Compliance Auditing of 3rd Party Organisation’s QC Management - Operations / Maintenance
Sofema Aviation Services www.sassofia.com looks at the challenges of using Compliance Audit Techniques to determine the effectiveness of a “supplier”
What do we Mean by Third Party when we talk about auditing?
Means that the organisation is “Stand Alone” or “Stand Apart”. So effectively we are connected to the Organisation for business purposes, however, we cannot exert direct control.
This is an important consideration because in some cases the where the relationship is sub-contractual the “Contracting Organisation” is held accountable for the diligence and acceptable delivery including standards, management oversight and the effective control of competence.
A typical example would be the relationship between the Operator & the Ground Handling organisation (although to not some improvements are coming in this regard – ref. Basic Regulation EC2018/1139).
The Operator bears the final responsibility for the loading of Pax / Fuel / Cargo / Baggage etc. and not the Ground Service Provider (GSP).
Delivering Effective Oversight of the Maintenance Organisation
Another example would be the relationship between the Operators Continuing Airworthiness Management Organisation (CAMO) and the Maintenance Repair Organisation (MRO).
The relationship between the CAMO and MRO is of significant importance when we look at the need to ensure a reliable and airworthy product. Additionally, there are multiple variations which need to be considered related to the management and control of the work package
The starting point is often the contract – to understand in details what the various obligations are.
Always Consider!
When we audit it is against a standard – means there is a specification which we are using as a reference point – and we are making a “gap analysis” using our knowledge & judgement.
What is the Difference between Compliance & Effectiveness?
Compliance
Well, when we talk about “Compliance” we are of course referring to either compliance with the regulatory requirements or compliance with the Organisations own Internal Procedures.
Now consider that this is actually a prescriptive measure – means that there is a document expectation which we need to demonstrate compliance with.
Effectiveness
When we talk on the other hand about “Effectiveness” we are again moving into an area of subjectivity and we need to develop “Standards” by which we can measure this “subjective” effectiveness against.
For Example Organisation “A” delivers 100 Hours of Aircraft Maintenance tasks (Derived from the MPD) using an average of 250 physical hours of Labour. Organisation “B” on the other hand takes an average of 375 Hours to deliver the same task. (100 Hours difference between A & B Organisations)
This does not mean that Organisation “B” workers are necessarily slower – but for sure there is a reason or range of reasons for this situation.
Further Steps to Evaluate
How can we build up a more detailed understanding related to the reasons behind the additional time taken?
Consider the following core 145 Elements and look at how the organisation is managing each of the elements.
A good aspect to consider for each is the following:
a) Where is the requirement?
b) How is it translated into the physical requirement of the Organisation?
c) How effective is the delivery?
d) How is the organisation measuring this? (Note QA should normally be independent as we are talking about a QC role)
The following Areas are key!
Manpower & Training
Facilities & Equipment
Documentation including Process & Procedures
Tooling
Competence
Internal Quality Assurance Assessment
Consider the potential impact on our Organisation of the Third Party Activities?
Well, it is fair to say the service degradation will have direct consequences and can affect our profitability. So engaging with Measures of Effectiveness can indeed lead to positive outcomes.
Sofema Aviation Services www.sassofia.com & SofemaOnline www.sofemaonline.com offers additional EASA, GCAA & FAA compliant regulatory and vocational online training including Quality Auditing. For details please see the website or email office@sassofia.com or online@sassofia.com
