Concerning Competence within an EASA Compliant Continuing Airworthiness Management Organisation (CAMO)

Sofema Online www.sofemaonline.com considers the process to manage competence following the transition from EASA Part M Subpart G Obligations to EASA Part CAMO Obligations

Introduction

EASA first identified a requirement to manage competence within the EASA Part M CAMO environment in February 2010 regulation 127/210 this was then updated with  Regulation (EU) 2015/1536 - see the following:

M.A.706 Personnel requirements (k) for complex motor-powered aircraft and for aircraft used by licensed air carriers in accordance with Regulation (EC) No 1008/2008, the organization shall establish and control the competence of personnel involved in the continuing airworthiness management, airworthiness review and/or quality audits in accordance with a procedure and to a standard agreed by the competent authority.

Important Note: This was actually a very poor piece of work by EASA and in no way represented an appropriate understanding of the criteria by which competence should be managed & whilst it placed a great deal of the responsibility on the Competent Authority - very few Competent Authorities actually issued guidance material which addressed the assessment of competence.

With the introduction of Part CAMO this issue has now been fully addressed.

EASA Part CAMO Competence Considerations  

AMC1 CAMO.A.305(g) Personnel requirements - Competency Assessment Objectives

The procedure referred to in point CAMO.A.305(g) should require amongst others that technical support personnel such as planners, engineers, and technical record staff, supervisors, post-holders, airworthiness review staff, whether employed or contracted, are assessed for competency before unsupervised work commences and competency is controlled on a continuous basis.

Competency should be assessed by the evaluation of:

a) On-the-job performance and/or testing of knowledge by appropriately qualified personnel;

b) Records for basic, organizational, and/or product type and differences training; and

c) Experience records.

Validation of the above could include a confirmation check with the organization (s) that issued such document(s).

For that purpose, experience/training may be recorded in a document such as a logbook.

As a result of this assessment, an individual’s qualification should determine:

a) Which level of ongoing supervision would be required and whether unsupervised work could be permitted;

b) Whether there is a need for additional training.

A record should be kept of each individual’s qualifications and competency assessment (refer also to point CAMO.A.220(c)).

This should include copies of all documents that attest to their qualifications, such as an authorization held, as applicable.

For a proper competency assessment of its personnel, the organization should consider the following:

(a) In accordance with the job function, adequate initial and recurrent training should be provided and recorded to ensure continued competency so that it is maintained throughout the duration of the employment/contract.

(b) All staff should be able to demonstrate knowledge of, and compliance with, the CAMO procedures, as applicable to their duties.

(c) All staff should be able to demonstrate an understanding of safety management principles including HF, related to their job function, and be trained as per AMC3 CAMO.A.305(g).

(d) To assist in the assessment of competency and to establish the training needs analysis, job descriptions are recommended for each job function in the organization. 

Note - Job descriptions should contain sufficient criteria to enable the required competency assessment.

(e) Criteria should allow the assessment to establish that, among other aspects (titles might be different in each organization):

(1) Managers are able to properly manage processes, resources and priorities described in their assigned duties, accountabilities and responsibilities in accordance with the safety policy and objectives and in compliance with the applicable requirements and procedures.

(2) Maintenance programme engineers are able to interpret source data (norms, data issued by the holder of a design approval or by the competent authority, etc.) and use them to develop the aircraft maintenance programme.

(3) Engineering staff is able to interpret source data (norms, data issued by the holder of a design approval or by the competent authority, etc.) and use them as needed (e.g. to make work cards).

(4) Planners are able to organize maintenance activities in an effective and timely manner.

(5) Compliance monitoring staff are able to monitor compliance with this Regulation and to identify non-compliances in an effective and timely manner so that the organization may remain in compliance with this Regulation.

(6) Staff who have been designated safety management responsibilities are familiar with the relevant processes in terms of hazard identification, risk management, and the monitoring of safety performance.

(7) All staff is familiar with the safety policy and the procedures and tools that can be used for internal safety reporting.

(f) The competency assessment should be based upon the procedure specified in GM1 CAMO.A.305(g).

 

AMC2 CAMO.A.305(g) Personnel requirements – Competency Assessment Procedure

(a) The organization should develop a procedure that describes the process for conducting a competency assessment of personnel. The procedure should specify:

(1) The persons who are responsible for this process

(2) When the assessment should take place

(3) How to give credit from previous assessments

(4) How to validate qualification records

(5) The means and methods to be used for the initial assessment

(6) The means and methods to be used for the continuous control of competency, including to gather feedback on the performance of personnel

(7) The aspects of competencies to be observed during the assessment in relation to each job function

(8) The actions to be taken if the assessment is not satisfactory

(9) How to record assessment results

(b) Competency may be assessed by having the person work under the supervision of another qualified person for a sufficient time to arrive at a conclusion.

Sufficient time could be as little as a few weeks if the person is fully exposed to relevant work.

The person need not be assessed against the complete spectrum of their intended duties.

If the person has been recruited from another approved CAMO, it is reasonable to accept written confirmation from the previous organization.

(c) All prospective continuing airworthiness management staff should be assessed for their competency related to their intended duties.

 

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