How to Ensure the Independence of Audits within an EASA Part 147 Organization

How to Ensure the Independence of Audits within an EASA Part 147 Organization

When we talk about the Quality System we are off course considering both the function of QA & QC.
 
The QA audit process must be independent which means the auditor is not involved in the day to deliver delivery of training or management of processes.

It should also be understood that the audits do not replace the need for ongoing Quality Control (QC) activities.

The audits which we will carry out are considered as “compliance audits” and essentially follow a prescriptive checklist ensuring that all elements of the process are delivering in accordance with both the regulatory and organizational requirements.

A QC Function should also exist to ensure that the instructors are delivering training to the required standard. Such “Process” once documented and implemented are also subject to periodic QA audit.

Audit reports will be produced for every audit and if necessary corrective actions will be raised to identify any discrepancies. It is important that all discrepancies are accepted by the relevant post holder and that the time to rectify the defect is mutually agreed between the auditor and the auditee.

The Accountable Manager (AM) is to be kept aware of all audit findings so that he is able to monitor compliance as appropriate. It is not acceptable to contract this follow up process to outside persons it must be the AM and other responsible Post Holders (PH) / Nominated Persons (NP) who are actively aware of the status of any outstanding discrepancies.

It is expected that there will be active involvement of the AM with regular meets being held between the AM and the various stake holders within the organization to check on the progress of the rectification.
The Quality Audit System is scalable means that for a larger organization more audits will be assigned to the various business areas.

In the case of audits that are carried out by the Competent Authority (CA) any findings identified will be categorized as either level 1 or level 2.

On receipt of the finding the MTO must define an acceptable corrective action plan and demonstrate corrective action to the satisfaction of the competent authority within an agreed period, after receipt of notification of findings according to 147.B.130.

Failure to complete rectification of level 1 findings within three days of written notification shall entail revocation, suspension or limitation by the competent authority, of the MTO approval in whole or in part.

It is of critical importance to ensure that all findings are actioned within the time scale granted by the competent authority, in the case of level 2 findings, the competent authority may give 6 months notice of the need for rectification or less, dependent upon the seriousness of the finding. When 6 months are allowed, initial notification = 3 months to the quality manager followed by the final 3 months notice to the accountable manager.

Action shall be taken by the competent authority to revoke, limit or suspend in whole or part the approval in case of failure to comply within the time scale granted by the competent authority in the case of a level 2 finding.

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