A discussion document by Steven Bentley MD of Sofema Aviation Services – Steven has more than 45 years experience in commercial aviation and has been delivering EASA and GCAA UAE compliant regulatory for the last 8 years.
Our organisation’s Quality Assurance auditors are presented with the dual challenge of auditing the management of the competency of the Stores Inspection Staff together with ensuring the organisational standards by which we are auditing the stores process are clearly defined.
This document considers several of the challenges we face in ensuring the strongest possible Stores Inspection process within our organisation.
Quality Auditing as we are aware is the independent assessment of the organisation against both the regulatory requirements (external obligations) and the organisations own requirements (internal obligations)
We should ensure that the Stores Inspector has a detailed understanding of the role of PMA & Fabrication of Parts within our organisation – what are we allowed to fabricate and where is the information found.
It is important that the Stores Inspector has a clear understanding of the regulatory environment to understand what should accompany the material and how we should deal with certificates of Compliance and where they are acceptable.
One challenge presented occurs when an organisation assumes mistakenly that the regulatory compliance is the ultimate goal – when in actual fact it is the minimum goal.
To explain further:
There are a number of gaps in the EASA system which we have to recognise and to ensure compensation. EASA is not strong at consolidating information between Implementing rules IR, Certification Specification CS, AMC material and the various annexes and other guidance material which is available.
Consider the FAA Suspect Parts Program
There is no direct EASA equivalent but nevertheless we should have an in depth knowledge.
a) Are we as auditors familiar with the FAA Suspect Parts – how the process works and how it is managed within our organisation?
Regarding acceptance of parts in accordance with the various agreements, it is necessary for the stores inspector to be familiar with the EASA / FAA Maintenance Annex Guidance MAG.
b) Are we as auditors familiar with the MAG do we know the equivalent documents for Transport Canada and for Brazil?
Receipt Documentation – For example EASA Form 1 or FAA 8130-3 are a means of communicating information, and it is incumbent on the receiving inspector to be familiar and accepting of the source, is the Inspector familiar with terms such as TSO / ETSO PMA / EPA.
c) Are we as auditors familiar with the above terms – what do these terms mean and what are we as an organisation permitted to use?
What is the role of Part 21 Subpart J, Part 21 Subpart G and Part 21 Subpart F organisations – Where can we use a part which has been certified in accordance with Part 21 Subpart F – what happens if a subcontract organisation to a Part 21 Subpart G organisation manufactures parts – where is the legitimacy.
d) Certification is of major importance to ensure only the correct parts are accepted into the system – Are we as auditors satisfied with the internal organisation process to ensure the competence of anyone responsible to verify incoming source documentation.
A challenging area found during audits is related to Shelf life – the Stores Inspector should understand where the information regarding shelf life may be found – Whilst sometimes it is found in the CMM there is other generic industry standards which have been developed.
e) Where may we find shelf life additional information and how is this managed in the organisation system? Is this information part of the competency management process for Stores Inspectors
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