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Introduction

The Key to a successful delivery of “CAMO” Continuing Airworthiness is without doubt “Core Competency” across the key business elements of Continuing Airworthiness Manager (CAM), Maintenance Planning (MP), Engineering (Eng), Reliability (REL) and Tech Records (T/L).

Remember that the goal of EASA compliance is a step on the journey and not the destination – the focus of any effective Continuing Airworthiness Management Organisation (CAMO) should be to maximize the availability, reliability and safety of the fleet as well as focusing on a reduction in maintenance costs.

EASA Focus is shifting to a Performance Based Approach to Regulation

A “Performance Based Approach” brings to the fore two challenges:

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Review the Following

Details of ageing aircraft system requirements with any specified sampling programmes (if applicable).

Details of specific structural maintenance programmes (if applicable), including but not limited to:

a. Damage Tolerance and Supplemental Structural Inspection Programmes (SSID)

SUPPLEMENTAL STRUCTURAL INSPECTION PROGRAMME (SSIP)

Increased utilisation, longer operational lives, and the high safety demands imposed on the current fleet of transport aeroplanes indicate the need for a programme to ensure a high level of structural integrity for all aeroplanes in the transport fleet.

Tagged in: Compliance Part M Review
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Introduction

The Current Portfolio of SAS “TTT” - training courses currently on offer include Ramp Safety / HF TTT - Maintenance Instructor TTT, Human Factors TTT, Internal Auditor TTT, Safety Management System TTT, Fuel Tank Safety (FTS) & Electrical Wiring Interconnect System (EWIS) TTT and Maintenance Error Decision Aid (MEDA) TTT.

Correct Understanding is Important

Let's have a clear understanding here because it is important to understand that a 3 or 4 day training does not “Deliver” a trainer and clearly we would be “not correct”  if we were to believe this to be so.☺

The reality is that this course as well as other activities is part of a systematic process of building soft skills and competence across a range of topics which support the organization.

Tagged in: Ramp RSHF Safety Trainer TTT
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It is not possible to separate the Safety Management System from the need to manage Ramp HF in the most effective way. In fact the more integration the better in terms of understanding and managing the exposure.

All the elements which are considered as part of our Aviation Ramp Safety & Human Factors Exposure may typically be accommodated and addressed as part of the delivery of the SMS system.

If we are able to study and take appropriate action in respect of the human factors issues, we will be able to better prepare to deal with human factors issues and behaviours in our daily routine.

Driven by ICAO obligations European Countries (as well as the rest of the world) are required to demonstrate compliance with the requirements of ICAO Annex 19.

Airports are specifically mentioned within the requirements related to the need for a State Safety Program as well as the need to demonstrate compliance with the SMS obligations.

Tagged in: HF MHF Ramp Safety SMS
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What are we Trying to Verify?

An Audit will typically generate a number of findings, and whilst the first step is usually to take an immediate “short term” action, the important business is ensuring the fundamental cause or “root cause” is addressed – the challenge is that this is far from easy!

Essentially, we are seeking evidence that the cause or “causes” of the problem have either been removed or mitigated in an acceptable way. (It is not always possible to completely fix the issue and sometimes the best outcome we can hope for is a reduction of the causes.)

Essential Evidence for Verification

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Steven Bentley MD of Sofema Aviation Services believes it is time to recognise QAS as a component of our organisations' SMS.

Where Should an EASA Compliant Quality Assurance System “Sit” in relation to the Organisations SMS?

Introduction

Historically (and growing up in the workplace through the 1970’s I can attest to the fact) there was no formal Quality Assurance within European Aviation Operations.

Of course we had Quality Control and the Role of Flight Operations Director and within Maintenance the Role of “Chief Inspector”.

As the Joint Airworthiness Authority’s influence grew the concept of an independent assessment of conformity became the acceptable way of demonstrating compliance.

Tagged in: QA QC Quality Safety SMS
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To deliver effective EASA compliance audits it is necessary to pay attention to a number of key areas which are identified below for discussion purposes.

a) Maintaining Objectivity
b) Sample Size
c) Value of Finding Raised
d) Operator’s Authority on Area of Audit

Maintaining Objectivity

Objectivity requires both perspective and balance on the part of the auditor. We should also pay attention to the fundamental reason we are carrying out the audit.

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An essential element of any system is to be able measure the effectiveness of the various processes which are involved in delivering the overall product.

The Quality System consists of 2 distinct parts:

a) The Quality Control Processes – Embedded in all production areas
b) The Quality Audit Processes – An independent way of assessing point a) above

By measuring the effectiveness of both parts of the company’s quality system (QA & QC) we will be able to provide a detailed status of the strength of the Quality Management System (QMS) as well as to provide a detailed understanding which will facilitate management planning and development.

Step 1 - Organisation & Regulatory Review

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All EASA Approvals typically provide an independent Quality Assurance Function (EASA Part 21J requires a design assurance system)

The next comment is to consider the EASA “take” on QA & QC (A Quality System Contains Both). QC is embedded in every aspect and element of the Production Process.

The primary objective of an EASA Compliant Quality Auditing is to ensure both external and internal compliance with regulatory and organisational procedures.

We have a number of secondary objectives which are typically organisationally driven rather than EASA driven. (Never the less such elements provide for an indication of the intent and effectiveness of the organisation.)

An example of a secondary objective would be a demonstration of continuous improvement – which would mean a reduction in findings over time for a consistent level of auditing activity.

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So let’s take a look at how we could perform an Audit of the Internal Reporting System within an Operators Management System.

Consider First the Background Regulatory Obligations and to note that we need in this case to comply with both 965/2012 and 376/2014 (Proposed Audit Items are identified as AI-N)

AMC1 ORO.GEN.200(a)(2) Management system
COMPLEX OPERATORS - SAFETY POLICY

(a) The safety policy should:

(4) Include safety reporting principles. AI-1

(b) The safety policy should include a commitment:

(5) Not to blame someone for reporting something which would not have been otherwise detected. AI-2

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Introduction

The essential purpose of an EASA compliance audit is to support the maintenance of the regulatory approval.

Quality Assurance Compliance Audits are a systematic and independent comparison of the way the system process or objective is met. Using the observations made during this audit, as “objective evidence” a comparison is thus made against the standard, generating non-conformities or corrective actions in the event of any discrepancy.

The audits should be documented with a checklist which shows the details of the audit standard or audit criteria which is being applied to the audit.

Note 1 Quality Assurance Audits are Prescriptive in as much as they are always referenced against a standard – means compliant.

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A discussion paper by Steve Bentley MD of SAS (www.sassofia.com)

So what is the Fundamental Mistake?

Essentially it is to "believe" that there is a similarity between ISO & EASA – there is not! Sure, Quality is Quality but make no mistake – EASA is all about compliance.

Even the Quality Assurance Manager has received a name change "makeover" He or She, is now called the Compliance Manager (CM).

What Does EASA Expect?

There are actually two expectations:

Tagged in: CM EASA ISO QA QAM
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Time Constraints

This is a circular tour where people are time challenged which presents them from fixing the problem which will provide them with additional free time!

Many companies are caught in this catch-22 situation where whilst there are multiple disconnects, Often the organisation does not have enough “trained” people to perform the root cause analysis.

The Fire Brigade

People are often too busy fixing todays problems to address ongoing disconnects. Short term fixes are usually aimed at contributing factors without doing a root cause analysis. (Even if we add more people, with the intention to solve the situation the effort will usually not succeed since without training, additional resources are used ineffectively due to poor planning and scheduling.)

Reality Check

Whilst typically front-line staff may recognize a given problem, senior management often do not appreciate the dynamics of the same issue.

Often when senior management do understand the problem, they are pressured to deliver a quick fix to the situation.

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Introduction

Why people break rules, particularly if the outcome can be negative and even dangerous? What is it that makes a worker break the rules or commit a violation?

A great deal of research has been undertaken during the last 25 years with the focus looking at the view of errors in different way.

Rather than Human error being considered the ultimate cause of system failure, it is important to understand the context in which the error was committed. (For example, was it deliberate or related to Pressure, Fatigue, Stress or any of the other “Dirty Dozen”?)

Violations – Personal or Organizationally Optimizing?

To reduce exposure to violations and errors, a broad range of organisational interventions may be required.

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Steven Bentley MD of SAS www.sassofia.com considers the potential for HF Error with an EASA/GCAA compliant CAMO

Introduction

The Primary Roles of the CAMO are Maintenance Planning, Technical Records, Reliability & Engineering. Each “Role” brings the challenges of how we can ensure enough attention to both personal and organisational responsibility, when we consider the potential for HF error.

HF Example – Stress Caused by Pressure from “Poor Planning”

We are not considering here that it could be the Maintenance Planning Worker who is stressed – however this is of course a possibility, and we should always make sure that our team members have the appropriate level of “Competence” for the role.

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Steve Bentley MD of SAS (www.sassofia.com) discusses the various areas where the Maintenance Planning Process was able to become a precursor contributing to potential maintenance.

EASA commissioned a “Study on the need of a common worksheet/work card system” to evaluate the impact of maintenance documentation on the Human Factor concern.

(Specifications N°: EASA/2006/OP/25 On demand of the European Aviation Safety Agency (EASA), BUREAU VERITAS conducted a “Study on the need of a common worksheet/work card system” from January to November 2007. The present document presents the results of this study.)

The study aimed at providing further insights on the use of documentation, the common practices in place between operators and maintenance organisations and to assess whether current rules and practices may still contribute to incidents/accidents.

Among other results, the study produced a list of incidents/accidents related to the use of maintenance documentation.

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Introduction

Whilst currently (October 2018) EASA does not mandate the obligation to ensure CAMO & Maintenance Planning Staff receive HF training, the reality is that the potential for Human Factor Error knows no bounds and it is just as likely that a Human Factor (HF) error could originate from an exposure within the Maintenance Planning Environment as anywhere else within the “Aviation System”.

Currently some 80% of aircraft accidents are attributable to human error, however this is a situation where it is possible to manage and or address by managing the exposure.

Human Error is recognised as rectifiable through the process of raising awareness, implementation of effective process and procedure and effective communication within the workplace.

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Introduction

Whilst Aircraft fuel-tank entry is essential for both inspection and modification it poses a number of hazards to maintenance personnel performing the work.

Fuel-tank work can be accomplished as required without placing personnel at risk through effective preparation and training.

The Maintenance Organisation should strive to ensure a safe, healthy work environment for fuel-tank personnel by identifying potential hazards, developing control measures, and instructing personnel in the specific procedures to be followed during all Aircraft fuel-tank maintenance activities.

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Considering the role of a Fuel Tank Entry Team

An essential requirement to minimize exposure to the risk of injury during fuel-tank work is a properly trained and equipped team.

Personnel with authorization to enter the fuel tank and perform work must be able to recognize potential hazards and initiate evacuation if there are any concern issues.

The following elements are critical to safe working conditions:

a) Communication
b) Respiratory protection
c) Ventilation and air monitoring
d) Electrically powered tooling & equipment
e) Airplane damage considerations

Tagged in: Aviation Entry Fuel Tank
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Primary Hazards related to Fuel Tank Working

There are a number of potential hazards which fuel-tank maintenance personnel may experience whilst engaged in Fuel Tank Work however the 2 primary hazards are:

a) Chemical
b) Physical

Considering Chemical Hazards and their Consequences - Fuel

Off course the most commonly recognized hazard is the jet fuel itself which is a flammable liquid and will ignite if the temperature of the fuel is such that vapour is created. (The temperature at which the vapours of a flammable liquid can ignite is known as the "flash point".)

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