Sofema Online (SOL) www.sofemaonline.com Considers the challenge of miss-interpretation of EASA Regs regarding Roles and Responsibilities.
Comment by Steve Bentley – CEO of Sofema with 50 Years of relevant commercial aviation experience: “Every time we are asked to provide evidence of an EASA 147 approval as a pre-requisite to enable or support the delivery of 145 HF training or other (example EWIS / FTS) (happens about 5 times each year – & Note in 2021 we had over 17,000 enrollments) it creates a moment of reflection – why?
Because it is Not Correct!
Either the approved QM or TM of the asking organisation does not understand the regulations (Usual) or the Regulatory Authority Miss understands (Rare)
To Clear the Air – Who is Responsible to Manage Competence in an EASA 145 Organisation?
Reference The Following Implementing Rule – 145.A.30 Personnel requirements – Regulation (EU) No 1321/2014 – Regulation (EU) 2020/270
(e) The organisation shall establish and control the competence of personnel involved in any maintenance, airworthiness reviews, management, and/or quality audits in accordance with a procedure and to a standard agreed by the competent authority.
In addition to the necessary expertise related to the job function, competence must include an understanding of the application of human factors and human performance issues appropriate to that person’s function in the organisation. ‘Human factors’ means principles which apply to aeronautical design, certification, training, operations, and maintenance and which seek a safe interface between the human and other system components by proper consideration of human performance. ‘Human performance’ means human capabilities and limitations which have an impact on the safety and efficiency of aeronautical operations.
So let’s be clear – it is 100% the responsibility of the organisation to “manage” the competence of its workforce.
Important Note – this means the 145 organisation is responsible to validate any externally provided training – This is exactly the reason why Sofema Online provides Guest Enrollments to our courses.
Please review the following – What is the relationship between Part 147 Organisations and any Regulatory Training Obligations?
One of the most frequent questions we (Sofema) are asked concerns the relationship between EASA Regulatory Training and 147 approval.
Typically, this relates to the fundamental misunderstanding regarding the role of an EASA 147 approval.
- Please Note – EASA Part 147 is NOT in any way a generic training approval, it is only for providing BASIC and TYPE training to PART 66 Licensed aircraft engineers and for no other purpose.
Note – Both SAS & SOL receives their regulatory training course acceptance from the receiving organisation.
- Based on a range of acceptance criteria including the continuous demonstration of effective delivery.”
Further Guidance – please read Our Blog: EASA Part of the Solution or Part of the Problem?
Detailed Consideration of 145.A.35 Certifying staff and support staff
(d) The organisation shall ensure that all certifying staff and support staff receive sufficient continuation training in each two-year period to ensure that such staff has up-to-date knowledge of relevant technology, organisation procedures, and human factor issues. (Regulation (EU) No 1321/2014)
AMC 145.A.35(d) Certifying staff and support staff (ED Decision 2015/029/R)
1. Continuation training is a two-way process to ensure that certifying staff remains current in terms of procedures, human factors, and technical knowledge and that the organisation receives feedback on the adequacy of its procedures and maintenance instructions.
- Due to the interactive nature of this training, consideration should be given to the possibility that such training has the involvement of the quality department to ensure that feedback is actioned.
- Alternatively, there should be a procedure to ensure that feedback is formally passed from the training department to the quality department to initiate action.
2. Continuation training should cover changes in relevant requirements such as Part-145, changes in organisation procedures, and the modification standard of the products being maintained plus human factor issues identified from any internal or external analysis of incidents.
- It should also address instances where staff failed to follow procedures and the reasons why particular procedures are not always followed. In many cases, the continuation training will reinforce the need to follow procedures and ensure that incomplete or incorrect procedures are identified to the company in order that they can be corrected.
- This does not preclude the possible need to carry out a quality audit of such procedures.
3. Continuation training should be of sufficient duration in each 2 year period to meet the intent of 145.A.35(d) and may be split into a number of separate elements.
- 145.A.35(d) requires such training to keep certifying staff updated in terms of relevant technology, procedures, and human factors issues which means it is one part of ensuring quality. Therefore sufficient duration should be related to relevant quality audit findings and other internal / external sources of information available to the organisation on human errors in maintenance.
- This means that in the case of an organisation that maintains aircraft with few relevant quality audit findings, continuation training could be limited to days rather than weeks, whereas a similar organisation with a number of relevant quality audit findings, such training may take several weeks.
- For an organisation that maintains aircraft components, the duration of continuation training would follow the same philosophy but should be scaled down to reflect the more limited nature of the activity.
- For example, certifying staff who release hydraulic pumps may only require a few hours of continuation training whereas those who release turbine engines may only require a few days of such training. The content of continuation training should be related to relevant quality audit findings and it is recommended that such training is reviewed at least once every 24 month period.
4. The method of training is intended to be a flexible process and could, for example, include:
- A Part-147 continuation training course,
- Aeronautical college courses,
- Internal short-duration courses, seminars, etc.
- The elements, general content, and length of such training should be specified in the maintenance organisation exposition unless such training is undertaken by an organisation approved under Part-147 when such details may be specified under the approval and cross-referenced in the maintenance organisation exposition.
Note Concerning Point 4 above:
There is nothing implied here that says in any way that it is a requirement for a 147 organisation to be a required part of the process – simply it is an option – regardless of whatever training is ultimately chosen – nothing takes away from the responsibility of the 145 organisation to manage the competence of its employees and the acceptability of any provided external training to meet the 145 organisations objectives.
About Sofema Aviation Services & Sofema Online
Since 2008 we have delivered regulatory compliant and vocational training to more than 50,000 clients. Currently, we offer over 550 different courses and continue to develop specific material to meet our clients’ objectives – please see www.sassofia.com & www.sofemaonline.com or email firstname.lastname@example.org for further details.
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