a diligent way, usually by audit).
The problem occurs when the Regulator does not fully understand the role and responsibility of the Organization to self manage.
Organization and Regulatory Authorities should understand that within the EASA system the following points are valid :-
a) There is no such thing as EASA accreditation to deliver regulatory training, EASA have never awarded certification to deliver such training to any organization;
b) Part 147 approval is only an organisation approval to deliver Part 66 training to licensed aircraft engineers & has no other relevance. (For example to unlicensed stores personnel or production planning staff);
c) It is not required that Part 145 trainings be delivered by a Part 147 organization;
d) Part Operations Training & SMS Training is not covered by EASA approval
How can we change this misunderstanding ?
a) by reiterating that the strength of the EASA system is the Organisations ability to manage itself directly.
b) by sharing the understanding that the Role of Regulator is as Competent Authority providing support and oversight, rather than direct control.
Sofema Aviation Services https://sassofia.com/regulatory-training-courses/ currently offers more than 90 regulatory and vocational training courses.
Comments? please email office@sassofia.com
Tags:
EASA Regulatory Training Approval, Part 145, Part 147, Part 66, Sofema Aviation Services
