Review regarding EASA Quality System by Sofema Aviation Services (SAS) www.sassofia.com
Introduction
In 1998 The Joint Aviation Authorities launched JAR OPS 1 (and “3”) contained within these documents was for the first time a specific requirement (JAR OPS Subpart B 1.035) for an independent audit function within the Operations Environment – With the transition to EASA Regulation 965/2012 a number of anomalies and miss conceptions where addressed. (Note 14 years elapsed time between the initial and “replacement” regulation.
The UAE Ops Regulation was fundamentally based on JAR OPS 1 however the process to adopt the EASA 965/2012 system is currently in transition with completion scheduled for 2023 – reference – CAR AIR OPS Final Implementation by 16 May 2023.
What is an EASA Quality System?
Essentially it consists of a method to deliver the organisations “product” under the control of nominated persons – this is a “Control of Quality” together with an independent function to assess compliance and this is known as “Quality Assurance”.
The problem is in simple terminology and it is all in a comma!
Considering the following sentences and the difference between the 2:
Version 1 Official – iii. Quality Manager. The manager, acceptable to the Authority, responsible for the management of the Quality System, monitoring function, and requesting corrective actions.
Version 2 Proposal iii. Quality Manager. The manager, acceptable to the Authority, responsible for the management of the Quality System monitoring function and requesting corrective actions.
In version 2 (which is not official the QM is responsible for the monitoring/oversight function whereas Version implies a different level of responsibility.)
There is a misconception in various “EASA centric” areas of the industry that the Quality Manager is responsible for the Entire Quality System – means the delivery of QC which is not true.
Making a Change
To lay the ground for an improved Quality Experience, EASA has re-identified the Quality Manager as the Compliance Manager (CM) – this subtle change is intended to focus on the true nature of the role of the QM within the EASA System.
Now consider the Role of the Post Holder – He is responsible for the Business Area to function in accordance with the regulatory obligations – This is Quality Control.
Now consider for every finding or nonconformity raised by the Quality Manager there is potentially a double finding.
1/ What is the Problem?
2/ Why did the business area not know it was a problem?
We compensate to a degree by requiring the PH (Business Area Owner) to determine the Root Cause – however ineffective determination of RC is a major disconnect in what could otherwise by an excellent system.
A further comment to consider if the CAA makes a finding – then we finish up with 3 issues:
1/ What is the Problem?
2/ Why did the business area not know it was a problem?
3/ Why has the Quality Audit System NOT identified the issue?
So a final comment is that:
Evidence of findings made by the CAA should be at a very low “interpretive” level and should not identify issues which carry significance – and this is a measure of an effective organisational system.
Next Steps
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Sofema Aviation Services (SAS) and Sofema Online (SOL) provide EASA Regulatory Compliant and Vocational training including more than 50 courses specifically related to Quality Assurance and Root Cause Analysis – Delivered as classroom, webinar, and online certificated courses – for details please see the websites www.sassofia.com & www.sofemaonline.com or email team@sassofia.com
Tags:
aviation, Aviation Quality Assurance, Aviation Quality System, Quality Assurance system, Quality Control, EASA Quality Systems, CAR-OPS, EASA 965/2012, SAS blogs, Joint Airworthiness Authority (JAA)
