Just as important do Organisational Quality systems understand the role of 147 training organisations.
The is some concern in certain quarters regarding a shortfall in competence amongst senior aviation personal particularly persons who are nominated as post holders.
Lets clear the air!
1/ The Accountable Manager is not required to be an expert.
True – The accountable manager must be acceptable to the competent authority but is not required to be a specialist for example in Operations or Maintenance.
2/ The Quality Manager is not responsible for the Quality System.
True – The quality Manager is responsible for the Quality Assurance (compliance) system. However Quality Control (QC) is the direct responsibility of the relevant Post Holder.
3/Â The Safety Manager is not responsible for Safety.
True – the Safety Manager is responsible to enable, support, document and train safety but the actual responsibility sits again with the Post Holders.
4/ Organisational Training for FTS and EWIS must be conducted by a 147 organization.
False – in fact the only purpose a 147 organization is approved is to deliver both Basic and Type training to Part 66 Engineers.
The 145 organization is in fact responsible “itself” for a range of recurrent training obligations Including Human Factors, Fuel Tank Safety (FTS) Electrical Wiring Interconnect Systems (EWIS) Organisational Procedures, Safety Management System (SMS) and any other relevant training deemed necessary by the quality system.
A Competent Quality Assurance Manager will know that the most effective training will take full account of the organisations process and procedures and link to both the Quality and Safety Systems.
Therefore strength is in the management and control of the training content and delivery within the Quality System?
5/ Is it not better to use a 147 Organization for recurrent training?
Answer…..It is the responsibility of the 145 organization to assess the training needs, to evaluate and ensure appropriate training is delivered.
Having established that the 147 approval is only applicable to Part 66 staff there is no authority behind training for any other groups of staff – however some Quality Managers take comfort from this, in a way that some how alleviates their obligation to make an appropriate decision.
The bottom line is that 147 is a small part of the story (A competent Quality Manager will know this).
What is relevant is the following:
a) Does the training meet the organisations needs?
b) Is the training Content appropriate for the type of aircraft operated by the organization?
c) Does the training address the needs of all groups of staff for example Management, Planning, Quality and Stores Personnel?
d) Does the training identify the need for FTS and EWIS procedures to be specific and appropriate for the organization?
FACT Electrical Wiring is amongst the weakest of the aircraft systems today in respect of risk and exposure to events and consequences.
6/ Who is responsible to accept regulatory and other recurrent training?
Answer….. The quality manager based on an analysis of the organization needs and exposures.
To simply apply criteria that 147 is good everything else is bad shows a fundamental weakness and lack of understanding with the Quality Department.
7/ What is the Role of the Post Holders, Quality Manager and Safety Manager?
Answer….. Together the combined role of this group is to protect the Organization Directly and the Accountable Manager indirectly in respect of compliance with regulatory and organisational obligations.
8/ What does it mean when the regulator finds a problem with our organization?
Answer….. It may be that in fact there are two findings
a) There is a problem with organization compliance in respect of a regulatory obligation
b) That there is a weakness within the Quality System as all deficiencies should be noted within the Quality Audit System of the organization.
To discover that there is a problem from an external source often indicates an additional problem within the oversight of the organization.
Sofema Aviation Services delivers training to the highest standards – We train industry and we train regulators.
Last Year SAS delivered regulatory and vocational training to more than 1500 delegates.
For details of available training courses please see www.sassofia.com or email office@sassofia.com
Tags:
Accountable Manager, aviation services, EWIS, FTS, Organisational Quality systems, Part 147, Post Holder, Quality Assurance, Quality Manager, Regulatory training, Safety Manager
