Steve Bentley CEO of Sofema Aviation Services (www.sassofia.com) looks at the regulatory implications of the New Part M and explains the new terms and what they mean.
Implementation Date – 24 March 2020
Following the Implementation Date - each aircraft must follow either Part-M or Part-ML standard, and any person or organization involved in continuing airworthiness must comply with Part-M, or Part-ML or both, depending on the scope of activities (related type(s) of aircraft and operation(s)).
Sofema Aviation Services (www.sassofia.com) Considers Elements related to EASA Regulation 965/2012
Introduction
No 216/2008 (superseded by regulation 2018/1139) mandates the European Commission to adopt common technical requirements and administrative procedures for air operators of aircraft to ensure compliance with the essential requirements laid down in Annexes IV and Vb of that Regulation.
An Air Operator Certificate (AOC) is a European Required certificate that allows an operator to perform specific operations of commercial air transport.
Introduction by Sofema Online
Introduction to Bowtie Risk Assessment Methodology
Bowtie is a risk evaluation method that can be used to analyze and demonstrate causal relationships in high-risk scenarios, in addition to enable an understanding of the control scenarios by identifying control measures.
The assessment of the bowtie elements facilitates the identification of the safety and risk priorities. Providing a visual interpretation of how improvements can be enabled and understood throughout the aviation system.
Bowtie is a visual tool that effectively depicts risk providing an opportunity to identify and assess the key safety barriers either in place or lacking between a safety event and an unsafe outcome.
Considerations from SofemaOnline (www.sofemaonline.com) (Reference also AC 145-10 - Repair Station Training Program)
Introduction
Whilst EASA facilitates the development of 147 Organisation Approval in Non-EU Countries, the FAA does not certificate part 147 AMTSs outside of the U.S.
Aircraft Maintenance Technician Schools (AMTS)
An AMTS is an educational facility certificated by the FAA to train prospective aircraft mechanics for careers in the airline industry, in aviation maintenance facilities, and in commercial and General Aviation (GA). 14 CFR part 147 specifies requirements for the certification and operation of an AMTS. The regulation includes both the curriculum requirements and the operating rules for all certificated AMTSs. The knowledge, skills, and abilities required of mechanics are considerable and demand high-quality training. Therefore, the FAA requires high standards from the AMTS.
An AMTS may be FAA-certificated for the following ratings:
Sofema Online provides a brief introduction to EASA Part 21 Subpart G Process and Privileges.
An EASA Part 21 Subpart G organization is an organization which has approval to manufacture aircraft parts and appliances in conformity with approved data.
The production organization certifies and releases the product on either Form 52 for a complete aircraft or EASA Form 1 for components.
Production Organisation Approvals (POAs) are managed by EASA in accordance with Subpart G of Regulation (EC) No 748/2012.
SofemaOnline takes a look at the facts concerning EPA
Introduction
FAA Parts Manufacturer Approval (PMA) is a combined design & production approval which does not exist within the EASA system. All design is done by EASA Part 21 Subpart J & All Production (assuming there is approved design data) is done by EASA Part 21 G Organisation.
Note EASA Part 21 Subpart F is for cases (typically part of design development) where there is no production authorisation approval.
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.
Presented by SofemaOnline
Do you want to grow RVSM Competence in your organisation? Online or Classroom EASA compliant RVSM training available now!
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.
www.Sofemaonline.com enables competence development for both individuals and organizations providing a valuable regulatory and vocational learning opportunity.
Our Learning Diplomas are quickly becoming an effective solution to the challenge of building competency, with more than 150 online courses currently available we are ideally positioned to support your training needs. The Sofema Online team is renowned for its excellent preparation and organization skills providing a superb online learning experience as well as a friendly and approachable customer service – Contact Sofema Online now at Online@sassofia.com
Sofema Courses are developed by subject matter experts with a strong work ethic as well as a deep knowledge and passion for their subject. Our focus is aimed at raising your competency by significantly improving your knowledge, understanding and practical skills.
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:
