To start by saying that I firmly believe the concept of the management system as required by EASA actually delivers a working methodology which not only complies with the intent of ICAO but does so in a practical way.
EASA recognizes the roles and responsibilities within the management team, clearly identifying that the responsibility of both QC and Safety sits ultimately with the Post Holder. One of the problems industry faces is that this is not always recognized by the Post Holder himself, (try asking the Post Holder how he delivers SMS within his business area), you will see that often part of the problem is a fundamental lack of understanding concerning roles and responsibilities within the organization, it is early days this needs to change as does the effectiveness of the regulatory oversight which is often weak. – For example the Helios tragedy !
It seems there are as many opinion’s as there are contributor’s, I try to focus on both the rational behind the regulations (EASA) and recommended practices (ICAO). I also try to be pragmatic and to view things in the most direct way. (In doing so I try as a regulatory trainer to deliver an understanding that sits comfortably with all organizational stakeholders.)
Maybe to agree a few common understanding and to clarify some misconceptions.
Quality Assurance is looking either currently or “rearward” whereas Safety is looking into the future, as such Safety is subjective and requires a specific understanding supported by assessor competence to determine Risk and Exposure.
For example Safety is not so much an inspection to see that nothing is at variance with our expectation, rather an understanding that the organization has the capacity and competence to deliver process and procedure in the most effective way.
We see Quality & Safety as independent functions within the organization although the closer the integrated relationship within the “management system” the better. Use Quality Findings as a starting point for Risk assessment & use Safety perceptions as a precursor to performing Quality Audits.
Performance Auditing is different of course is (may be part of the improvement process) in a potentially more significant way – see six sigma etc. One of the reasons that EASA has rebranded the Quality Manager as the “Compliance Manager” is to clearly identify this (compliance) role as the predominant role.
When I started in Aviation in the 1970’s Quality typically consisted of Quality Control, in addition Safety was present as a “personal” rather than an Organizational obligation. 40 years later we have a very different environment within the organization, an environment which is focused on Safety in a way it never was in the past.
Quality Assurance really got going in Europe first in the “Maintenance Environment” with the introduction of JAR 145 and later within “Operations” following the introduction of JAR OPS.
ICAO Annex 19 identifies Safety risk assessment and mitigation in the following way – The service provider shall develop and maintain a process that ensures analysis, assessment and control of the safety risks associated with identified hazards. (ICAO Annex 19 App 2 – 2.1)
Whenever we see safety related criteria it always contains the word “RISK” in some way, whereas when we see Quality related criteria we are looking at “Compliance”.
So Quality Auditing is not Safety Auditing and if you are measuring actual against a documented expectation, you are looking at “compliance” (yes we can perform compliance audits of Safety Environments.)
Many people talk about Safety Auditing and then describe a compliance audit, it is interesting to ask people the difference between quality and safety auditing, when in actual fact from an EASA perspective it is quite straightforward – compliance versus risk & exposure.
If we agree with the above, Safety Auditing then has to be performed in a way which is different, from compliance auditing my contention and understanding in Compliance is directly associated with the rules which impact the organization, Safety Auditing concerns the ongoing ability to continue to be able to follow these rules under a range of potential scenarios (identify – assess and manage risk).
The traditional safety strategies relied on outcomes from the understanding regarding conditions and causes of an accident based either on the specific analysis or as a result of investigation of individual past accidents.
A Proactive Aviation Safety System also requires a risk management strategy based on identification, analysis of hazards and application of a mitigation process to deliver remedial controls with the environment of a systems-based approach.
This needs to be supported by an effective Quality Assurance System delivering compliance at an effective level.
Tags:
Annex 19, Aviation Quality, EASA, European Environment, ICAO, Post Holder, Quality Assurance, Quality Audits, Risk and Exposure, Risk Assessment, Safety, Safety Auditing
