UAE GCAA - CAR 1.035 Quality System Considerations
Steve Bentley MD of Sofema Aviation Services (www.sassofia.com) takes a look at the Flight Ops Quality System
Introduction
In 1998 The Joint Aviation Authorities launched JAR OPS 1 (and “3”) contained within the document was for the first time a specific requirement (JAR OPS Subpart B 1.035) for an independent audit function within the Operations Environment – With the transition to EASA Regulation 965/2012 a number of anomalies and miss conceptions where addressed.
The UAE Ops Regulation is fundamentally based on JAR OPS 1.
What is an EASA Quality System?
Essentially it consists of a method to deliver the organisations “product” under the control of nominated persons – this is a “Control of Quality” together with an independent function to assess compliance and this is known as “Quality Assurance”.
The problem is in simple terminology and it is all in a comma!
Considering the following sentences and the difference between the 2:
Version 1 Official - iii. Quality Manager. The manager, acceptable to the Authority, responsible for the management of the Quality System, monitoring function and requesting corrective actions.
Version 2 Proposal iii. Quality Manager. The manager, acceptable to the Authority, responsible for the management of the Quality System monitoring function and requesting corrective actions.
In version 2 (which is not official the QM is responsible for the monitoring/oversight function whereas Version implies a different level of responsibility.)
There is a misconception in various “EASA centric” areas of the industry that the Quality Manager is responsible for the Entire Quality System – means the deliver of QC which is not true.
Making a Change
To lay the ground for an improved Quality Experience, EASA has re identified the Quality Manager as the Compliance Manager (CM) – this subtle change is intended to focus on the true nature of the role of the QM within the EASA System.
Now consider the Role of the Post Holder – He is responsible for the Business Area to function in accordance with the regulatory obligations – This is Quality Control.
Now consider for every finding or nonconformity raised by the Quality Manager there is potentially a double finding.
1/ What is the Problem?
2/ Why did the business area not know it was a problem?
We compensate to a degree by requiring the PH (Business Area Owner) to determine the Root Cause – however ineffective determination of RC is a major disconnect in what could otherwise by an excellent system.
As a final comment consider if the CAA makes a finding – then we finish up with 3 issues:
1/ What is the Problem?
2/ Why did the business area not know it was a problem?
3/ Why has the Quality Audit System NOT identified the issue?
So a final comment is that:
Evidence of findings made by the CAA should be at a very low “interpretive” level and should not identify issues which carry significance – and this is a measure of an effective organisational system.
Sofema Aviation Services www.sassofia.com and our online partner SofemaOnline www.sofemaonline.com offer classroom and regulatory training compliant with EASA, FAA and UAE GCAA Regulations and include vocational training – for details please email office@sassofia.com
