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.

Comments by Steve Bentley MD Sofema Aviation Services www.sassofia.com

Introduction

As a precursor to the introduction of Regulation 376/2014 EASA identified shortcomings related to Aviation Occurrence Reporting and proposed in 2010 a new regulation which in compliance with ICAO objectives moved the focus from a ‘reactive’ system to a pro-active, risk and evidence based system.  It also acknowledges that safety occurrence data is vital to allow for the timely identification and management of potential safety hazards and acts upon this before these hazards turn into an actual accident. 

EASA introduced EU Regulation 376/2014, (repealing EU directive 2003/42/EC), which came into force on 15th Nov 2015. The regulation provides additional safeguards to address the lack of protection of the reporters, the lack of harmonisation in the occurrence data collection and integration (leading to low quality reports and incomplete information), as well as insufficient requirements regarding safety analysis and the resulting recommendations.

Sofema Aviation Service www.sassofia.com looks at SMS reporting from the EASA perspective

What do we mean by Safety Occurrence Reporting?

We use the term Safety Occurrence to identify as a collective term which is used to embrace all events which have, or could have significance in the context of aviation safety.

Events identified may in fact range from minor events which are deemed to have a potential for an impact on safety through to incidents or events that should be reported to more serious events including serious incidents and accidents.

Building a Reporting Culture

The willingness to report, safety related exposures is a significant measure when we are considering the effectiveness of Safety Management System.

Sofema Aviation Services www.sassofia.com  & www.sofemaonline.com looks at the bigger picture driven by the recent changes to the EASA Basic Regulation 1139/2018.

Introduction

On 11th September this year entered in force the new EASA Basic Regulation No 1139/2018 which repeals existing Regulation (EU) 216/2008.

The European Aviation Safety Agency (EASA) welcomes the adoption by the Council of the European Union of updated aviation safety rules for Europe which include a new mandate for EASA.

The so-called new Basic Regulation formalises EASA’s role in the domain of drones and urban air mobility, enabling the Agency to prepare rules for all sizes of civil drones and harmonize standards for the commercial market across Europe.

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.

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?

Sofema Aviation Services www.sassofia.com looks at the basic requirements related to an effective EASA Compliant Aviation Stores

Regulatory Drivers

Storage, Tagging and Release of Aircraft Components and Materials to Aircraft Maintenance

[Part 145.A.25 (d), AMC 145.A.25 (d) 1, 2, 3 - Part 145.A.40 (a) - AMC 145.A.42 (b) - Part 145.A.70 (a) 12] 

Concerning Storage

Stores shall provide the necessary capacity to stock aircraft components, consumable and raw material in the manner recommended by manufacturer’s instructions and in accordance with the relevant regulations and safety precautions.

EASA Regulations Provide for EASA Part 145 Organisational Theoretical & Practical Training in support of Task Training for CAT A and CAT B2 Aircraft Engineers.

In Addition, EASA Regulations provide for On the Job Training (OJT) following completion of the First Type Training in each Category.

EASA Regulatory Background Guidance

66.A.45 Endorsement with aircraft ratings

In addition to the requirement of point (b), the endorsement of the first aircraft type rating within a given category/sub-category requires satisfactory completion of the corresponding On the Job Training, as described in Appendix III to Annex III (Part-66)

Equip yourself as an instructor and be able to provide training in support of both EASA 145 & EASA 147.

Support the delivery of training to the highest possible standard of technical and behavioural instructional skill.

Engage with continues professional development and commit to continuous improvement as an instructor.

Available Now! – Online Training to Prepare you for the Instructor Role

SofemaOnline EASA Part 145 / 147 Instructor Techniques Course Train the Trainer course is waiting for you now here.

Issues and observations made by Steve Bentley MD SAS (www.sassofia.com) 

EASA Clearly identifies roles and responsibilities of the Role of EASA Part 147 Practical Trainer and Practical Assessor. However EASA has omitted to clearly identify the Role of EASA Part 145 Trainer “Supervisor / LAE”

Following the amendment of EC 1149/2011 EASA Part 145 has NOT been updated to include either AMC or Guidance material required to ensure standardisation of the OJT / OJE Process – rather it is left as an open obligation of each organisation to individually develop a procedure which is then accepted by the local Competent Authority (CA) (potential weakness and exposure).

Appendix III to AMC defines On-the-job-Experience as requiring a particular skill set to be present with the role of Supervisor related to the role of OJT “trainer” – this requires both training to an organisational standard & authorisation (see highlighted area above).

Sofema Aviation Services www.sassofia.com looks at several Organisational Challenges related to the Management of  on the Job Training within an EASA Part 145 Environment

Regulatory Background

Driven by changes in EASA regulations in accordance with EC 1149/2011 EASA introduced unique terms for Practical Training which is the responsibility of the 147 Organisation and “On the Job Training (OJT) which typically sits with the 145 organisation.

Note 2 – Whilst EASA Part 147 Contains multiple references to roles and responsibilities in respect of the role of Practical Assessor and Practical Trainer – There is an absence of guidance within EASA Part 145 - Clearly this is a challenge.

EASA References within Part 66 provide for very limited guidance material related to 145 – Ref appendices to Annex III 

Appendix III - 4.2 Point 6 On the Job Training (OJT) shall be approved by the competent authority who has issued the licence.

SOL (www.sofemaonline.com) and SAS (www.sassofia.com) offer EASA compliant regulatory training both online and within the classroom environment.

Are you looking for effective EASA Part M Regulatory Training?

SofemaOnline and Sofema Aviation Services together cover all elements of Part M. Our training courses are delivered by Industry Professionals with a wealth of experience in the field and an immense amount of practical relevance is included throughout the presentation.

What is EASA Part M?

A set of regulatory guidelines used to manage continuing airworthiness. EASA Part M has been around officially since Sept 2003.

Part M can trace its origins to JAR OPS 1 & JAR OPS 3 when in 1998 the Operator was identified as key player in maintaining the integrity of the Continuing Airworthiness. (CAW)

SofemaOnline provides online regulatory training courses to support the development of your Continuing Airworthiness Management Organisation (CAMO)

The following information supports consideration of which training is appropriate for a CAMO engaged with Large Aircraft (Aircraft above 5700 KGS).

All the following courses are available via the online training platform SofemaOnline.

Consider the benefits of enrolling and receiving SofemaOnline training courses:

Enjoy an Easy Online learning experience with SofemaOnline.com and SAS-e-aviation YouTube Video Channel.

The most effective way undertaking distance learning with the opportunity to receive cost effective training delivering more knowledge in the most flexible and efficient manner.

What is SofemaOnline?
 
SofemaOnline (SOL) is your trusted online training partner for EASA and FAA Compliant Regulatory Training – Currently more than 2000 people are enrolled and undertaking training online with SOL!

Why is SofemaOnline Growing?

During 2018 SofemaOnline has doubled its online training business when compared to 2017 and this is a continuation of a trend because 2017 was a doubling of the business we achieved in 2016!

With a growing portfolio of courses and our ability to quickly respond to our customers needs we are anticipating to again double our business by the end of 2019!

Where are we in our SMS journey in 2018? It is almost 1 decade since ICAO introduced the requirement for Proactive SMS, the good news is that it is evident that SMS is having a positive effect on the overall safety level across the industry.

In accordance with EASA Regulatory Obligations the accountable executive is accountable for establishing the SMS and allocating sufficient resources to support and maintain an effective SMS.

The current situation shows on examination that across lower levels within the industry (and this is true of almost all organisations) there as still a significant level of unreported exposures. Partly this is due to insufficient engagement with the SMS by many of the junior employees.

Pre-Requisites for Delivering SMS

SMS should build on existing organisation business processes and integrate with all the various elements of the management system. SMS Key Processes include Hazard Identification, Occurrence Reporting, Risk Management and Performance Measurement.

Whilst the ancestry of the FAA goes back to the 1920’s  the “Modern” FAA essentially started with the Federal Aviation Act of 1958. A different level of aviation safety was to be found at this time with a number of accidents driving congress to mandate a new independent regulatory body with authority to address safety issues through the power of rulemaking.

Today the FAA has a broad reach with authority for all aspects of aviation related activity in the United States.

Meanwhile over in Europe the Joint Aviation Authority (JAA) forerunner of European Aviation Safety Agency (EASA) can show its origins back to the early 1970’s. 

The original purpose of the JAA was to provide oversight and guidance related to the design and certification of large Aircraft, Engines and APU’s. It was during these early days that an alignment started to take place between the FAA and the JAA to introduce common certification codes for large aircraft and aircraft engines. Such alignment contributed to the common acceptance of Aircraft Parts and Alliances by participating entities.

Sofema Aviation Services www.sassofia.com looks at the challenges of maintaining an effective supply change compliant with EASA, Best Practice & Due Diligence.

What is it all about

Amongst other proposed changes EASA looked at enhancing the supplier evaluation procedure to provide clarity together with a strong and robust process.

So what happened

Unfortunately, as is currently happening in many regulatory related areas EASA steps back and several years pass. (This story is not a positive reflection on the role of EASA – however it is unlikely that this will change or improve in the near term!)

Sofema Aviation Services www.sassofia.com considers an EASA Compliant Maintenance Planning Process. 

Maintenance has come a long way since the early days when maintenance programs owed more to the perception of the maintenance needs, as opposed to the analyzed and justified needs. In addition the role of the regulator was also minimal, and in part developed as a result of events, incidents and accidents. 

During the end of the first half of the 20th century regulations began to strengthen and the aircraft manufacturer was seen as the appropriate source of the maintenance program development. The early attempts at effective maintenance (in the 1960’s) saw time limits developed which resulted in aircraft being progressively dismantled, in what became know as Hard Time primary maintenance.

All hard time components were then routed through an overhaul process and after an appropriate restoration process were considered as zero timed. (Means they were considered as zero life and good to go again) - Following investigations into the effectiveness of the Aircraft Maintenance Process, by both the FAA and several airlines, a number of determinations were made.

When a maintenance program is developed, it includes tasks that satisfy the criteria for both applicability and effectiveness.

The applicability of a task is determined by the characteristics of the component or equipment to be maintained.

The effectiveness is stated in terms of the consequences that the task is designed to prevent. The basics types of tasks that are performed by maintenance personnel are each applicable under a unique set of conditions.

Tasks may be directed at preventing functional failures or preventing a failure event consisting of the sequential occurrence of two or more independent failures which may have consequences that would not be produced by any of the failures occurring separately.

Maintenance Program task types include:

(1) Inspections of an item to find and correct any potential failures;

(2) Rework/remanufacture/overhaul of an item at or before some specified time or age limit;