Certain Parts will require special attention due to the size for example Aircraft Landing Gears and Engines. To ensure adequate inspection techniques are followed the following should be included.

a) Written procedures?

b) Internal quality audit procedures?

c) Signature procedures?

d) Procedures for checking for physical damage and defects?

e) Preservation procedures?

f) Procedures for quantities received controls?

g) Verification procedures for part/model/serial numbers?

h) Documentation matches part(s)/material(s) received?

Sofema Aviation Services www.sassofia.com looks at the basic requirements related to an effective EASA Compliant Aviation Stores

Regulatory Drivers

Storage, Tagging and Release of Aircraft Components and Materials to Aircraft Maintenance

[Part 145.A.25 (d), AMC 145.A.25 (d) 1, 2, 3 - Part 145.A.40 (a) - AMC 145.A.42 (b) - Part 145.A.70 (a) 12] 

Concerning Storage

Stores shall provide the necessary capacity to stock aircraft components, consumable and raw material in the manner recommended by manufacturer’s instructions and in accordance with the relevant regulations and safety precautions.

EASA Regulations Provide for EASA Part 145 Organisational Theoretical & Practical Training in support of Task Training for CAT A and CAT B2 Aircraft Engineers.

In Addition, EASA Regulations provide for On the Job Training (OJT) following completion of the First Type Training in each Category.

EASA Regulatory Background Guidance

66.A.45 Endorsement with aircraft ratings

In addition to the requirement of point (b), the endorsement of the first aircraft type rating within a given category/sub-category requires satisfactory completion of the corresponding On the Job Training, as described in Appendix III to Annex III (Part-66)

Equip yourself as an instructor and be able to provide training in support of both EASA 145 & EASA 147.

Support the delivery of training to the highest possible standard of technical and behavioural instructional skill.

Engage with continues professional development and commit to continuous improvement as an instructor.

Available Now! – Online Training to Prepare you for the Instructor Role

SofemaOnline EASA Part 145 / 147 Instructor Techniques Course Train the Trainer course is waiting for you now here.

Issues and observations made by Steve Bentley MD SAS (www.sassofia.com) 

EASA Clearly identifies roles and responsibilities of the Role of EASA Part 147 Practical Trainer and Practical Assessor. However EASA has omitted to clearly identify the Role of EASA Part 145 Trainer “Supervisor / LAE”

Following the amendment of EC 1149/2011 EASA Part 145 has NOT been updated to include either AMC or Guidance material required to ensure standardisation of the OJT / OJE Process – rather it is left as an open obligation of each organisation to individually develop a procedure which is then accepted by the local Competent Authority (CA) (potential weakness and exposure).

Appendix III to AMC defines On-the-job-Experience as requiring a particular skill set to be present with the role of Supervisor related to the role of OJT “trainer” – this requires both training to an organisational standard & authorisation (see highlighted area above).

Sofema Aviation Services www.sassofia.com looks at several Organisational Challenges related to the Management of  on the Job Training within an EASA Part 145 Environment

Regulatory Background

Driven by changes in EASA regulations in accordance with EC 1149/2011 EASA introduced unique terms for Practical Training which is the responsibility of the 147 Organisation and “On the Job Training (OJT) which typically sits with the 145 organisation.

Note 2 – Whilst EASA Part 147 Contains multiple references to roles and responsibilities in respect of the role of Practical Assessor and Practical Trainer – There is an absence of guidance within EASA Part 145 - Clearly this is a challenge.

EASA References within Part 66 provide for very limited guidance material related to 145 – Ref appendices to Annex III 

Appendix III - 4.2 Point 6 On the Job Training (OJT) shall be approved by the competent authority who has issued the licence.

SOL (www.sofemaonline.com) and SAS (www.sassofia.com) offer EASA compliant regulatory training both online and within the classroom environment.

Are you looking for effective EASA Part M Regulatory Training?

SofemaOnline and Sofema Aviation Services together cover all elements of Part M. Our training courses are delivered by Industry Professionals with a wealth of experience in the field and an immense amount of practical relevance is included throughout the presentation.

What is EASA Part M?

A set of regulatory guidelines used to manage continuing airworthiness. EASA Part M has been around officially since Sept 2003.

Part M can trace its origins to JAR OPS 1 & JAR OPS 3 when in 1998 the Operator was identified as key player in maintaining the integrity of the Continuing Airworthiness. (CAW)

SofemaOnline provides online regulatory training courses to support the development of your Continuing Airworthiness Management Organisation (CAMO)

The following information supports consideration of which training is appropriate for a CAMO engaged with Large Aircraft (Aircraft above 5700 KGS).

All the following courses are available via the online training platform SofemaOnline.

Consider the benefits of enrolling and receiving SofemaOnline training courses:

Enjoy an Easy Online learning experience with SofemaOnline.com and SAS-e-aviation YouTube Video Channel.

The most effective way undertaking distance learning with the opportunity to receive cost effective training delivering more knowledge in the most flexible and efficient manner.

What is SofemaOnline?
 
SofemaOnline (SOL) is your trusted online training partner for EASA and FAA Compliant Regulatory Training – Currently more than 2000 people are enrolled and undertaking training online with SOL!

Why is SofemaOnline Growing?

During 2018 SofemaOnline has doubled its online training business when compared to 2017 and this is a continuation of a trend because 2017 was a doubling of the business we achieved in 2016!

With a growing portfolio of courses and our ability to quickly respond to our customers needs we are anticipating to again double our business by the end of 2019!

Where are we in our SMS journey in 2018? It is almost 1 decade since ICAO introduced the requirement for Proactive SMS, the good news is that it is evident that SMS is having a positive effect on the overall safety level across the industry.

In accordance with EASA Regulatory Obligations the accountable executive is accountable for establishing the SMS and allocating sufficient resources to support and maintain an effective SMS.

The current situation shows on examination that across lower levels within the industry (and this is true of almost all organisations) there as still a significant level of unreported exposures. Partly this is due to insufficient engagement with the SMS by many of the junior employees.

Pre-Requisites for Delivering SMS

SMS should build on existing organisation business processes and integrate with all the various elements of the management system. SMS Key Processes include Hazard Identification, Occurrence Reporting, Risk Management and Performance Measurement.

Whilst the ancestry of the FAA goes back to the 1920’s  the “Modern” FAA essentially started with the Federal Aviation Act of 1958. A different level of aviation safety was to be found at this time with a number of accidents driving congress to mandate a new independent regulatory body with authority to address safety issues through the power of rulemaking.

Today the FAA has a broad reach with authority for all aspects of aviation related activity in the United States.

Meanwhile over in Europe the Joint Aviation Authority (JAA) forerunner of European Aviation Safety Agency (EASA) can show its origins back to the early 1970’s. 

The original purpose of the JAA was to provide oversight and guidance related to the design and certification of large Aircraft, Engines and APU’s. It was during these early days that an alignment started to take place between the FAA and the JAA to introduce common certification codes for large aircraft and aircraft engines. Such alignment contributed to the common acceptance of Aircraft Parts and Alliances by participating entities.

Sofema Aviation Services www.sassofia.com looks at the challenges of maintaining an effective supply change compliant with EASA, Best Practice & Due Diligence.

What is it all about

Amongst other proposed changes EASA looked at enhancing the supplier evaluation procedure to provide clarity together with a strong and robust process.

So what happened

Unfortunately, as is currently happening in many regulatory related areas EASA steps back and several years pass. (This story is not a positive reflection on the role of EASA – however it is unlikely that this will change or improve in the near term!)

Sofema Aviation Services www.sassofia.com considers an EASA Compliant Maintenance Planning Process. 

Maintenance has come a long way since the early days when maintenance programs owed more to the perception of the maintenance needs, as opposed to the analyzed and justified needs. In addition the role of the regulator was also minimal, and in part developed as a result of events, incidents and accidents. 

During the end of the first half of the 20th century regulations began to strengthen and the aircraft manufacturer was seen as the appropriate source of the maintenance program development. The early attempts at effective maintenance (in the 1960’s) saw time limits developed which resulted in aircraft being progressively dismantled, in what became know as Hard Time primary maintenance.

All hard time components were then routed through an overhaul process and after an appropriate restoration process were considered as zero timed. (Means they were considered as zero life and good to go again) - Following investigations into the effectiveness of the Aircraft Maintenance Process, by both the FAA and several airlines, a number of determinations were made.

When a maintenance program is developed, it includes tasks that satisfy the criteria for both applicability and effectiveness.

The applicability of a task is determined by the characteristics of the component or equipment to be maintained.

The effectiveness is stated in terms of the consequences that the task is designed to prevent. The basics types of tasks that are performed by maintenance personnel are each applicable under a unique set of conditions.

Tasks may be directed at preventing functional failures or preventing a failure event consisting of the sequential occurrence of two or more independent failures which may have consequences that would not be produced by any of the failures occurring separately.

Maintenance Program task types include:

(1) Inspections of an item to find and correct any potential failures;

(2) Rework/remanufacture/overhaul of an item at or before some specified time or age limit;

Compliance Auditing brings with it the daily challenge of ensuring that the organisation remains at all times fully compliant with both internal and external obligations.

The Audit Management, Control and Oversight system should ensure that the established safety and quality procedures are fully complied with.

In addition :

a)     To plan and deliver audits

b)     To review findings

c)     To perform root cause analysis and develop additional actions where necessary (under the specific control or guidance of the business area owner of post holder)

In an effective Quality Management System QMS monitoring is a continuous process. It is essential to ensure robust and continuous oversight of all internal processes, and procedures.

Let’s consider the difference between Assessment & Audit

Assessment

The evaluation process used to measure the performance or effectiveness of a system and its elements.

Our goal is to perform an assessment of the auditing process follow up to determine both the cost effectiveness and overall value to the business.

Audit

An EASA Audit is a systematic and independent examination to determine whether quality activities comply with external regulatory requirements and internal organisational specifications and whether these specifications are implemented effectively.

A primary indicator of a poor or failing system is repeat findings or findings which should be addressed at a lower level – for example the Competent Authority should not identify problems which are normally expected to be found within the internal Quality Assurance System audit process.

The ability to successfully identify and address the root cause is not a given and like many activities benefits from improved knowledge experience and development of individual competence.

Typically it is only by monitoring over time that we are able to confirm that the mitigation's which have been developed as a result of analysed root cause have done the job. However we can draw a conclusion based on our understanding of the analysis and actions which have taken place to assess if we have confidence in the steps which have been taken.

Any shortfall in expectation could for example cause the finding to be re-opened for additional analysis.

Some of the reasons that the true root cause has been miss identified are considered here :

a) Root Cause Analysis (RCA) based on assumptions rather than on objective evidence. It is essential to ensure that all data is accurately classified and clearly understood in relation to the observed facts.

Please consider that just because a product meets for example compliance with ISO 9001-2015 objectives does not automatically mean it is safe. (Just as not having an accident can be taken as meaning that we will not have an accident in the future.)

In reality the key aspect becomes our ability to measure risk and exposure. Quality systems audits consider gaps related to compliance with both external regulations and internal organisational process and procedures.

Quality Assurance and Risk Assessment

The first point to make is that the term “risk” subjective whereas the role of an EASA regulatory driven audit is to assess compliance with a standard not an opinion so this creates a challenge.

So when a discrepancy is identified it creates a number of questions

Why should we wish to measure the performance of our Compliance Audit Process?

Essentially for 2 reasons

1/ The first is that we have an organisational obligation to ensure both regulatory and organisation compliance and of course there is a cost for this – so the question becomes is the organisation receiving value for money?

2/ The second is because there is a cost associated lets call it a return on investment – if we invest more will we return more- without a measure we will not be able to understand this.

The Internal Audit function was predominantly existing as a mandatory process to ensure and demonstrate compliance is also able to focus on improving business performance and add value by supporting strategic business objectives.

Management communication of the various shortfalls related to the audit findings should be strong and consistent and to be demonstrated to have a contributory impact on a culture of compliance within an organization