EASA has taken a definitive step with the issue of EASA regulation 965/2012 with the development of the regulatory obligations driven by ORO.GEN.200 Management system –
(a) The operator shall establish, implement and maintain a management system that includes:
(1) clearly defined lines of responsibility and accountability throughout the operator, including direct safety accountability of the accountable manager;
(2) a description of the overall philosophies and principles of the operator with regard to safety referred to as the safety policy;
(3) the identification of aviation safety hazards entailed by the activities of the operator, their evaluation and the management of associated risks, including taking actions to mitigate the risk and verify their effectiveness;
(4) maintaining personnel trained and competent to perform their tasks;
(5) documentation of all management system key processes, including a process for making personnel aware of their responsibilities and the procedure for amending this documentation;
(6) a function to monitor compliance of the operator with the relevant requirements. Compliance monitoring shall include a feedback system of findings to the accountable manager to ensure effective implementation of corrective actions as necessary; and
(7) any additional requirements that are prescribed in the relevant Subparts of this Annex or other applicable Annexes.
(b) The management system shall correspond to the size of the operator and the nature and complexity of its activities, taking into account the hazards and associated risks inherent in these activities.
Reference item (6) the role of Quality Assurance compliant with reg 965/2012 ORO Gen 200 is now considered solely as “compliance” & note that previously the role was somewhat more significant (the Compliance Manager is no longer “tasked” with ensuring the adequacy of procedures) – why? Well, partly it is due to the need for Post Holders to have definitive responsibility for their particular business areas.
JAR-OPS 1.035 Quality system (See AMC OPS 1.035 and IEM OPS 1.035) (a) An operator shall establish one Quality System and designate one Quality Manager to monitor compliance with, and the adequacy of, procedures required to ensure safe operational practices and airworthy aeroplanes. Compliance monitoring must include a feedback system to the Accountable Manager
Essentially whilst the pure “EASA” role of the Compliance Manager (CM) is diminished this in no way should limit the CM from either working with Post Holders (Nominated Persons – (NP) to provide performance-based guidance through joint endeavours. The Key element here being “joint” means that the Organisation and in particular the Accountable Manager should consider how they can best be served by the Compliance Manager (CM). Consider that EASA Compliance should be considered as a step on the journey and not the destination!
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