Considering Responsibilities Related to EASA Part 145 Initial and Recurrent Training

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Question and Answer Session with Steve Bentley CEO of Sofema Online (SOL)

1. What are Initial & Recurrent EASA 145 Training Courses?

A/ The Part 145 Organisation is responsible for the competence of its employees - this of course includes both Certifying Staff & Mechanics.

See the following link for details of what training is required to support EASA Part 145 approval, including Third Country Approval  https://www.easa.europa.eu/faq/19100

2. Who is Responsible for the Delivery of the Training?

A/ The 145 Organisation is 100% responsible for this training - they cannot “Contract” this responsibility - however they can “Sub Contract” the delivery of the training to another organisation which “they” (Means) the 145 Organisation deems to be acceptable through assessment and or audit.

3. Must Such Courses be delivered by an EASA 147 Organisations?

A/ Absolutely NOT - such organisations approved under EASA Part 147 “MAY” deliver such training courses as can any other organisation for example the JAA-to, Baines Simmons, Sofema Aviation Services & UK CAA International - all deliver such courses without certification approval (and this is 100% correct).

The Important point which cannot be over emphasized is that the “Receiving” Organisation remains 100% responsible the training content meeting the organisations needs.

4. So can a third country Civil Aviation Authority) CAA approve an External Organisation to deliver this training and remain compliant with EASA Guidelines?

A/ Absolutely NOT - A third country CAA can Accept & Validate but not approve such training - Should a Third Country CAA “Approve” such training - they are taking over responsibility for the competence within the organisation - rather than make the system stronger this makes it weaker because it undermines the Auditing and Assessment Process within Organisation.

5. So how does the 145 Organisation oversight system work?

A/ There are 2 elements involved in this oversite process:

     a) The Business Area Owner as well as the Nominated Person (Post Holder) and to include the Accountable Manager are responsible for the Competence of the Maintenance Staff - (This is a Quality Control Function & should not be QA).

     b) All Quality Control Processes should be independently audited by the Quality Assurance Department - Including both Initial & Recurrent Training (This is performed under the control of the Quality Assurance Manager) - Note that this MUST be independent.

6. Can Initial & Recurrent Training be delivered by the 145 Organisation itself (Without 147 approval)?

A/ Off course - there are many advantages to deliver the training in this way, however the organisation will typically consider the cost of the overhead of internally delivering the training process and balance against the opportunity to outsource the physical training delivery either in classroom or online.

The decision typically considers many factors and is not a “one size fits all” decision. Included in the decision-making process will be the competence of the Instructor - (assessed Internally to a “145” procedure acceptable to the organisation and meeting acceptable quality assurance oversight & validation).

7. How Does Sofema Aviation Services (SAS) support the “assessment of 145 Initial & Recurrent Training prior to the delivery of a classroom training?

A/ SAS will provide the receiving organisation with the CV of the Instructor, in addition the material may be previewed using “Team Viewer” to establish that it meets the organisations objectives & criteria.

8. How does Sofema Online support the “Assessment” of the 145 Initial & Recurrent process?

A/ Where more than 5 delegates require access to a particular training course on the Sofema Online Platform - SOL will provide a guest access on request to assess the Acceptability, Suitability & Regulatory Compliance of the training material.

Following this audit, the Organisations Quality Manager is able to internally “authorise” the use of the SOL online platform and confirm acceptability of its use within the organisation for the stated purpose.

Periodically assessments of Students who have completed the training should be carried out by the 145 Organisation - typically as part of the internal competence assessment.

9. What Human Factors Training is delivered by an EASA Part 147?

A/ Module 9 of Part 66 must be delivered by an EASA Part 147 Basic Training organisation if the recipient requires a certificate as part of the wish to gain an EASA Part 66 Aircraft Maintenance Engineers Licence AMEL.

10. So Human Factors for an Organisation is different to 147 Human Factors?

A/ Absolutely it is different! - the syllabus is different, and the objectives are different - simply put Human Factors for an EASA Part 145 Organisation must show compliance with 145.A.30(e) and associated AMC/GM.

11. Regarding the Online Training - Are the qualifications of the Course Owner Relevant to the Assessment?

A/ Off course NOT! - This is completely irrelevant.

Why? Because the online program does not require any further instructional involvement (means it is 100% complete).

So the online course in its entirety is available for audit & assessment purposes.

12. What does an online training course audit consist off?

A/

Step 1. A review of the Regulatory Requirement Driving the Course.

Step 2. A review of the Organisations Objectives and Requirements.

Step 3. Review of the proposed Material as a GAP Analysis against the requirements of Step 1 & Step 2.

Step 4. Documentation of the Assessment Procedures to fulfil the requirements of Quality Assurance Departments obligation to demonstrate independent audit.

Step 5. Periodic assessment of the employees typically during competence assessment.

13. So where does this process go wrong in typical Third Country Organisations?

A/ Part of the problem is understanding the difference between the FAA & EASA systems - they ARE different - the role of independent QA does not exist in the FAA system.

The Role of Independence of the Quality Assurance Function is often misunderstood by Third Country Regulatory Authorities.

Within the EASA system the Approved Organisation is 100% responsible - the Accountable Manager MUST Know this Fact & the Nominated Post Holder MUST Know this.

It is part of the responsibility of the approving CAA to ensure that the appropriate level of management competence is evident to manage the above obligations.

Further Steps

Please See www.sassofia.com or www.sofemaonline.com or email office@sassofia.com or online@sassofia.com

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