Sofema Online (SOL) www.sofemaonline.com considers the terms, definitions, and differences related to Practical Assessment from an EASA perspective.

Introduction

 Appendix III 4.2.

• Practical Assessment is performed by Part-147 within an approved maintenance environment.

>>  (Part-145, with A rating, manufacturer) under the Part-147 approval

>>  Defined maintenance environment as described in the directly approved procedure by the competent authority (66.B.130) - Reference: Appendix III 1(b)

 Sofema Online (SOL) www.sofemaonline.com reviews the regulatory requirements driven by ED Decision 2022/011/R concerning the amendment of the AMC & GM to Commission Regulation (EU) No 1321/2014 in the context of  SMS in Part-145 and Occurrence reporting

>> Amendment of the AMC & GM to Commission Regulation (EU) No 1321/2014

• ‘SMS in Part-145’ and ‘Occurrence reporting’

Introduction

Sofema Online (SOL) www.sofemaonline.com considers the responsibilities of EU-based AMOs holding a 14 CFR Part 145 approval. Ref Maintenance Annex Guidance Change 8 Section C.

Introduction – Certification Process for EU-based Approved Maintenance Organizations

Initial Certification Process

Sofema Online (SOL) www.sofemaonline.com considers the process of reviewing the system’s effectiveness following the completion of a Base Maintenance Check.

Introduction

An ideal time to optimize the various processes occurs following each maintenance check, an investment in this opportunity will typically reap benefits in overall efficiency & effectiveness.

Consider the typical issues which can be looked at following the completion of a maintenance check:

Review by Sofema Aviation Services (www.sassofia.com)

Regulatory Background

Reference NPA 2019-05 & EASA  (RMT).0251 Phase II in EPAS 2019-2023, NPA proposes amendments to Annex I (Part 21) to Regulation (EU) No 748/2012 and Annex II (Part-145) to Regulation (EU) No 1321/2014, in order to:

○ Introduce safety management principles that implement ICAO Annex 19, and foster an organizational culture for effective safety management and effective occurrence reporting in accordance with Commission Regulation (EU) No 376/2014.

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. 

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

Presented by SofemaOnline - a service provided by Sofema Aviation Services, offering a range of EASA, FAA and other leading regulatory compliant and vocational online courses, many with voice over.

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))

Presented by SofemaOnline - a service provided by Sofema Aviation Services, offering a range of EASA, FAA and other leading regulatory compliant and vocational online courses, many with voice over.

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?

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. 

Presented by Sofema Aviation Services (www.sassofia.com) and Sofema Online (www.sofemaonline.com)

Within the EASA Part 145 environment SMS is inextricably linked to HF working and behaviours, as well as culture and attitude within the workplace.

What does a “GOOD” Organisation look like?

Consider the following and let’s call them “Positive Organizational Characteristics”.

Steve Bentley CEO of Sofema Aviation Services www.sassofia.com looks at common errors made by MRO’s in allocating responsibilities for process 7 procedures – compounded by the weakness of regulatory auditors to identify such. 

All comments are welcome office@sassofia.com 

145.121 Maintenance procedures and quality system

(a) The organisation shall establish a safety and quality policy for the organisation which shall be included in the organisation’s exposition.

How Effective is your Maintenance Error Management System (MEMS)?

The basic MEDA philosophy is based on an understanding that people do not intentionally make errors and that organizational factors play a significant and contributory role.

It is widely recognized that the majority of causal and contributory factors leading to an error can be managed. In addition developing root cause understandings, leads to a wider and more effective mitigation process.

Where do you Stand?

How many of the following questions can you answer?

To be approved in accordance with 14 CFR Part 145, pursuant to the terms of this Annex, the AMO shall comply with all of the following Special Conditions:

The AMO shall submit an application in a form and a manner acceptable to the FAA.

a) The application for both initial and renewed FAA certification shall include:

i. A statement demonstrating that the FAA repair station certificate and/or rating is necessary for maintaining or altering U.S.-registered aeronautical products or foreign-registered aeronautical products operated under the provisions of 14 CFR.

Sofema Aviation Services (www.sassofia.com) considers the challenges to be found during the implementation & delivery of an effective Maintenance Error Management System (MEMS) within an EASA Part 145 Aircraft Maintenance Organisation (AMO)

Tensions between the desire to ensure safety behaviours and the organisations economic objectives (Production versus Protection) deliver real challenges which have a direct bearing on safety culture.

What is an Aviation Maintenance Safety Culture?

Within the workplace the consequences of human failure can be significant, unfortunately, we are all capable of error regardless of our training or motivation.

A human error is an action or decision which was not intended, however it is important to consider that human failure is not random. There are two main types of human failure: errors and violations.

Errors often occur highly trained procedures where the person carrying them out does not need to concentrate on what they are doing (Improved design can reduce their likelihood and provide a more error tolerant system).

Violations are rarely malicious (sabotage) and usually result from an intention to get the job done as efficiently as possible. Getting to the root cause of any violation is the key to understanding and hence preventing the violation.

Organisation Obligations

The potential for Human Error should be managed proactively and should be addressed as part of a wider risk assessment process.

There are a number of ways we can assess the integrity of a Vendor/Supplier with the objective of improving the supplier performance.

Understanding the purpose of Receipt Discrepancy Processes and Component Reliability Assessment including warranty issues.

Why would we carry out a Vendor Survey?

Essentially it is a process which sits alongside the Supplier Evaluation Procedures and enables an ongoing assessment of the effectiveness of the supply chain arrangement with a given vendor.

What do we want to know concerning our vendors?

We want to know how effective is the product which is received from a particular supplier, and we measure this in a number of ways:

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?