Considerations Related to the Assessment of Effective EASA Organisational Compliance

With the exception of EASA Part 21 Subpart J "Design Organisation Approval" which as will be aware is managed directly by EASA the process for all other approvals (Air Carrier – Part 145 / Part M / Part 147 / Part 21 Subpart G POE / ATO) essentially works as follows

Achieving Regulatory Approval (Simplified)

1/ The organisation demonstrates to the Competent Authority (CA) that they satisfy the pre-requisites to be granted the requested approval

Documentation / Facilities / Manpower / Competence / Finance / Oversight

2/ The Accountable Manager of the Approved Organisation signs a statement to confirm his or her responsibility related to ensure sufficient finance is available to maintain full compliance

3/ The Organisation must set up a process (Independent Quality Assurance) to ensure continuous compliance

4/ The CA periodically assess the organisation for continuous compliance and raises findings for any non – compliance (Level 1 or 2 as appropriate)

Challenges related to the Effective Assessment of a given organisation

1/ When we consider compliance audits whilst it may be satisfactory the reality is that it is an unknown if the compliance will be satisfactory next week or next month. 

2/ A shortfall of the compliance audit is that it does not always test either the process or procedures which are developed to deliver the requirement. (As a result some assumption is typically made on behalf of the auditor.) Whilst often this does not become an issue it remains a weakness.

3/ Compliance Auditing can be misleading depending on the depth of the audit (deeper audits take more time)

4/ When there is a limited time available we should maximise the effectiveness of the criteria – how to do this

       a) Focus on the ability of the organisation to assess it self so an audit which focuses on the quality system 70% - 80% and physical business area audit 20% - 30%.

       b) Use the audit of the Quality Assurance System to understand how effective is the organisations External / Internal audit process

5/ Who is performing the internal audit? / what is their audit competence – how is this evidenced?

6/ What is the audit standard which is being assessed – how is it documented? / how deep is the assessment?

Consider the following statement

          i/ The organisation shall have a process to ensure training is provided in respect of XYZ

Audit finding – the process exists therefore it is acceptable

Now consider a different scenario

          ii/ The organisation shall have a process to ensure training is provided in respect of XYZ

Comments related to the above - When asked to demonstrate how they were measuring the effectiveness of the training – the organisation was not able to provide an adequate response.

Whilst people are receiving training, the relevant question is does it meet both the objectives and specific need of the organisation (How is this evidenced)

 Real Life Example of A Shortfall

 A Group of 20 staff who had completed an internal SMS course where not able to explain the difference between a hazard and a risk – when pressed it was quickly established that there was much confusion

 As a result this group had essentially received “tick the box” training and the company passes the audit – but is it OK ?.......clearly not !

 Taking Steps to improve our Audit Engagement Process

 What should we look for in addition to our basic Competence Assessment -  So in general an audit oversight process that looks deeper at the following will be more effective.

        a) How the process is being managed – Means who is managing it and are they training and competent for the task – How is this evidenced?

        b) How the effectiveness of the process is being assessed – Who is measuring the effectiveness of the process & what is the measure employed – Is it successful.

        c) How the assessment process is documented – Where is it document – Consistent Processes need to be written down so that they are understood and shared by all.

       d) Where is the physical evidence that assessment has taken place?

       e) Are there examples where a shortfall in the process has been identified and how a corrective action was initiated which is shown to be successful

 Sofema Aviation Services www.sassofia.com (SAS) and our partner SofemaOnline www.sofemaonline.com (SOL) offer both classroom based and online regulatory training course compliant with EASA Regulations.  For additional details please see the websites or email office@sassofia.com or online@sassofia.com