Sofema Aviation Services (SAS) www.sassofia.com considers the EASA Root Cause Requirements and best practices to address EASA Findings. How to provide an acceptable response and how to address such findings so they are fully mitigated.
Here is an Example Finding for Discussion and Comment
Regulatory Paragraphs 145.A.30 (e)
Finding Description –The Organisation cannot demonstrate compliance with 145.A.30 (e) with regards to Control of staff competency/Control of staff understanding of safety management principles and human factors
Related evidence(s) description
There is no evidence that all staff involved in the EASA processes received the training in safety management principles and human factors as per the syllabus required by EASA 145.A.30(e). |
The organization cannot provide evidence that all staff involved in the EASA-related repair processes are appropriately trained and competence assessed regarding their responsibilities and function (described in the MOE).
Organisation Response – Root Cause
ORG. did not understand the requirement enough.
SAS Note regarding Root Cause
Simple answers are not usually acceptable by authorities – even if they are damaging to the organisation’s business case because they show a lack of understanding related to roles and responsibilities.
Let’s consider the following elements before returning to the root cause.
- The regulatory requirements are enunciated – so to state that you did not understand begs the question of why (means ORG. did not understand the requirement enough is a contributing factor, not a root cause)
- Why did the organisation NOT understand the requirement? Takes you closer to the root cause
- To reach the root cause answer the following.
- Who is responsible for ensuring that the requirement is met? (note two aspects – Business Area ownership – plus independent assessment)
- So for both the business area and the independent compliance area – to both misunderstand – implies a systemic shortfall related to the level of engagement of the business with the need to satisfy the regulatory requirements
- The cause is possible closer to the following.
o The Org failed to provide sufficient trained & competent resources to manage the administrative and training obligations to satisfy the regulatory requirement and documentation requirements necessary to meet the approval requirements.
Note – There is still a possible deeper question to again ask why? (however, a serious recognition of a shortfall is a step in the right direction)
Org accepts the finding and advises the following corrective action.
- The safety management and human factors training will be completed for mechanics involved in the EASA processes through in-house personnel.
SAS Important Note – A corrective action is something you have done not intend to do – plus proposing a training does not ensure a level of engagement.
Lets consider again the finding
Finding Description –The Organisation cannot demonstrate compliance with 145.A.30 (e) with regards to Control of staff competency/Control of staff understanding of safety management principles and human factors
SAS Comment Org needs to be able to demonstrate.
- Staff Competency – includes ALL staff involved – Mechanics – certifying staff – logistics – managers – quality & safety managers.
- Completion of required training (including internal process and procedure training)
- A review process to demonstrate that the staff understand the roles and responsibilities including safety which has been documented within the management system.
o Examples include interviews / surveys / Examinations
Additional comment by the ORG – we have reviewed the EASA Part 145 requirement again!
SAS Comment – Raises the challenge of demonstrating the organisation at every level complies with the EASA regulatory requirement – this is more than a review it is necessary for a detailed understanding to be demonstrated by key staff. Specifically, Business Owners, Quality & Safety
SAS Additional Note oversimplification of answers typically makes regulatory authorities nervous and motivated to look further and deeper.
Demonstrating Full Understanding of an Issue – Recognising all Root Causes together with Contributing Factors and providing appropriate mitigations for each one are essential – Finally documenting all aspects of the process and providing evidence of all steps will help to satisfy the authorities regarding rectification of the shortfall.
Next Steps
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Sofema Aviation Services (SAS) www.sassofia.com – provides regulatory training and consultancy for EASA Part 145 organisations – please see the website or email team@sassofia.com
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145 organisations, SAS blogs, Quality & Safety, SAS Library, Third Country 145, EASA Root Cause, Root Cause Requirements, EASA Findings, EASA 145.A., regulatory requirement, Business Owners
