Misunderstanding & Confusion Related to EASA Approvals for Third Countries
Steve Bentley FRAeS CEO of Sofema Aviation Services (SAS) considers in depth a number of issues and challenges which are faced by the Industry
>> Due to various misunderstandings related to the need for regulatory training and
>> Obligations related to the management of competence.
Third Country Approved Organizations are responsible directly for the competence of all staff required to discharge EASA Regulatory obligations.
>> Whilst essential regulatory training can be outsourced the acceptance of this training remains with the organization.
>> How does your organization assess training and validate the competence of the workforce?
Note that Sofema Online provides free of charge guest access to assess our online training product which currently exceeds 300 courses. Please see the list of currently available courses
Regulatory Training Organizations are NOT approved by EASA!
This is a common misunderstanding, however, it is fundamental to the effectiveness of a Third Country Approved Organization.
Senior Persons from Third Country Organizations ask us quite often for evidence we hold direct approval from EASA - which of course does not exist. ( This is one more element of the overall problem)
>> It is essential that the leadership team (Accountable Manager (AM) Nominated Post Holder (NP) Compliance Manager (CM) and Safety Manager (SM) have a fundamental knowledge of the EASA Regulations related to the organizations' approval or proposed approval
EASA, 's role is to provide the various standards which are available as Implementing Rules (IR), Acceptable Means of Compliance (AMC), Certification Specifications (CS) and Guidance Material GM)
Whilst it may seem unfair it is not EASA's job to provide individual tuition to Industry. There is an expectation that the Industry will achieve and maintain the necessary competence to effectively manage their approval
Nominated Persons (NP) are responsible for Quality Control (QC)
Another misunderstanding is related to the role of the Compliance Manager (CM) – he/she has nothing to do with Quality Control this is the responsibility of the relevant NP. The CM must be independent and audit all elements and aspects of the organization for compliance with EASA Regulatory obligations.
Consider The Following:
>> If the CM identifies a non-conformity the first questions should be – why does the business area not know about this?
This means why was there a problem in the first place and why has the business area not self-identified?
>> If the Regulatory Inspector identifies a nonconformity – then the matter is quite serious as it has the potential to easily become a systemic failure where the internal system is not functioning correctly.
o The Regulatory Inspector should find very few nonconformities if the CM is doing his or her job in the correct way.
At Sofema we have been dealing with this challenge for almost 15 years and in the meantime provide training to over 100,000 delegates - some additional comments are shared here:
>> There are a number of misconceptions most are explained on Sofema FAQ
>> There is no Approval for example regarding the delivery of "non-Part 66" Regulatory, and Competence building 145 courses - HF/SMS/ EWIS/ FTS/ EGR / RVSM/ MMEL _ MEL etc.
Essentially it is the responsibility of the receiving organization to validate the training by either a) delivering the training itself or b) auditing the provider to ensure the training meets the organization`s objectives (EASA expects the AM & Leadership team to understand point 4 and act appropriately)
o To enable the organization to make this determination Sofema provides FOC guest enrollment for Client and Competent Authorities
>> Sofema Online is currently developing an area which we call Course Learning Objectives (CLO's) which provide details of the course curriculum - This is used to support the demonstration of specific course content for audit purposes
Please Note It is recommended for the Accountable Executive and Leadership team to be fully familiar with the EASA certification and Competence Management Process - please see attached EASA user guide which provides good guidance in this regard
Provision of Sofema Classroom & Online Training
Sofema Online - online courses are based on our classroom courses and most of the 145 related online courses include instructor voice over.
>> Sofema Recognizes some clients prefer an instructor led course and we have 30 Instructors (worldwide) typically all with a minimum of 20 years of practical relevant experience to support the delivery
Where do Regulatory Training Organizations' Receive their Approval?
The important note to take away - is that Sofema Works hard to be a qualified vendor - however - we are qualified by you the client rather than by EASA - our entire business model is focused on delivering regulatory-compliant training at the highest level - lowest cost. It is partly for this reason that we will during 2023 complete the enrollment of over 27,500 delegates
Client Questions Received by Sofema
Q/ Can I become an EASA Auditor as a member of an airline maintenance organization from a third country outside the EU?
A/ Auditors are not in anyway approved by EASA – Nor do they function independently. Auditors gain their approval from the organization (however they should ultimately be competent and acceptable to the Competent authority /EASA)
Q/ What are the specific qualifications to become an EASA Auditor?
A/ Visit the EASA website – download your own personal copy of EASY Access Rules and study the material – 90% + of questions are answered. Regulation EU 1321/2014 Easy Access Rules
Q/ What training is required to qualify as an EASA Auditor?
A/ example for 145 Approval see this document - Foreign Part-145 - Management Personnel - WI.CAO.00115-006 -this is for Quality Manager - Auditor is similar
Q/ Is the required training for EASA Auditor satisfied by 'SOFEMA Online'? How can I check that it is satisfied? I would like to see a certificate of designated from EASA for the training.
A/ Sofema Online Training Covers all the required Areas however it is important to understand that this is a journey.
>> Means you need engagement and practical experience - good auditors have years of practical experience - the auditor is not independently certified he works for the organization
Q/ If the training requirements for EASA Auditor are satisfied by 'SOFEMA Online', I would like to know the duration and cost of the training. Are all training courses available online?
A/ Please see the following course - with Instructor voice over
>> This package is available online - also available as webinar Please email team@sassofia.com for details of price and availability
Q/ How can I obtain the final EASA Auditor license? Is there a separate test and how does the test work?
A/ There is no such license - the organization manages the auditor and issues an internal approval based on competence and qualification
Ensuring the Effective Management of Delegate Competence related to completion of Online Training
>> Regarding Sofema Online courses - where there is a direct connection with the need to develop organizational competence in support of an EASA approval.
o We recommend that if the organization chooses (and EASA accepts) the delegate complete the online course with Instructor Voice over - and on completion sits the online exam under the supervision of the quality department.
Here you may see a list of available online courses
Here you may view ALL available classroom & instructor led webinar training
Next Steps
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Please consider the course lists for both Sofema Aviation Services and Sofema Online Once you identify the course or courses you would like we will provide a detailed offer with pleasure. If you have any additional comments or questions we will be pleased to provide guidance and support
