Consider the following role definitions and responsibilities :- First that the Accountable Manager is responsible for the Quality System which includes both elements of Quality Control and Quality Assurance; Second The Quality Assurance Manager is responsible for the auditing of all Compliance related elements of the organization system.
When we speak about Organisational Compliance we are talking about compliance with all external regulatory requirements together with the internal obligations driven by all “internal” company documentation, manuals and procedures.
The Quality Manager is required to head up the independent process for performing gap analysis (auditing for conformity) of the organisations documentation systems and processes. Any finding becomes a “discrepancy” and generates the need for “corrective action”.
Quality Control is the responsibility of the individual post holders and business area owners. Quality Control is delivered through the development of regulatory compliant organisational procedures which are followed by suitably trained and competent organisational staff. Independently all QC processes should be audited by the QA process.
The organization has an inherent obligation to ensure compliance and this is further enfranchised by the obligation of the Accountable Manager “AM” to sign a statement accepting responsibility for the organization to remain in compliance with all mentioned requirements.
The Accountable Manager is not required to be a specialist in the way that the Post Holders are required to demonstrate specific background knowledge experience and competence to the regulator before being allowed to commence “Post Holder” Duties.
So we should share the understanding that one of the roles of the Post Holder is to protect the Accountable Manager by ensure that all required compliance’s are satisfied in respect of the relevant business area. Moreover any identified deficiencies are brought to the attention of the Accountable manager in the most appropriate way, if necessary with the support of the Quality and Safety Manager.
The regulatory authority will perform “oversight” audits of the organization, it should be understood that the purpose of these audits is entirely different to the needs of the organization.
The regulatory authority is not part of the organisations QC or QA process and independently assesses what they wish when they wish. It should be said that lack of awareness not identified by the regulatory does not exonerate the organization anyway from compliance.
It is a fact that anything omitted in terms of oversight by the regulator due to time manpower or other constraints will not be missed by agencies such as the National Transportation Safety Board NTSB or Aircraft Accident Investigation Board AAIB.
The Quality Manager is also responsible to “Protect” the Accountable Manager by ensuring that all significant organisational non conformity’s are brought to the attention of the AM.
Once we accept the above we can focus on the importance of the QM.
To finish with two comments.
The first is that if the QM fails to identify organization non conformity he has let down the AM.
The second is that if the regulatory finds an organizational deficiency it is possibly an indication of two deficiencies – The first is that the organization has been identified as non compliant, and the second is that apparently the independent Quality Audit system has failed to identify the shortfall indication a potential weakness within the organisations oversight system.
Suffice to say an effective aviation quality and compliance system should generate few if any non conformity’s during regulatory audits.
Steven Bentley, the author of this Blog, is MD of Sofema Aviation Services www.sassofia.com. If you would like details of available Quality Audit and Compliance training courses please visit the web site or email office@sassofia.com
