EASA Part 145 "Quality Assurance" Becomes "Compliance" with NPA 2019-05 (C) and a Part of the SMS
Comment by Steve Bentley CEO of www.sassofia.com
Quality Assurance is considered as a subset of SMS. Is this correct?
What does EASA Say?
These key safety management processes are supported by a compliance monitoring function as an integral part of the management system for safety.
Most aviation safety regulations constitute generic safety risk controls established by the ‘regulator’. Therefore, ensuring effective compliance with the regulations during daily operations and independent monitoring of compliance are fundamental to any management system for safety.
The compliance monitoring function may, in addition, support the follow-up of safety risk mitigation actions.
Moreover, where non-compliances are identified through internal audits, the causes will be thoroughly assessed and analysed.
Such an analysis in return supports the risk management process by providing insights into causal and contributing factors, including human factors, organisational factors and the environment in which the organisation operates.
In this way, the outputs of compliance monitoring become some of the various inputs to the safety risk management functions.
On the other hand, the safety risk management processes may be used to determine focus areas for compliance monitoring.
In this way, internal audits will inform the organisation’s management of the level of compliance within the organisation, whether safety risk mitigation actions have been implemented, and where corrective or preventive action is required.
The combination of safety risk management and compliance monitoring should lead to an enhanced understanding of the end-to-end process and the process interfaces, exposing opportunities for increased efficiencies, which are not limited to safety aspects.
As aviation is a complex system with many organisations and individuals interacting together, the primary focus of the key safety management processes is on the organisational processes and procedures, but it also relies on the humans in the system.
Authors Note - What EASA has done is undoubtably a positive by placing the focus firmly on the how & why of any given identified deficiency.
The process integrates the oversight activities and should drive real improvement by essentially drilling deeper into any issues which are found.
Consider that the business area owners/Post Holders or Nominated Persons are ultimately responsible however they are not alone and the business has an obligation to both enable and support them to deliver their organisational obligations.
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