An Opinion expressed by Steven Bentley Managing Director of Sofema Aviation Services www.sassofia.com considers the role of the Quality Assurance Department in respect to the generation of the varius procedures required to comply with EASa regulations.
An EASA approved operator or MRO must employ at least 1 Quality Manager (although EASA are currently in the process of renaming this person the “Compliance Manager”)
In addition the organization must ensure that it has fully compliant and documented processes to show how all regulatory requirements are complied with.
Typically these compliances are contained in the following organizational manuals, Operations Manual Part A, Continuing Airworthiness Management Exposition (CAME). Maintenance Organization Exposition (MOE). They may also be further described in Departmental and local procedures.
The key comment in this story is that the process and procedures are part of the Quality Control System and as such are typically owned by the Post Holder responsible for the particular business area. (of course Quality Procedures are excluded from these comments. and typically belong to the QA office )
The Accountable Manager is responsible for the entire Quality System (Plus the Safety Management System)
QC being the delivery of the process and procedures required to demonstrate compliance.
(QC as stated previously is the responsibility of the Postholders)
QA being the delivery of the organisational product that complies with all regulatory and company requirements. (QA of course being the responsibility of the Quality Manager).
The EASA Regulatory system requires that audits are delivered as an independent and objective exercise. Therefore we have to ensure that the auditor is not directly instrumental in the development or management of the procedures.
One way of ensuring this independence of audit distance is to ensure that the Quality Assurance Department has no “direct” involvement in the development of procedures.
Is it acceptable for the Quality Assurance Department to “Manage” the Procedures
Manuals.
Of course! , managing and presenting the documents to the CAA for approval are typical duties assigned to the Quality Department.
Such practices as QA managing the documents does not in any way compromise the integrity of the ownership of specific procedures.
Is it acceptable for the Quality Assurance Department to provide guidance on the content of the procedures.
An essential function of an effective Quality Assurance Department is to provide support and guidance to other departments in the organization and of course process and procedure support forms an integral part of this process.
There is however a big difference between support, guidance and ownership.
Sofema Aviation Services Provides regulatory training including Quality Audit and Quality Management.
For details of available trainings please visit www.sassofia.com or email office@sassofia.com
Tags:
EASA, organisational procedures, Quality Manager, Quality System
