The Limits of Part-147 Approval: Understanding the role of the EASA Inspector and specialized training entities through the lens of EASA FAQ n.19073.

 

The presence of specialized providers like Sofema Online (SOL), which offers over 525 courses, packages, and diplomas, perfectly illustrates why the EASA Inspector’s role must be clearly defined between the Provider (Part-147) and the User (Part-145/CAMO).

Organizations like Sofema operate in a specialized "Regulatory Training" space that, by definition, sits outside the narrow privileges of a Part-147 approval.

A common industry misconception is that regulatory training (like SMS, Human Factors, or Part-145 Essentials) requires a Part-147 "stamp." As highlighted by Sofema, EASA does not issue an "approval" for regulatory training organizations. *

Part-147 Limits: This approval is strictly for Part-66 Basic and Type training.

• >> The Sofema Model: Providers like Sofema Online specialize in the "other" 90% of aviation training - vocational and regulatory compliance - which is not covered by the Part-147 audit scope.

The Inspector’s Focus: Acceptance vs. Approval

When an EASA Inspector audits a maintenance organization (Part-145), their role regarding a Sofema Online certificate is not to "approve" Sofema as a school, but to assess the "Acceptance" process of the Part-145 organization.

With large-scale providers offering specialized Diplomas (e.g., CAMO Diploma or Quality & Safety Graduate Package), the EASA Inspector’s role focuses on Competence Management Oversight.

Instead of debating the "delivery method" such as whether an online diploma is as effective as a classroom setting - the Inspector focuses on requirements like 145.A.35. They ask: Is the staff member actually competent to perform their assigned tasks? The certificate from a third-party provider is a "record of training," but the validation of competence remains the legal responsibility of the Part-145 or CAMO organization, not the training provider or the Part-147 approval.

How the Inspector Validates 525+ Different Courses

Since the Inspector cannot possibly audit every delivery method or slide in 525 courses, they look at the Maintenance Organisation Exposition (MOE) or CAME. They ask:

• "How did your Quality Manager verify that this Sofema Online course meets our internal standards?"
• "Did you use the Guest Access (offered by providers like SOL) to audit the syllabus before enrolling your staff?"

Managing Competence in the "Non-Regulated" Space

With large-scale providers offering specialized Diplomas (e.g., CAMO Diploma or Quality & Safety Graduate Package), the EASA Inspector’s role shifts toward Competence Management Oversight.

Instead of debating the "delivery method" (e.g., whether an online diploma is as good as a classroom), the Inspector focuses on 145.A.35: Is the staff member actually competent to perform their tasks? > Key takeaway for the Inspector:

• >> The certificate from a third-party provider is merely a "record of training." The validation of competence remains the legal responsibility of the Part-145 organization, not the training provider or the Part-147 approval.

Important Note - Exclusion from the Approval Schedule

As clarified in FAQ n.19073, courses that do not lead to Part-66 qualifications cannot be part of an organization's Part-147 Approval Schedule.

• >> Because they are not within the official scope of the training organization’s approval, they fall outside the direct jurisdiction of the EASA Inspector during a Part-147 audit.
• >> The Inspector’s Role: Non-Interference

o The primary role of the EASA Inspector during a Part-147 audit is to ensure compliance with the requirements for basic and type training.

o Therefore, the Inspector should not include the choice of delivery method, content, or scope of "extra" courses in their assessment.

• >> Oversight Limitation: The Agency or Member State does not "approve" the pedagogy or delivery platform (e.g., e-learning vs. classroom) for these courses under the Part-147 banner.
• >> Organizational Freedom: Training organizations (Including non 147 Organisations are free to provide these courses as commercial entities, but they do so without the specific "EASA Part-147" stamp of approval for that specific content.

Oversight at the User Level (Part-145/CAMO)

If the EASA Inspector does not audit these courses at the training provider level, the responsibility shifts to the User. When an Inspector audits a maintenance organization (Part-145), they assess the "appropriateness" of the training received by the staff rather than the training provider itself.

• >> At the Part-147 Organization: The Inspector ensures they are not certifying non-Part-66 courses under their 147 stamp.
• >> At the Part-145/CAO Organization: The Inspector verifies that the Quality Manager has vetted the 3rd party training (e.g., Sofema) to ensure it meets the organization's specific needs.

Next Steps 

See Sofema Aviation Services and SofemaOnline or email team@sassofia.com