Sofema Aviation Services (www.sassofia.com) Reviews Base Maintenance Audit Basics
Consider the following as checkpoints to take note or develop during the audit of Base Maintenance essentially as an opportunity to validate the effectiveness of the Base Maintenance System – remember the goal of the auditor is to confirm conformity not to find problems.
a) During base maintenance, the individual tasks which are signed for are not in fact certifications but merely a record of who has completed the task. How is this process managed – who can sign as the mechanic & who can sign as the “inspector” – how does the organisation ensure the effectiveness of this process. (Part of the competence oversight process)
b) Where is the individual’s responsibility in a) above & where is the organisation’s responsibility – who is each discharged and how is each validated
c) How does QC function in the Maintenance Environment. (Consider 145.48 Performance of Maintenance as relevant also here) For the Certification Staff / Manager / Supervisor – Note there is no “Separate” QC in EASA 145 – You are responsible for your own QC unless the Organisation develops a separate QC process – if yes management/control/oversight/measurement of effectiveness.
d) Knowledge of Airworthiness Terms – The certifying Staff are working with AD’s Mods, STC,s TSO & Repair RAS / 8100-9 / ETSO, PMA & EPA, LLP, DATA from CS-25 / FAR 25 etc – do they know what each team means and the implications related to the part they fit.
Note the Certifying staff is the last link in the chain – if some higher up the chain has created a finding would the certifying staff understand it?
What makes an STC “special” in relation to “continuing airworthiness?
Speak to 1 Certifying staff if he struggles to satisfy you regarding his knowledge try another then a third – after 3 certifying staff failing to demonstrate an understanding then for sure we have a systemic issue, if it is just 1 person then it is still an issue but not systemic:
i/ During the audit it was identified that several certifying staff where unable to demonstrate an adequate understanding of several regulatory terms and their engagement with the maintenance process terms not limited to the following were not adequately understood with AD’s Mods, STC,s TSO & Repair RAS / 8100-9 / ETSO, PMA & EPA, LLP, DATA from CS-25 / FAR 25
ii/ The Base Maintenance Manager (In-Charge) was not aware of this deviation due to lack of Competence oversite/ supervision
iii/ XYZ Quality Assurance has failed to identify the discrepancy regarding the competence level of certifying staff.
So you now have 3 findings from a single event, such auditing activity raises the bar and draws the organisations attention to a lower level of performance – never lose sight of the fact that you are representing the operator and expect a high level of service.
e) Consider that whilst the Operator has responsibility for the configuration control – It is also the responsibility of the EASA Part 145 organisation to actually understand in the correct way how the maintenance system works, can it demonstrate what it is doing is fully compliant with the requirements!
f) Physical Inspection of the aircraft – has the area been cleaned in preparation for Inspection Activities.
g) The Inspector MUST be satisfied that the area is ready for Inspection. It is not possible to inspect a dirty area.
h) Does the Inspector know what they are actually looking for during this inspection? (Accept/reject criteria. Based on what standard?) – What is the role of CS25?
i/ What would be the typical description of the defect to be detected, (preferably with an illustration of a sample defect)
ii/ Do we have all the prerequisites in place (are we comfortable) – lighting, vision, access
Note – It is never the intention of the inspector to deliberately commit an error by missing something during an Inspection, it happens for a range of reasons! For example – Lack of familiarity – New to the area or process, not aware of relevant documentation or Complacency – seen it all before many times – been there done that!
i) Can the workers demonstrate knowledge regarding the organisations’ process for occurrence reporting system and the understanding of the importance of the worker’s obligations to report occurrences, incorrect maintenance data and existing or potential defects?
j) How effective is the Handover Process ? have poor handovers ever contributed to internal events or audit findings – if yes where is the weakness and opportunity to improve!
k) All Maintenance Staff and in particular Certifying Staff have both a “personal” and “organisational” obligation to report into the organisation system, how is this being demonstrated? Are you personally fulfilling this obligation?
l) How effective are the aircraft inspectors – do they understand the difference between a Visual Check & General Visual Check
Visual Check – Identified as “Operational / Visual Check” (OP/VC or OPC/VCK) by MSG3 – A visual check to observe an item and determine whether the item is fulfilling its intended purpose.
General Visual Inspection (GVI)
A general visual examination of an interior or exterior area, installation or assembly to detect obvious damage, failure or irregularity. This level of inspection is made from within touching distance unless otherwise specified. A mirror may be necessary to enhance visual access to all exposed surfaces in the inspection area. This level of inspection is made under normally available lighting conditions such as daylight, hangar lighting, flashlight or droplight and may require removal or opening of access panels or doors. Stands, ladders or platforms may be required to gain proximity to the area being checked.
Please see the following link https://sassofia.com/aviation-quality/
For additional information please see www.sassofia.com or email office@sassofia.com
Tags:
EASA / GCAA, Compliant Base Maintenance, Quality Assurance Audits
