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)
Challenges related to the Effective Assessment of a given organisation
1/ When we consider compliance audits whilst it may be satisfactory the reality is that it is unknown if the compliance will be satisfactory next week or next month.
2/ A shortfall of the compliance audit is that it does not always test either the process or procedures that are developed to deliver the requirement. (As a result, some assumption is typically made on behalf of the auditor.) Whilst often this does not become an issue it remains a weakness.
3/ Compliance Auditing can be misleading depending on the depth of the audit (deeper audits take more time)
4/ When there is a limited time available we should maximise the effectiveness of the criteria – how to do this
a) Focus on the ability of the organisation to assess itself so an audit which focuses on the quality system 70% - 80% and physical business area audit 20% - 30%.
b) Use the audit of the Quality Assurance System to understand how effective the organisations External / Internal audit process
5/ Who is performing the internal audit? / What is their audit competence – how is this evidenced?
6/ What is the audit standard that is being assessed – how is it documented? /How deep is the assessment?
Consider the following statement
i/ The organisation shall have a process to ensure training is provided in respect of XYZ
Audit finding – the process exists therefore it is acceptable
Now consider a different scenario
ii/ The organisation shall have a process to ensure training is provided in respect of XYZ
Comments related to the above - When asked to demonstrate how they were measuring the effectiveness of the training – the organisation was not able to provide an adequate response.
Whilst people are receiving training, the relevant question is does it meet both the objectives and specific needs of the organisation (How is this evidenced)
Real-Life Example of A Shortfall
A Group of 20 staff who had completed an internal SMS course were not able to explain the difference between a hazard and a risk – when pressed it was quickly established that there was much confusion
As a result, this group had essentially received “tick the box” training and the company passed the audit – but is it OK ?....... not!
Taking Steps to Improve Our Audit Engagement Process
What should we look for in addition to our basic Competence Assessment - So in general an audit oversight process that looks deeper at the following will be more effective.
a) How the process is being managed – Means who is managing it and are they trained and competent for the task – How is this evidenced?
b) How the effectiveness of the process is being assessed – Who is measuring the effectiveness of the process & what is the measure employed – Is it successful?
c) How the assessment process is documented – Where is it documented – Consistent Processes need to be written down so that they are understood and shared by all.
d) Where is the physical evidence that the assessment has taken place?
e) Are there examples where a shortfall in the process has been identified and how a corrective action was initiated which is shown to be successful
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