The amount of Digital Data available in modern aircraft facilitates FDM providing the opportunity for effective analysis which is essential to provide for the best decisions regarding both the performance of flight crew as well as the aircraft systems and processes.
Aircraft are analysed to identify any exceedances (a specialist task typically performed using software tools).
Gathering FDM Data
Traditionally, data needs to be downloaded to a removable disk regularly before the data is lost. But latest technologies allow wireless data transmission from recorders to the ground station, which is more accessible for research and monitoring purposes.
What is Flight Operational Quality Assurance (FOQA)?
Even though Aviation is probably the safest form of mass transport, there remains an inherent obligation to reduce exposure and thereby drive down accident rates.
Operational Flight Data Monitoring, known more recently as Flight Operational Quality Assurance (FOQA), is probably the most important safety tool available to aviation.
Essentially Flight Data Monitoring (FDM) is the exploitation of flight data to support an understanding of the various exposures, the knowledge of which, may successfully lead to the development of mitigations which can be employed to enhance flight safety.
According to Commission Regulation (EU) 965/2012, “Flight Data Monitoring (FDM) means the proactive and non-punitive use of digital flight data from routine operations to improve aviation safety”.
European regulations expect the National Aviation Authority – NAA (competent authority) to have oversight of the Management Systems of their aircraft operators.
An EASA Flight Data Monitoring System (FDM) provides a set of tools for the operator to monitor operational safety. (FDM becomes the main data sources for monitoring the operational safety level.)
Operational Flight Data Monitoring, known more recently as Flight Operational Quality Assurance (FOQA), is probably the most important safety tool available to aviation.
Rather than reacting to serious incidents, operators have a very useful tool to proactively identify safety hazards and mitigate the risks.
What Happens to Identified Events?
Whilst each individual event typically needs to be investigated so that the appropriate management decisions may be made by the airline, there is an opportunity for a deeper and longer lasting outcome.
Event data may be managed to facilitate the wider and longer-term trend analysis so that events & issues can be identified and corrective action is taken.
The following white paper considers a number of challenges faced by EASA Regulatory Authorities to engage with a Performance-Based Approach in this case with Aircraft continuing airworthiness monitoring (ACAM) (however there is a read across into SMS).
Steve Bentley is MD of Sofema Aviation Services www.sassofia.com
EASA commenced operations on September 28, 2003. Under the regulation, EASA initially has responsibility for:
a) All design approvals b) Continued airworthiness c) Design organization approvals d) Environmental certification e) Approving production f) Maintenance (repair station), and g) Maintenance training organizations
The U.S. government has a bilateral agreement in place with the European Union, rather than EASA.
The U.S./EU Agreement covers more areas than bilateral agreements the U.S. has with other countries.
It is a three tiered agreement.
a) The highest tier is the Executive Agreement, which provides the framework for all cooperation between the U.S. and the EU in the area of aviation safety. b) The second tier is the Annexes.
- Annex 1 covers airworthiness and environmental certification, and - Annex 2 covers maintenance.
The Continuous Airworthiness Management Organization “CAMO” is essentially responsible for 4 primary functions - Planning, Technical Records, Engineering, and Reliability. These groups work together to ensure that the Aircraft remain fully compliant with all requirements concerning the aircraft maintenance management and associated oversight.
Within the CAMO the Maintenance Planning, Technical Records, Engineering & Reliability groups work together to ensure that the aircraft remain fully compliant with all requirements concerning the aircraft maintenance management and associated oversight.
Within the CAMO department the Maintenance Planning Group has a range of responsibilities including:
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.
The Role of Maintenance Error Management Systems (MEMS)
The ability of the organisation to investigate Maintenance Error is a valuable tool to understand causal, contributory and root elements and to develop and provide appropriate mitigation's to reduce ongoing exposure.
If we wish to minimize re-occurrence we should address not only the root cause (or causes) of a given outcome, but to also consider all the contributing causes (and there could be many!) as this will have a significant positive impact on the lowering of the threat level (reduction in exposure).
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:
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.)
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.
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.
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.
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
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.
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).
