Presented by Steven Bentley MD of Sofema Aviation services comments or observations are welcome please email office@sassofia.com
The following non exhaustive list is a guide to the effective auditing of Competence Management in a EASA Part 145 organization. All requirements are derived from either IR Implementing Rule requirements. Or AMC Acceptable Means of Compliance requirements.
This list is provided with the hope that it will assist those who are wishing to audit some or all of the organizational elements associated with the management and implementation of EASA 145 Competence Management Systems.
Audit Questions and Subjects
1/ How is the Competence Management system controlled ? – those managing the system should have a full understanding of the needs of the competency system, how is this management evidenced.
2/ Is the Competence Management Procedure fully Documented ? – The Competence Management Procedure should be fully described in such a way that there is consistent delivery across the business.
3/ How are the various standards defined for each job position ? – Are the standards identified in sufficient detail to allow a consistent and standardized measurement to be delivered.
4/ How is a consistent measure of the job performance delivered ? – What processes, techniques or mechanisms are available to promote effective measurement of performance?
5/ How are the testers trained and assessed? – As a result of this assessment, an individual’s qualification should determine: level of ongoing supervision and whether unsupervised work could be permitted also the need for additional training.
6/ How is the organization managing work competency at the shop floor level?
7/ How do supervisors and foreman know the status of the competence of the people who they are using – visibility of competence status ?
8/ How does the organization determine adequate initial and recurrent aircraft inspection training standards.
9/ All staff should be able to demonstrate knowledge of and compliance with the maintenance organisation procedures, as applicable to their duties. – How is this demonstrated ?
10/ Review the methods of providing visibility of Organisational procedures, – what training is provided ?
11/ What records are available to confirm understanding by all relevant personnel of organizational procedures ?
12/ How Is this understanding of human factors demonstrated ?
13/ Does the company invest in detailed job descriptions or choose an alternate solution –determine for all appropriate positions.
14/ What documented system is available to demonstrate the measurement of the ability of managers to manage work output, processes resources and priorities ?
15/ How does the organization manage and measure the need to ensure compliance with maintenance data management processes ?
16/ How does the organization manage and measure the need to ensure working supervisors have clear instructions regarding the segregation of management responsibilities from the need to perform maintenance and certification activities.
17/ How does the organization manage and assess on an ongoing basis the competency of mechanics to understand the maintenance data to a level whereby the can assess the quality of the data and determine mistakes etc.
18/ What training is made available to mechanics –initial and ongoing – how is it managed.
19/ What additional processes are in place in respect of the Competence management Process of this group of Staff (Specialized Services)
20/ How does the organization Document Inspection Standards ?
21/ How is the Organisational Inspection Standard Trained ?
22/ How does the organization manage and assess on an ongoing basis the competency of Certifying Staff to maintain diligent and appropriate certification behaviour.
23/ Where is this standard to maintain diligent and appropriate certification behaviour documented ?
24/ How does the Company Measure and Manage Auditor competence ?
25/ What auditor training and oversight systems are in place ?
26/ What evidences are available to support the demonstration of Auditor Soft Skills ?
27/ How does the Organization manage human factors training to make it organization specific ?
28/ What measures are in place to assess the effectiveness of Human Factors Training ?
29/ How does the organization assess initial competence to preclude immediate HF training as appropriate ?
30/ How does the organization collect feedback from H F Continuation Training sessions ?
31/ How is this information used within the organization to improve the HF management process ? (feedback system into quality system).
32/ How is the process to review external sources of information relevant to Human Factors Managed.
33/ How is the FTS Training managed to ensure Customer FTS procedures are acknowledge and incorporated into procedures. (For example Independent Inspection and Verification).
34/ Is the organization process for complying with AMC 20-22 fully documented ?
35/ How is practical training managed for:
a/ Persons required to inspect EWIS
b/ Persons required to perform EWIS installation and modification
36/ How is the assessment periodicity managed and controlled ?
37/ Does the organization have a process to build up an effective record of ongoing competence status.
38/ Does the organization have a process to validate external competence records (sample or 100%).
39/ Is there an acceptable process which is documented suitable for each category of staff to deliver competence assessment.
40/ Is there an acceptable process which is documented suitable for each category of staff to deliver ongoing competence assessment complete with feedback process.
41/ Is there an acceptable process which is documented suitable for each category of staff to demonstrate ongoing competence assessment complete with feedback process.
42/ Is there a documented process which describes a procedure which may be followed to ensure acceptability or conformity in respect of Quality audit staff knowledge of applicable officially recognized standards.
43/ Has the organization documented a standard by which the identified element or requirement may be compared – Training in regulations as appropriate, to the jurisdiction, comprehensive understanding of the company processes and procedures. EASA / FAA / ISO / ICAO / IATA.
44/ Do the Quality auditors have a knowledge of auditing techniques including Planning, conducting and reporting.
45/ Have Quality Auditors attended an audit course approved and accepted by the organization.
46/ How does the organization announce its capabilities (MOE ?) & How is this information delivered?.
47/ How does the organization confirm that the appropriate people have the necessary understanding of the MOE.
48/ Knowledge of Part-M, Part-145 and any other relevant regulations – How is this information delivered?
49/ How does the organization confirm that the appropriate people have the necessary understanding of the regulatory environment.
50/ How does the organization confirm that the appropriate people have the necessary understanding in respect of knowledge of occurrence reporting system and understanding of the importance of reporting occurrences, incorrect maintenance data and existing or potential defects.
51/ How does the organization manage its need to report both Mandatory and Non Mandatory events.
52/ Where is the reportable MOR criteria located ? Does this Criteria equate to AMC 20-8 ?
53/ How does the organization manage its obligations to ensure all staff are suitably trained and briefed to behave in an appropriate way in respect of safety risks and safety behaviours.
54/ How is the FTS Training managed to ensure Customer FTS procedures are acknowledge and incorporated into procedures. (For example Independent Inspection and Verification).
55/ Understanding of professional integrity, behaviour and attitude towards safety – How does the organization manage its obligations to ensure all staff are suitably trained and briefed to behave in an appropriate way in respect of safety risks and safety behaviours.
56/ How does the Company manage organizational culture to deliver positive results.
57/ How is this information delivered? to Understanding of conditions for ensuring continuing airworthiness of aircraft and Components.
58/ How does the organization deliver training in respect of Duplicate Inspections, Independent Inspections of Critical Tasks.
59/ How does the organization confirm that the appropriate people have the necessary understanding to compile and control completed work cards.
60/ Personnel ability to consider human performance and limitations. – How Is this demonstrated
61/ How does the company determine required qualifications for task performance – Where is this information located ?
62/ How does the organization manage the Stores Inspection Process.
63/ What Training and Validation are available for Stores Inspection Processes in respect of EASA / FAA / Suspect Parts / Shelf Life Procedures – Internal Company Procedures.
64/ How does the organization assess the ability to identify and rectify existing and potential unsafe conditions.
62/ How does the organization manage the competence of third parties involved in maintenance activity.
63/ how does the organization demonstrate the availability of approved data and use of correct procedures including training and testing – How is the understanding tested ?
64/ How does the production planning process extending into individual work planning ? Do Supervisors and Certifiers, is the process fully documented and understood ?
65/ How does the organization ensure that Supervisors and Managers have the ability to promote the safety and quality policy.
66/ Does the organization promote a proactive SMS policy ? , Is the SMS program fully documented ?
67/ Is the SMS program trained and communicated effectively ?
68/ How is it the SMS and Quality Policy knowledge tested within the organization ?
69/ How does the organization identify and communicate the applicable standard ? To properly process removed, uninstalled and rejected parts.
70/ How does the organization identify and communicate the applicable standard ? to properly record and sign for work accomplished
71/ How does the organization identify and communicate the applicable standard ? to recognize the acceptability of parts to be installed prior to fitment
72 / How does the organization identify and communicate the applicable standard ? to split complex maintenance tasks into clear stages
73/ How does the organization identify and communicate the applicable standard to understand work orders, work cards and refer to and use applicable maintenance data
74/ How does the organization deliver training in respect of use of IT internal and external systems to include where necessary knowledge of EASA website and content
75/ How does the organize identify and communicate the applicable standard ? to use, control and be familiar with required tooling and/or equipment.
76/ How does the organization communicate the applicable standard to identify and manage soft skills to include communication and literacy communicate the applicable standard ?
77/ How does the Company Measure and Manage Auditor competence ?
78/ What auditor training and oversight systems are in place ?
79/ What evidences are available to support the demonstration of Auditor Soft Skills ?
80/ How does the organization identify and communicate the applicable standard in respect maintenance error investigation skills
81/ How does the organization identify and communicate the applicable resources management and production planning skills, how is the understanding tested.
82/ How does the organization promote and test teamwork, decision-making and leadership skills
Sofema Aviation Services provides training in auditing EASA Part 145 Competence Assessment as well as aviation quality audit services and training. Please visit www.sassofia.com or email office@sassofia.com
