Maintenance Planning Document (MPD) – The MPD is essentially generic across a particular fleet, is issued by the aircraft manufacturer, and applies to many aircraft, it is not customized and several (hundreds of) tasks are dependent for example on the aircraft modification status and its serial number.

It cannot under any circumstances be considered as a final list of tasks for a given tail number.

Aircraft Modification Status – The applicability of multiple tasks may be affected by the aircraft modification status. (The MPD may list a task as “pre-mod” or “post-mod”.)

To correctly set the tasks we must know the mod status of the aircraft to know which tasks are applicable and should be carried out.

Also, the aircraft may have custom modifications embodied, which often come with their maintenance tasks. (Via Supplemental Type Certificate (STC) controlled by Part 21 Subpart J Design organisations)

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 basic 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;

Compliance Auditing brings with it the daily challenge of ensuring that the organisation remains at all times fully compliant with both internal and external obligations.

The Audit Management, Control, and Oversight system should ensure that the established safety and quality procedures are fully complied with.

In addition :

a)     To plan and deliver audits

b)     To review findings

c)     To perform root cause analysis and develop additional actions where necessary (under the specific control or guidance of the business area owner of the post holder)

In an effective Quality Management System QMS monitoring is a continuous process. It is essential to ensure robust and continuous oversight of all internal processes, and procedures.

Let’s consider the difference between Assessment & Audit

Assessment

The evaluation process is used to measure the performance or effectiveness of a system and its elements.

Our goal is to assess the auditing process follow-up to determine both the cost-effectiveness and overall value to the business.

Audit

An EASA Audit is a systematic and independent examination to determine whether quality activities comply with external regulatory requirements and internal organisational specifications and whether these specifications are implemented effectively.

A primary indicator of a poor or failing system is repeat findings or findings which should be addressed at a lower level – for example, the Competent Authority should not identify problems that are normally expected to be found within the internal Quality Assurance System audit process.

The ability to successfully identify and address the root cause is not a given and like many activities benefits from improved knowledge experience and development of individual competence.

Typically it is only by monitoring over time that we can confirm that the mitigations that have been developed as a result of analysed root causes have done the job. However, we can draw a conclusion based on our understanding of the analysis and actions that have taken place to assess if we have confidence in the steps that have been taken.

Any shortfall in expectation could for example cause the finding to be re-opened for additional analysis.

Some of the reasons that the true root cause has been miss identified are considered here :

a) Root Cause Analysis (RCA) based on assumptions rather than on objective evidence. It is essential to ensure that all data is accurately classified and clearly understood concerning the observed facts.

Please consider that just because a product meets for example compliance with ISO 9001-2015 objectives does not automatically mean it is safe. (Just as not having an accident can be taken as meaning that we will not have an accident in the future.)

In reality, the key aspect becomes our ability to measure risk and exposure. Quality systems audits consider gaps related to compliance with both external regulations and internal organisational processes and procedures.

Quality Assurance and Risk Assessment

The first point to make is that the term “risk” is subjective whereas the role of an EASA regulatory-driven audit is to assess compliance with a standard, not an opinion so this creates a challenge.

So when a discrepancy is identified it creates several questions

Why should we wish to measure the performance of our Compliance Audit Process?

Essentially for 2 reasons:

1/ The first is that we have an organisational obligation to ensure both regulatory and organisation compliance and of course, there is a cost for this – so the question becomes is the organisation receiving value for money?

2/ The second is because there is a cost associated let's call it a return on investment – if we invest more will we return more- without a measure, we will not be able to understand this.

The Internal Audit function predominantly exists as a mandatory process to ensure and demonstrate compliance and is also able to focus on improving business performance and adding value by supporting strategic business objectives.

Management communication of the various shortfalls related to the audit findings should be strong and consistent and be demonstrated to have a contributory impact on a culture of compliance within an organization

Except for EASA Part 21 Subpart J "Design Organisation Approval" which as will be aware is managed directly by EASA the process for all other approvals (Air Carrier – Part 145 / Part M / Part 147 / Part 21 Subpart G POE / ATO) essentially works as follows:

Achieving Regulatory Approval (Simplified)

1/ The organisation demonstrates to the Competent Authority (CA) that they satisfy the pre-requisites to be granted the requested approval

Documentation / Facilities / Manpower / Competence / Finance / Oversight

2/ The Accountable Manager of the Approved Organisation signs a statement to confirm his or her responsibility related to ensuring sufficient finance is available to maintain full compliance

3/ The Organisation must set up a process (Independent Quality Assurance) to ensure continuous compliance

4/ The CA periodically assesses the organisation for continuous compliance and raises findings for any non – compliance (Level 1 or 2 as appropriate)

Analytical Techniques (RCA Tools)

“Five Whys” Approach

The “five whys” approach. By using this approach, root cause contributors can be identified along with the antecedent events, and potential mitigation or prevention strategies can be suggested based on the answers.

Once the initiating problem is specified, a consecutive series of “why” questions are asked, with each answer becoming the subject of the next question.

Note that with each response, not only does a deeper investigational dive occur, but opportunities for implementing mitigation strategies are highlighted.

Ishikawa Fishbone Diagrams

A fishbone diagram, which is essentially a cause-and-effect diagram provides for a graphic representation that categorises the potential causes related to a problem to identify the root causes.

The process of understanding the causal elements including the various Root Causes is a subjective process – which means it can be influenced by personal behaviour. 

It is important for the reason that we should take careful steps to ensure that we have the necessary skill level and competence in the persons or teams who are responsible for the evaluation process. 

Team Composition

Any team that is assembled to consider Root Cause must have the appropriate skill set and knowledge of Investigative Methodology. Background Knowledge and understanding related to Parts, Materials, Processes & Human Performance as required should be present as required.

Note the importance of ensuring Management Commitment to be successful in any given investigation the lead investigator and team members should be given

management backing to pursue the root cause in the most effective way

Within our Aviation system, both Quality and Safety Management systems have shared common values. To be effective they both have to be planned and managed and provided with appropriate resources. In addition, both aim to involve every relevant functional element within the organization and indeed, both processes strive for continuous improvement. 

Root Cause is Root Cause you may correctly say! So how can there be a difference between Quality Management Systems (QMS) Root Cause and Safety Management Systems (SMS) Root Cause?

Let's first consider the Different roles of Quality & Safety.

Quality is looking at Compliance (It has happened!).

Quality systems tend not to consider the role of risk whereas of course,e this is a fundamental tenant of the SMS system.

The Quality Management System (QMS) remains however the primary means of ensuring that the organization is meeting requirements (Ensuring Regulatory Compliance) and continuously improving its processes.

www.sassofia.com considers the complexities of Root Cause Analysis (RCA)

To be effective in reducing negative events we need to understand how we can use various analytical techniques to first understand and then to mitigate the actual as well as potential exposure.

The root cause analysis (RCA) method uses a cause and effect approach by asking (For example) multiple "why" questions as an effective way to identify one or more low-level elements that contributed in some way to a subsequent failure.

With sufficient information available we can develop some corrective actions that should directly impact the exposure and which if taken correctly should prevent failure in the future.

Direct cause is defined as “the cause that directly resulted in the occurrence.” This would be like the person who whilst following a standard operating procedure (SOP) makes an “error” which results in an adverse outcome.

So therefore we can say that the person’s error is the direct cause of the problem that occurred.

A Supplemental Type Certificate (STC) is an FAA  or EASA-approved major modification or repair to an existing type certified aircraft, engine, or propeller. As it adds to the existing type certificate, it is deemed 'supplemental'. As its name suggests, an STC is a certificate. It defines the product design change, states how the modification affects the existing type design, and lists the serial number effectively. It also identifies the certification basis, listing specific regulatory compliance for the design change.

An STC is a supplemental type design approval for a major alteration specific to a make and model or even a specific serial number as a one “off” STC

The STC Holder – STCH remains ultimately responsible for the certification of the modification.  An STC is a design approval, however it doesn’t allow the holder to produce anything. (typically created by Part 21 /FAR 21 Subpart J Organisation Design Approval Holder (DAH) Design Organisation Approval (DOA)).

Note - The STC, which incorporates by reference the related Type Certificate (TC), approves not only the modification but how the modification affects the original design.

The application must be made in the form and manner prescribed by the FAA  or EASA.

SofemaOnline.com Provides EASA Compliant Regulatory and Vocational Training when you need it at your own pace. We provide an ever-growing portfolio of online training courses and combination packages for example

Operations Regulation 965/2012 package, EASA Part M package & EASA Part 145 Package.

What sets SofemaOnline apart?

Quite simply we bust the myth that regulatory compliance is the objective!

It is not – compliance with the regulations is in reality minimum compliance, It should be a given, not an objective- as Industries leading training organisation with 45 years of background our focus is on the effective delivery of the business process.

Our training courses are based on and compliant with EASA, FAA, ICA,O and other Standards as applicable and focus on a practical interpretation of the regulations (which is not necessarily the case with our competitors)

One of our major focus points is on delivering competence in the workplace

Whilst we all recognise the importance of safety in particular within “our” Maintenance Environment we face as an industry the problem of (Some say) Chronic underreporting of safety incidents.  Please consider when was the last time YOU filed a safety internal report.

What is the reason?

Is it the fear of reprisals or is it a case of fundamental disconnection from the responsibility to accept a personal obligation to report?

Whatever the reason the reality is that there is without doubt insufficient occurrence reporting, which results in “open” not closed loops ineffective closure, and a reduced ability to deliver proactive safety improvements. (If at all !)

EASA has introduced a new EU Occurrence Reporting Regulation which is one key step in this direction as it sets a new framework to encourage and protect safety reporting by aviation professionals.

The Regulation (EU Reg. 376/2014 became applicable as of 15 Nov 2015 and requires aviation organisations in the EU to both adopt and maintain a proactive Just Culture to facilitate the collection of key safety data and information and to protect the reports as well as the information.

I want my Aviation Organisation Staff Training Program Managed online! - Now I know that SofemaOnline  www.sofemaonline.com (SOL) manages specialty training on behalf of Aviation Organisations just like ours!

What's on offer?

Your own Company Aviation-centered Short Course – Developed for you and Managed online by www.sofemaonline.com

Providing as much or as little support as you need, is The cost cost-effective way to manage your online training needs. SofemaOnline (SOL) courses provide the perfect opportunity for your employees to explore areas that will underpin their understanding of roles responsibilities and competence-driving elements.

SOL courses have been shown to improve job performance and motivate your employees to engage in effective learning in a short period of time.

With online training, our courses are suitable even for individuals and new starters. Introductory short courses can be a perfect way to ensure that new starters are up to speed and have the relevant awareness of regulatory requirements and the company.

www.sofemaonline.com offers the perfect solution

Sofema Aviation Services (www.sassofia.com) and SofemaOnline (www.sofemaonline.com) Providing Guidance and Understanding Regarding Classroom, Webbex and Online EASA Compliant Regulatory and Vocational Training Courses.

Sofema Aviation Services (SAS) and SofemaOnline (SOL) have built up a portfolio of training courses that will by the end of 2018 number more than 500 Courses.
We are increasingly receiving requests for guidance as to the choice of the most appropriate course to take for a particular person or role within the organisation.

To provide an answer without a detailed understanding can be somewhat challenging as often the appropriate level of training depends very much on both the ultimate objective as well as the current knowledge level of the delegate.

GCAA says now –EASA Says Later! ICAO says 8 years ago (2009)

Sofema Aviation Services (www.sassofia.com) considers the current status of SMS within an EASA-compliant Part 145 organisation.

What is SMS?

Sure we all know what is a Safety Management System (SMS)

But consider the two options:-

a) Safety Management System focused on ensuring “Mandatory Compliance” with all Safety Objectives

b) Management System focused on developing in an effective way optimized for efficiency and delivering all Mandatory Safety Objectives

This Blog looks at a basic understanding related to Part 66 Basic Examinations

 Introduction

 Examinations are conducted under strict examination conditions; all basic examinations shall be carried out using the multi-choice question format.

Be careful and always read the question!

The incorrect alternatives shall seem equally plausible to anyone ignorant of the subject. All of the alternatives shall be related to the question and of similar vocabulary, grammatical construction, and length.

In numerical questions, the incorrect answers shall correspond to procedural errors such as corrections applied in the wrong sense or incorrect unit conversions; they shall not be mere random numbers.