Sofema Aviation Services examines best practices for ensuring regulatory compliance and effective audit outcomes, particularly in small (less than 10 employees) and medium-sized (up to 50 employees) EASA Part 145 organisations.
While EASA recognizes the resource constraints faced by smaller companies, independence in auditing is essential to maintain credibility and compliance.
The requirement for independence is defined in AMC1 145.A.200(a)(6) – Compliance Monitoring — General, which states:
"The independence of the compliance monitoring should be established by always ensuring that audits and inspections are carried out by personnel who are not responsible for the functions, procedures or products that are audited or inspected."
— [Source: AMC1 145.A.200(a)(6) – ED Decision 2022/011/R]
This replaces the earlier Part-145.A.65(c) language.
Although "responsible" is not explicitly defined in the regulation, it is generally interpreted to include:
Personnel directly involved in, managing, approving, or supervising the activity, function, procedure, or product being audited.
Authors or approvers of procedures.
Operational managers or line supervisors overseeing the work.
For example:
A person who develops procedures for SMS, training, or maintenance cannot audit those same areas.
A line station supervisor responsible for shift handovers cannot audit shift handover practices at their own station.
EASA does not prohibit combining roles such as Quality Manager, Safety Manager, and Training Manager. However, independence must be maintained when auditing. A Quality (Compliance) Manager cannot independently audit a system they directly manage, such as the SMS or training programme.
For example, if the Quality Manager is also responsible for Safety and Training, they cannot independently assess the effectiveness of these systems. This creates conflicts of interest and undermines audit objectivity.
For small organisations where the Compliance Manager also holds Safety and Training responsibilities:
The same person cannot audit the areas they manage.
Delegate audits to another qualified staff member without operational involvement.
Engage external auditors or consultants for areas with potential conflicts.
Consider reciprocal audits between organisations (noting confidentiality and data protection considerations).
If external or internal alternatives are not possible, document constraints in the MOE, justify the situation, and implement risk mitigation measures such as:
Additional reviews by the Accountable Manager.
External audits for high-risk areas like SMS, training, and competence assessment.
Senior managers must avoid directly auditing areas where they have operational authority. The Quality Manager’s role is inherently focused on auditing, provided they are not performing operational tasks. However, if they are also responsible for SMS or Training, independence is compromised.
Responsibility Matrix: Map audit areas against personnel responsibilities to identify potential conflicts.
Assign audits to personnel without direct operational involvement.
Rotate audit responsibilities to avoid conflicts and promote cross-function understanding.
Ensure auditors receive appropriate training and demonstrate competence.
Use external audits for critical areas where independence cannot be achieved.
Function: Safety Management System
Responsible Manager: Safety Manager / QA Mgr
Auditor: Deputy Auditor / External
Function: Training & Competence
Responsible Manager: Training Manager / QA Mgr
Auditor: Deputy Auditor / External
Function: Base Maintenance
Responsible Manager: Base Maintenance Manager
Auditor: QA Manager
Function: Line Maintenance
Responsible Manager: Line Maintenance Manager
Auditor: QA Manager
Function: Stores & Tooling
Responsible Manager: Stores Manager
Auditor: QA Manager
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