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 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 several 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, is 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, is 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 – which means the delivery 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 following 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 be 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 that carry significance – and this is a measure of an effective organisational system.