Sofema Aviation Services provides clarification regarding the various terms used to describe the European Aviation Safety Agency (EASA) rulemaking.

Introduction - Here’s a quick self-check!

Can you explain the difference between a “Decision” and an “Opinion”? (If like many of Sofema delegates you are not so sure, then you are in good company :)

Here we take a look at some of the common terms and explain what are the differences.

Can EASA Interpret EU Law?

EASA is not the competent authority to interpret EU Law. The responsibility to interpret EU Law rests with the judicial system, and ultimately with the European Court of Justice. EASA cannot even provide an 'authentic interpretation' (which is an official interpretation of a statute issued by the statute's legislator). 

SofemaOnline considers the acceptance of Parts Manufacture Authority (PMA) parts within the European System.

An FAA PMA is the normal approval mechanism for any company that wants to produce and sell aircraft parts, however, is not in possession of a production certificate for a complete aircraft, engine or propeller. In accordance with EASA Decision No. 2007/003/C PMA parts are approved following the issue of the FAA PMA (without the requirement for a separate application).

The European Union (EU) regulations require that EASA issue certificates for the design of parts and of their installation into products subject to those EU regulations. This created a problem because when EASA was formed, several significant EU member states had long-standing agreements to accept FAA-PMA parts from the United States. This made sense for supporting European air carriers who were already using such parts.

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Concerning Operational Approval

Ref - AMC3 SPA.RVSM.105 RVSM operational approval (ED Decision 2017/009/R)

a. Maintenance programme

The aircraft maintenance programme should include the instructions for continuing airworthiness issued by the type certificate holder in relation to the RVSM operations certification in accordance with AMC1 ACNS.A.GEN.010. 

Sofema Aviation Services (www.sassofia.com) takes a look “under the hood” of EASA Compliant Quality Auditing Derived Data. 

Introduction

Effective Quality Management ensures that the organization's products and services are able to continue to meet internal company, client and all “Regulatory Requirements”.
Quality Assurance is the means by which the quality management process can be focused on providing confidence that all quality requirements will be fulfilled.

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Sofema Aviation Services considers the Challenges of Developing an Effective Training Needs Analysis in support of EASA Part 147 type training

All Maintenance Training Organisations are required to generate their own TNA (Training Needs Analysis) and syllabus to develop their type or basic training courses in accordance with regulation 1321/2014.

Whilst the TNA process is proprietorial to the organization which creates the training course it is nevertheless a requirement that the entire process is subject to audit either by the applicable CAA or another auditor.

The essential purpose of the audit is to ensure the validity of the TNA management process. In particular to ensure the correctness of TNA outcomes including the training duration.

Considering Changes introduced by COMMISSION IMPLEMENTING REGULATION (EU) 2019/1383 of 8 July 2019 amending and correcting Regulation (EU) No 1321/2014 as regards safety management systems in continuing airworthiness management organizations and alleviation's for general aviation aircraft concerning maintenance and continuing airworthiness management.

Sofema Aviation Services considers the new regulation

Subjects Covered

Related to Commission Regulation (EU) No 1321/2014 & the introduction of simplified Continuous Airworthiness (CAW) requirements corresponding to the lower risks associated with light aircraft in general aviation, which is not listed in the air operator certificate of an air carrier.

Related to Aircraft Maintenance Programmes (AMP) airworthiness reviews and deferment of defects.

SofemaOnline takes a look at what SMS Internal Reporting Elements should be addressed in the context of the Organisational 145 SMS 

Reporting Systems should include the possibility of Voluntary and Confidential Elements, however, please note that an essential feature of a successful system is the willingness of the Employees to engage with the system. In fact, this becomes a key measure of an effective system.

Introduction

The overall purpose of the internal safety reporting scheme is to use the reported information to improve the level of the safety performance of the organisation, and not to attribute blame.

The scheme is an essential part of the overall monitoring function and should be complementary to the normal day-to-day procedures and ‘control’ systems; it is not intended to duplicate or supersede any of them.

SofemaOnline takes a look at what SMS related Change Management Processes are coming into EASA 145 Management Systems 

Introduction

Unless they are properly managed, changes in organisational structure, facilities, the scope of work, personnel, documentation, policies, and procedures, etc. can result in the inadvertent introduction of new hazards and expose the organisation to new or increased risk.

Effective organisations seek to improve their processes, with conscious recognition that changes can expose the organisation to potentially latent hazards and risks if they are not properly and effectively managed.

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.

Sofema Aviation Services looks at what is coming related to EASA Part 145 Management System 

Introduction

EASA objective is to encourage organisations to embed safety management and risk-based decision-making into all their activities, instead of superimposing another system onto their existing management system and governance structure.

The new elements that are introduced by the NPA 145 in particular address component 2 ‘Safety Risk Management’ of the ICAO SMS framework. and address component 3 ‘Safety Assurance’.

It is important to recognise that safety management will be a continuous activity, as hazards, risks and the effectiveness of safety risk mitigations will change over time. 

SofemaOnline looks at the challenges related to the potential uncertainty of the status of instructions for continued airworthiness (ICA) and needs, therefore, to avoid there being too much room for interpretation in the rules and standards, leading to differences and possible safety risks.

The specific objective is to establish clear requirements and responsibilities for all parties involved in the production of ICA, their approval and their implementation.

The Notice of Proposed Amendment (NPA) proposes to amend Annex I (Part 21) of Regulation (EU) No 748/2012 to clarify that ICA are part of the type certificate (TC) and to develop the related acceptable means of compliance (AMC) and guidance material (GM).

It also merges the requirements related to record-keeping, manuals and ICA in the various subparts into a single requirement for each of these aspects in Subpart A (new points 21.A.5, 6 and 7).

SofemaOnline takes a looks at NPA 2018-11

The objective of this Notice of Proposed Amendment (NPA) is to improve the level of safety related to the minimum syllabus of maintenance certifying staff (MCS) type rating training (TRT), enabling design approval holders (DAHs) that comply with Annex I (Part 21) of Regulation (EU) No 748/2012 to identify the technical elements necessary to be addressed for the purpose of training of maintenance certifying staff involved in the maintenance of their products.

In addition, the intent is to ensure an adequate minimum syllabus standard at organisations that comply with Annex IV (Part-147) to Regulation (EU) No 1321/2014.

This NPA proposes:

The first issue of Certification Specification on Maintenance Certifying Staff (MCS) data (CS-MCSD) and the associated Guidance Material (GM);

Sofemaonline.com offers online training including EASA Part 66 Module 9 Human Factors compliant training for third country workshop personnel

Introduction

It is important to ensure that all employees are aware of how to act in the event of a workplace emergency. Whilst not every person needs to be qualified as a fire marshal or Emergency First Aid Responder, it is important that a number of employees are "highly trained" and all employees have an general awareness of all potential emergencies and how to proceed.

All employees should understand what constitutes an emergency or disaster at the workplace?

Additionally, to understand:

As part of the proposals to be found in forthcoming regulation NPA 2019-05 (C) SMS will be introduced into the EASA 145 Environment

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Introduction - Safety Management Systems (SMS) - Nothing New?

SMS became an ICAO requirement as of Jan 2009 and EASA is late to embed SMS within the “145” environment. However, there is a very important aspect of SMS to consider and it is this. 

The fact that everyone is “familiar” with SMS is a source of potential challenge and even “danger”. Why? - Familiarity Breeds Contempt (Hear that one before?)

Ask your colleague to explain to you the difference between Hazard & Risk or The Difference between Compliance Auditing (Quality Assurance) and Safety Auditing, and you will see the point!

Introducing Changes to Production Planning - 145.A.47 (Forthcoming regulation NPA 2019-05 (C))

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The purpose of the Fatigue Risk Management System (FRMS) is to promote a reduction, as far as practicably reasonable, workplace fatigue and its associated risks, to ensure a safe and error-free work environment for employees, contractors, and clients.

FRMS should ideally be a component of your SMS, commitment from senior and line management together with clear consultation and effective communication with all employees should be ensured to provide a positive safety culture.

Introducing 145.A.37 (Forthcoming regulation NPA 2019-05 (C))

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Why Should 145 Organisations be involved with the issuance of Airworthiness Review Certificates?

The Answer is basically to fill a niche, the approval is quite restricted and is only applicable to small “None AOC” aircraft – namely.

The Certificate which is used to provide the ARC is EASA Form 15C.

What is ML.1?

Sofemaonline.com offers online training including EASA Part 66 Module 9 Human Factors compliant training for third country workshop personnel

Introduction

Aircraft certifications are made within the framework of an organisation approval, part of which lays on the organisation the need to ensure currency – but it is not a one-sided story because the certifying staff also has a responsibility to remain current - means up to date with developments and changes to either the regulations or approved data which is driving the task.

Aircraft maintenance technicians typically undertake a significant basic training program which provides them with the knowledge and competence to enable them to become aircraft mechanics. 

Introduction

Steve Bentley CEO of Sofema Aviation Services www.sassofia.com & Sofema Online www.sofemaonline.com takes a look at what the forthcoming EASA changes to Part 145 will look like and what they could mean for Quality, Safety & Management Personnel. 

Name Change QM/QAM to CM 

In keeping with “Management System” understanding from Regulation 965/2012, the previous role title of Quality Manager or Quality Assurance Manager is essentially dropped with the focus again on Compliance Management. So again we will see either Compliance Manager or Quality Manager responsible for Compliance. 

Practical Base Maintenance Audits - Advanced Techniques for Auditing Workshops

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Auditing workshops

What is Unique within the Workshop Environment is that there is no Workshop Licence – So, for this reason, it is necessary to pay particular attention to the competence of the workshop certification personnel.

A typical workshop audit would start with the Organisations Quality System and ask the questions: