Aircraft Continuing Airworthiness Monitoring Requirements ACAM Operator Roles & Responsibilities related to QMS (Quality Control (QC) & Quality Assurance (QA)
Considering the Fundamental EASA QA/ QC Relationship
The Quality Manager (Compliance Manager) is responsible for the independent assessment of compliance – not to loose sight that this process is additional and should be considered as a Safety Net rather than a primary method of ensuring compliance.
The Continuing Airworthiness Manager (CAM) is responsible for the QC Activities related to the compliances which are validated during the ACAM process.
Building on this understanding means that an effective oversight of an effective process will focus on the physical management, delivery and maintenance of competence within the system of control.
The Regulatory Point of View
When we consider the effectiveness of the fundamental aspects of the EASA Continuing Airworthiness Regulatory system, we understand that the integrity of the system depends on a chain of responsibilities and oversight activities:
a) The Quality System of the Organisation (Means QA & QC activities).
b) The Oversight performed by the competent authority issuing the organisation approval.
c) Airworthiness Reviews performed on the aircraft for the renewal of the Airworthiness Review Certificate (keep the CofA valid).
d) The ACAM (Aircraft Continuing Airworthiness Monitoring) programme of the State of Registry.
The recommendation driven by EASA is to engage with a Risk based approach – partly this is of course related to the time constraints regarding the availability of manpower to perform in depth auditing which is very time consuming. Regulation EC 1536/2015 (applicable on 25 August 2016)
By focusing on a risk-based approach it becomes possible to cover all the airworthiness key risk elements during the sample product surveys of aircraft.
The Regulatory Authority is expected to have a process in place to analyse findings for their safety significance. Included in this process is a product survey which involves a physical inspection during each ACAM Survey.
Product survey includes the need to perform a physical inspection during each ACAM survey.
Key Risk Elements
With the Introduction of 13 Key Risk Elements (KREs) a unified approach is available which will permit consistency across the member states.
These 13 KREs are grouped in 3 categories: aircraft - configuration, operation and maintenance.
To be used effectively the KRE need to be adapted to the complexity of the aircraft type being surveyed and guidance has been provided.
To Ensure an Effective Oversight Process
Devote time to understanding how the organisation is managing a particular element with the following elements being applicable.
1) What is the standard / requirement?
2) How is it documented?
3) What is your QC process to ensure effective delivery?
4) Where is the evidence that the QC process has been performed?
With the above information understood it is then relatively straightforward to validate sufficient data to be satisfied regarding compliance.
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