Steve Bentley CEO of Sofema Aviation Services www.sassofia.com looks at common errors made by MRO’s in allocating responsibilities for process & procedures – compounded by the weakness of regulatory auditors to identify such.
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145.121 Maintenance procedures and quality system
(a) The organisation shall establish a safety and quality policy for the organisation which shall be included in the organisation’s exposition.
(b) The organisation shall establish procedures acceptable to the Governor taking into account human factors and human performance to ensure good maintenance practices and compliance with all relevant requirements that shall include:
(1) a clear work order or contract; and
(2) that aircraft shall be released to service in accordance with paragraph 145.115.
(c) The organisation shall establish procedures, as appropriate, for the issue of a Special Flight Permit Release Certificate (SFPRC) to support Special Flight Permits issued by the Governor.
(d) The organisation shall establish a quality system that includes independent audits with associated feedback systems in order to monitor:
(1) compliance with required aircraft maintenance standards; and
(2) the adequacy of the maintenance procedures to ensure that such procedures invoke good maintenance practices.
(e) The organisation shall have a quality feedback reporting system to the person or group of persons specified in paragraph 145.105(a) and ultimately to the accountable manager.
(f) The organisation shall ensure proper and timely corrective action is taken in response to reports resulting from the independent audits;
Example Extract from Approved OTAR MOE
Quality Manager – responsibilities
He is responsible to the Accountable Manager for the effective management of the Quality Activities so that contractual obligations are satisfied, company targets met, and all works are accomplished in compliance with regulatory requirements and the policies detailed in this manual.
Authors Comment
How to be responsible & independent? (whenever there are role disparities within an organisation – there is a tendency for disconnects to occur)
Note: Post Holders / Business Area Owners should be directly responsible for process & procedure – this is QC – The Quality Manager delivers independent oversite – QA!
A better term to use would be to say “he is responsible to the Accountable Manager for the effective oversight of Quality Control Activities and directly responsible for the effective delivery of Quality Assurance activities to ensure the organisation remains fully compliant”
The Quality Manager has direct access to the Accountable Manager in the event of any reported discrepancy not being adequately attended to by the relevant person, or in respect of any disagreement over the nature of a discrepancy.
(Yes correct)
Duties and responsibilities include:
1) Establishing and monitoring of Part 145 independent Quality assurance system, including the associated feedback system, to monitor compliance of the Part 145 organisation with EASA requirements;
(Yes correct)
2) Preparing standard practices and procedures (M.O.E., including the associated procedure(s) for use within the organisation and ensuring their adequacy regarding Part 145 and any amendments to the Regulation;
As soon as you make the Quality Manager Responsible for procedures – you remove the layer of protection – means the QM is now no longer independent, he is owning the procedures.
3) Establishing procedures acceptable to OTAA/BCAA to ensure approved maintenance practices and compliance with all relevant requirements of valid Part 145 Approval, which must include a clear detailed explanation of the working order or contractual relations so that Aircraft or Aircraft components may be released to service in accordance with Part 145.115;
Note: OTAR requirements place the burden on the Organisation by transferring the requirement to the Quality Manager – the system immediately weakens.
(d) The organisation shall establish a quality system that includes independent audits with associated feedback systems in order to monitor:
(1) compliance with required aircraft maintenance standards; and
(2) the adequacy of the maintenance procedures to ensure that such procedures invoke good maintenance practices.
Final Comments
The Strongest Systems focus on competent business area Ownership* and Management to own and deliver all Production Elements – (QC) together with an effective independent process to determine ongoing compliance (QA).
Note: Ownership means full responsibility for the effectiveness of the process & procedures.
Consider that any internal audit finding is a “chink” in the armour of the organisation – simply put how did the business area owner become exposed.
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Tags:
Aviation Quality System, OTAR, Part 145, Quality Assurance, Quality Control
