Avisa-ee is a Regulatory Training and Consulting Company who will be pleased to assist you to set up an EASA compliant Part 147 Training School. Based in Sofia Bulgaria we can easily travel to your business site to assist with the initial evaluation or on going developments of your EASA Part 147 Training School.
For more information please click here
Why do we have MRO inefficiencies? At www.sassofia.com we have answers. Or to put it another way YOU have the answers and we will support you through the process of MRO Optimization
The effectiveness of your MRO organisation translates to the bottom line without effective management of the costs and overheads the development and growth of the organisation is impeded MRO Optimisation develops multiple milestones and effective tools to manage the delivery.
Sofema Aviation Services are able to drive the MRO Optimisation to draw on a huge diversity of consultants to provide the support you need to develop the understanding of the challenges and solutions within the organisation
The factors which benefits from MRO Optimisation related to an organisations performance and capability are many and diverse Complex organisational factors come into play from unions to custom and practice to simple basic in efficiencies, often a simple lack vision across the business employing MRO Optimisation can make significant improvements across the business.
Workplace communication which is pivotal to effective organisations is one of the first areas to usually benefit from MRO Optimisation. The importance of leadership needs to be highlighted and the opportunity to use this leadership for motivation of the workshop. Often the organisation does not place enough focus on the development of business simply dealing with today and not paying too much attention to tomorrow. Gap Analysis can identify key improvement areas as part of the MRO Optimisation process
Many organisations particularly the ones which have been around for some time can have multiple management layers which can impede the effectiveness of the organisation. Staff initiatives are stifled and a lack of team work and encouragement is usually evident. Often there is a lack of interdepartmental or organisation procedures and Service Level Agreements
Issues include the management of Competency and the provision of training needed for all staff that have a production exposure are often given insufficient weight which has a negative effect . MRO Optimisation can make a significant difference across the business
Management of Change is always a challenge One of the hardest changes to be made concerns the optimisation of process and procedures within an organisation where this has a direct bearing on the terms and conditions of the employees. MRO Optimisation focuses on the efficient deployment of the available recourses.
If you would like to discuss the ways in which Sofema Aviation Services can support you to develop your maintenance organisation please contact us at office@sassofia.com or visit our web site www.sassofia.com
EASA Part M owes its origins to the days of the Joint Airworthiness Authority where it was to be found within JAR OPS, Since the creation and establishment of European Aviation Safety Agency which was formally established in October 2002 by EU Regulation and now has Executive powers since 28 September 2003, EASA is Headquartered in Cologne, Germany
Part M concerns the operator’s responsibilities in connection with the management of Continuing Airworthiness. Currently National Authorities have an expectation of the general training competencies within the Continuing Airworthiness Management Organisation moreover training in Part M Subpart G training is part of this standard
Transition of arrangements from Joint Aviation Authority and National Airworthiness Authorities have now all completed. Understanding the current situation is fully explored during Part M Subpart G training.
Whilst Part M Subpart G training considers the whole of Part M and its 9 subparts it focuses on the specific needs of the Continuing Airworthiness Management Organisation.
The purpose of the Part M subpart G training is to provide an overview of the initial issue and Revisions of 2042/2003 annex 1 Part M, and to focus in detail during Part M Subpart G training on the following sections. Section C which deals with the implementation of Continuing Airworthiness in particular the Maintenance Program, and Section G which details the process for the effective operator management of Continuing Airworthiness.
EASA Part-M consists of several subparts. Whilst all subparts are covered during Part M Subpart G training The noteworthy subparts are F (Maintenance for aircraft below 5700kg in non commercial environment), G (Continuing Airworthiness Management Organization = CAMO, coordinating the compliance of aircraft with maintenance program, airworthiness directives and service bulletins) – The following details all the subparts of EASA Part M
•Subpart A – General
•Subpart B – Accountability
•Subpart C – Continuing Airworthiness
•Subpart D – Maintenance Standards
•Subpart E – Components
•Subpart F – Maintenance Organisation
•Subpart G – CAMO
•Subpart H – Certificate of Release to Service
•Subpart I – Airworthiness Review Certificate
Differences from JAA
The JAA was headquartered at Hoofddorp, Amsterdam. The main difference between EASA and JAA is that EASA has legal regulatory authority within the European Union (EU) through the enactment of its regulations through the European Commission, Council of the European Union and European Parliament, while most of the JAA regulatory products were harmonized codes without direct force of law. (almost like a gentlemen’s club which each one country was a member of) Also, some JAA nations such as Turkey were outside the EU whereas by definition, EASA is an agency of the EU and other nations adopt its rules and procedures on a voluntary basis. Avisa-ee provides Part M Subpart G training, either at the customers site or from our training premises in Sofia Bulgaria.
During many years of quality auditing in airline and MRO environments, says Steven Bentley, it has become apparent that a well managed, effective Quality System will not just save the organisation money – it may one day save the organization.
A Quality System is Quality Control(QC) plus Quality Assurance (QA)
– QC being the delivery of theprocess and procedures required to demonstrate compliance and QA being the
delivery of the organisational product that complies with all regulatory and company requirements. This should be the lifeblood of any organisation, integrated into every facet of the company. When this is the case, organisations can excel in the delivery of the product or service and are well placed to react quickly and efficiently to any identified shortfall. In addition, an effective Quality System that follows the QC/QA 80/20 rule can deliver significant savings by reducing waste and inefficiencies.
However, many organisations develop what could be considered a bolt on, rather than an integrated solution, and are driven primarily by the need to satisfy the regulator that a compliant Quality System is implemented. This means they miss the opportunity to benefit from the savings which arise from a truly effective Quality System. Even though such a bolt on arrangement often complies with the minimum of regulatory requirements, it usually falls far short of a system that is fully supportive of, and provides tangible benefits for, the organisation.
Responsibility
Who is responsible for quality in an organisation? An answer that is often given is the Quality Manager. This is partially true, but is not correct – the Quality Manager is responsible for Quality Assurance but should not be responsible for Quality Control. There are actually two correct answers. Legally, the correct answer is the Accountable Manager, who signs a statement to the eff ect that he or she accepts responsibility for the organisation complying with not just quality, but also all safety requirements. the other answer is ‘we all are’, which means everyone within the organisation has a shared responsibility to ensure delivery of a quality product. This is an important message that must be communicated to the workforce in a meaningful and eff ective way – a challenge that also highlights the need for effective communication.
The Accountable Manager position is a serious and demanding role, and it is important that there is a strong and eff ective team of competent and knowledgeable post holders to back up quality assurance and safety management to ensure that quality and safety are, or become, fundamental attributes within the organisation. Safety is playing an increasingly important role and Safety Management Systems (SMS) are particularly important in an eff ective organisation. this is especially relevant with the need to demonstrate compliance with ICAO annex 6 Safety Management System requirements, which have become effective since January 2009.
For the delivery of an eff ective Quality and Safety Management System, the more information regarding the organisational compliance status that is available, the morefocused the decision making of those involved will be. However, compliance management becomes difficult without the availability of an electronic oversight system, as a huge amount of documentation needs to be managed. this includes: policies procedures and manuals, both internal and external; showing the status of conformity ona continuous basis; planning, scheduling and recording the performance of audits; developing an approved database of acceptedsuppliers, allowing for a range of audit options from postal audit to continuing oversight; and the engraftation of corrective actions (discrepancies) with an automatic follow up process for outstanding discrepancies.Where does the Quality Manager fit into thisstory? They are responsible for the delivery of an eff ective QA system. Interestingly, therehave been a great deal of regulatory requirements written on the responsibilitiesof the Quality Manager, and far fewer regarding the responsibilities of the post holders to deliver eff ective quality control.
Effective system
To deliver an effective quality system requires a fundamental understanding and a recognition of the differences between QA, QC and Safety Management, and someone who is responsible for delivering the various elements. The key to QC success is to set and manage the company standards, making regulatory compliance an easier goal to achieve. There are three steps to achieve this. The first is the management of the documentation to ensure the procedures are necessary, effective and efficient; the second, but just as important, is the understanding of these procedures by the workforce to include, where necessary, appropriate training; and the third is the management of competencies to ensure the staff are qualified, capable and, indeed, motivated to deliver the process required in an effective way. Unless the organisation has effective control of these elements, it is in effect fighting with one arm behind its back. It should also be accepted that to promote effective QC, the process and procedures must belong to the post holder or line manager, even though the Accountable Manager holds ultimate responsibility. This retains the independence of the audit, but, more importantly, ownership of the procedure is an intrinsic element of delivering effective quality control. The process is overseen by, and is usually delivered through, company controlled documentation manuals, forms and procedures, such as Ops Man Gen Part A, Maintenance Organisation Exposition and Continuing Airworthiness Maintenance Exposition. The role of QA is two-fold. As described, it is to demonstrate that the organisation complies with all regulatory requirements. However, there is a more fundamental role: to share with the post holders and the Accountable Manager the deviations within the system from the company processes and procedures, as well as discrepancies as a result of non-conformity with regulatory requirements.
Some people believe that up to 20% of profit is lost by airlines due to wastage and inefficient procedures. Identifying such shortfalls may not automatically be within the remit of the QA system because it may not necessarily fall foul of any company or regulatory requirements. So the company has to have mechanisms to bring together the QC process, the safety management process and to compare them with wastage, which could be late departures, ground damage, over fuelling or inefficient routeing. Considering that an effective Quality System consists of 80% QC and 20% QA, it is apparent that effective QC is an essential part of a successful Total Quality System (TQS).
TQS
There are three steps to build an effective TQS: capture data and process it in a way which identifies wasteful processes; use this data to drive efficient changes in procedures that will benefit the organisation; and use the Quality Audit System (QAS) to ensure that the organisation is following all processes and procedures correctly. This includes manpower that is sufficient, trained and has its competencies managed; processes and procedures that are documented, effective and relevant; and ensuring that all supporting facilities equipment or infrastructure are appropriately controlled and managed. For an efficient QAS, six small audits in a year will yield far better results than one big audit that might satisfy a regulator. Quality
findings are reported to the responsible person or post holder. This is necessary for the accomplishment of corrective action and to close the loop, but equally important is the measurement of the data to generate a corporate understanding of status and trends: without such data, it is very diffi cult for an organisation to develop eff ective change strategies. this can be accomplished through a monthly presentation of the quality status of the major fi ndings from the preceding month, the current outstanding issues, and the planned audits for next month; forming the essential elements of such a briefing should take no more than 20 minutes. The development of an eff ective QAS should: look at and ensure compliance with regulatory
requirements; look at and ensure the eff ective delivery of in-company processes; and frequently sample the product to ensure it meets company as well as regulatory standards. In addition, an eff ective QAS will carry out a significant proportion of surveillance to validate the quality system.
Integrating quality and safety Quality and safety are first cousins – sometimes the Quality Manager is also responsible for safety, in larger organisations a separate Safety Manager will be found. the role of the safety system is to assess risk and consider the severity of potential issues, and develop appropriate response strategies and to bring this to the attention of the Accountable Manager and post holders. The more data that is available to work with, the more effective the SMS system will be. The Quality System can supplement the data feed into the SMS system, but essentially it should be understood that the quality system is performing audits to ensure the organisation remains compliant with regulatory and company requirements, whereas the SMS system is required to proactively identify potential weak points in the organisational system. These diff erences should be clearly understood by all key individuals.
To bring it all together in an eff ective TQS, an organisation needs to ensure that there is a robust structure with clearly defi ned roles and responsibilities from senior management down. It is important to have clear, concise and appropriate procedures, which are understood by trained and competent staff with managed competencies, and a strong quality audit system to bring to the attention of senior management deviations not just from regulatory requirements, but from company procedures as well. There needs to be a process to measure organisational deficiencies and inefficiencies, and to use the company tools, including the Quality System, to gather the necessary data to analyse and understand the problems and to make appropriate changes within the organisation. Finally, we require a connected SMS system that sits alongside and complements the Quality System. Organisations able to bring this together truly benefi t from an integrated and eff ective Quality System.
Numerous Fuel Tank events over more than 40 years have led to in excess of 500 fatalities.
The biggest by far being the tragic loss of Flight TWA 800.
Avisa-ee provide fuel tank safety training either at our training facility in Sofia Bulgaria or at your own facilities. See www.avisa-ee.com for details of available training courses both in company and open.
After the TWA Flt 800 incident accident investigation the FAA issued Special Federal Aviation
Rulemaking (SFAR) 88, set up committees to investigate – ATRSAC – and issued a number of advisory circulars. Both the FAA and EASA have mandated mandatory Fuel Tanks Safety Training. Within the EU the JAA issued JAA INT/POL 25/12 and JAA TGL 47
Requirement. (Still a valid document within the EASA environment).
Fuel Tank Safety Training is a requirement of EASA Part 66, EASA Part-M and Part-145 regulations, which requires that personnel involved in Continued Airworthiness Management and Maintenance of Aircraft Fuel Systems, are given suitable training appropriate to the job junction either as a -phase 1- “once” only training or as a 1 day -phase 2 – 24 month recurrent training.
IAW EASA Decision 2007/001/R/2007/002/R amended by ED Decision 2009/007/R
24/03/2009. requires Fuel Tank Safety Training to understand the requirement for In Service Management of Fuel System Safety
Amongst the requirements identified organisations will be required to demonstrate:
Continued Airworthiness Management including maintenance program’s, modifications and
Service Bulletin assessments. The Quality Assurance Program will have to include appropriate audit criteria to ensure compliance.
In addition the organisation will be required to develop effective Maintenance Procedures, Critical Design Configuration Control Limitations (CDCCL) management procedures.
Also to ensure training is provided in Inspection and Repair standards.
Amongst the areas covered during Fuel Tank safety training are Maintenance Planning Documents. MOE and CAME procedural requirements.
Avisa-ee Fuel Tank Safety Training includes an understanding of the following:
In-service maintenance of Fuel Tank Ignition Source, Suppression and Flammability Reduction features. Nitrogen Inerting Systems and safety precautions.
Understanding the Training Requirements:
Part-145 Fuel Tank Safety Training applies to Aircraft, Engine and Component Maintenance.
Phase 1 Managers, QA personnel, Stores Personnel, staff not directly involved in Maintenance. Phase 2 Part-145 personnel directly involved in maintenance, maintenance planning and staff involved in developing procedures. Also to be considered is the fact that training to be carried out before any maintenance task is commenced on aircraft or components by the maintenance staff.
Part-M Fuel Tank Safety Training applies to Subpart G approval holders and operators with aircraft with 30 seats or more and/or a payload above 3402 kg. For CAMO and other staff as detailed below.
Phase 1 Quality Inspectors, ARC signatories, Maintenance Programme
specialist managers. Phase 2 Airworthiness Management Staff, Continued Airworthiness Manager, Part M – Subpart G Maintenance staff.
Phase 1 Fuel Tank Safety Training should have been completed in the first quarter of 2009 but in all cases Fuel Tank Safety Training should be completed before the end of 2010.
Lear More About Fuel Tank Safety Training
Fuel tank Safety Training is mandated on both sides of the Atlantic by the FAA and Transport Canada in North America, and within Europe by EASA. European Aviation Safety Agency.
The need for Fuel Tank Safety Training came about in the aftermath of the tragic loss of TWA 800 in 1996, and what was possibly the biggest post crash investigation ever carried out. During the investigations there was a further incident in which a B737 exploded on the ground in Bangkok. Again Causal factors gave rise to the understanding of the need for specific and dedicated Fuel Tank Safety Training.
During the protracted investigations a number of Design shortfalls in the construction of the aircraft came to light particular in respect of the location of the air conditioning pack below the center fuel tank, (probably the single biggest single factor which led to introduction of Fuel Tank Safety Training). EASA have mandated the undertaking of this training by both the Part 145, and the Part M management organization as well as being included in the syllabus of the part 66 ;licensed aircraft engineer.
Avisa-ee www.avisa-ee.com are carrying out continuous in company Fuel tank safety trainings throughout 2010 as well as several open trainings. Avisa-ee trains to the highest regulatory training standards and is accredited by several agencies. The trainings are offered with a multi choice examination to comply with the regulator requirements.
Within the European environment Fuel Tank Safety Training consists of Phase 1 which is a non recurrent requirement for managers and senior personnel to become familiar with the requirements, and Phase 2 Fuel Tank Safety Training which is required to be completed by the end of 2010 and is a recurrent training applicable to persons working directly in the maintenance environment again including Part 145, and the Part M management organization as well as being included in the syllabus of the part 66 ;licensed aircraft engineer.
Fuel Tank Safety Training specifically looks at relevant issues such as ALI Airworthiness Limitation Items and CDCCL Critical Design Configuration Control Limitations and ways in which these elements need to be managed.
A survey carried out by the UK CAA found that over a number of years nearly 20% of maintenance related fuel tank reportable incidents were caused by maintenance error. Because of this it is not intended that Fuel Tank safety Training should lead to increased activity within the tanks, however that it should identify ways of working which promote safe and effective management of the Fuel tank environment.
If you would like to find out more about the availability of Fuel Tank Safety Training in your own organization please email office@avisa-ee.com or visit us on line at www.аvisa-ee.com
Learn More about Fuel Tank Safety Training
“Today’s milestone agreement marks the first time the global aviation community has come together to work on a global safety information exchange. Data must drive our actions so that we can focus our joint efforts on reducing the greatest risks,” said Giovanni Bisignani, IATA’s Director General and CEO.
Audit data will be a key element in the project. IATA, ICAO, the FAA and the EU conduct audit programs that collect complementary safety information. “We must understand safety trends, not just from the handful of accidents each year, but by bringing together and analyzing data from millions of safe flights. With this we can take more effective action to reduce risks and improve safety performance,” said Bisignani
The 2009 global accident rate, measured in hull losses per million flights of Western-built jet aircraft, was 0.71. This is a significant improvement of the 0.81 rate recorded in 2008. Compared to 10 years ago, the accident rate has been cut 36% from the 1.11 rate recorded in 2000.
Audit data will be a key element in the project. IATA, ICAO, the FAA and the EU conduct audit programs that collect complementary safety information. “We must understand safety trends, not just from the handful of accidents each year, but by bringing together and analyzing data from millions of safe flights. With this we can take more effective action to reduce risks and improve safety performance,” said Bisignani.
“There is no competition when it comes to safety. Cooperation is the way forward. We have a common goal of zero accidents and zero fatalities. The safety data from audits and oversight programs contains important parts of a whole picture. Agreeing to put this data together is a major step forward,” said Bisignani.
The four organizations will now start work on a way to standardize safety audit information and ensure compliance with local privacy laws and policies. This is targeted to be completed within 12 to 18 months.
Safety is no accident
Avisa-ee provides training in Safety Management Systems training for organisation executives and SMS Managers.
For details of the training please see the following link
Based in Sofia Bulgaria Sofema Aviation Services offers a wide range of services to the Eastern European Aviation Community , within both the Airline OPS and MRO environments. We are independent and provide support, consulting and training across all areas of the business from Post Holder through Quality and Safety to Flight Operational areas. Our Aviation Services are complemented where necessary by our associates to ensure we are able to maintain the necessary skill level and expertise.
Sofema Aviation Services has a straightforward mission -To deliver reliable, quality focused and flexible service on time, every time.
Through the cooperation with Avisa-ee, Sofema Aviation Services are able to offer a substantial range of open, regulatory training courses. Sofema Aviation Services also offers many specialized courses in specific areas of the Aviation Environment. We have a flexible resource which can usually assist in providing a bespoke training specifically tailored to your companies needs. In-company trainings can usually be arranged to be flexible and to meet your operational needs.
With a full service expertise MRO Consultancy Services we are able to We provide full service expertise to address every aspect of your MRO project. With optimised support based on your budget and your implementation requirements we can deliver many flexible options in some cases we can minimize overall implementation costs by utilizing your own resources.
Sofema Aviation Services supports Airlines and MRO’s with Technical Management Supply Chain Personnel and EASA Qualified Certification Engineers, either on a contract basis or as permanent employees. The challenge of managing contract staff is very specific and we assist with implementation in the most effective way for your organization.
Sofema Aviation Services currently support a number of IT solutions for the Operator and MRO Because of our independence we are able to be selective concerning products we are willing to support.
Sofema Aviation Services SAS provides a service to its clients and associates to qualify Language Proficiency pass grade for Aviation English Competency.
In particular to confirm that the candidate qualifies at the level of ICAO level 4 or above which is the minimum standard to operate either as an Air traffic Control Officer at International Airports or as a Pilot Flying Commercial Aircraft on international routes.
Sofema Aviation Services is pleased to provide direct and indirect support to the following areas of your business – Safety Management System, Quality System, Operations Environment, Maintenance Environment, Audit Support Services, Quality & Safety Audits.
Sofema Aviation Services is able to support you in configuring you ERP Emergency Response Plan. With extensive experience gained over 2 decades of working within the civil aviation environment we are able to work with you to analyse, develop, document, train and test your emergency procedures within the Operational and Human Environments.
EASA has mandated that fuel tank safety training is required for certain groups of maintenance staff. Why was this decision made ? The reason why is described in this article essentially driven by the need to address inherent centre fuel tank safety shortfalls.
What are the implications for operators and maintainers ? The need to have appropriate procedures and in company training is addressed through the Medium of Fuel Tank Safety Training. This required fuel tank safety training is mandatory of all staff who work on aircraft which carry more than 30 passengers or the equivalent size of Cargo aircraft.
What are the time scales involved ?. Essentially the compliance for phase 1 (management staff) has now passed. The compliance for phase 2 staff which includes all maintenance engineers is Dec 2010. Fuel Tank Safety Training including the recommended EASA examination will satisfy the obligation of both Part 145 and Part M organisations.
What does it mean for me as an operator or maintainer ? As an operator you should be satisfying yourself during audit that the Part 145 organisation fully complies with both the regulatory requirements and your Part M requirements. ( A hugely important element). As a Part 145 organisation you should satisfy yourself that you have appropriate Maintenance Organisation Exposition MOE Procedures, Competent and trained maintenance staff to comply with all the regulatory requirements, including the need for recurrent Fuel Tank Safety Training.
Understanding Health and safety issues associated with Nitrogen Enriched Air NEA is also an essential area for the Part 145 Maintenance organisation to manage.
Fuel Tank Safety requirements have come about after probably one of the most comprehensive assessments ever made following the tragic loss of TWA Flight 800 with 212 passengers and 18 crew. TWA Flight 800 crashed at 20.30 on July 17 1996, due to an In flight break up caused by an explosive failure in fuselage. Whilst Initial investigation focuses on terrorism after some 6 months of investigation terrorism was discounted or indeed an external explosion.
The causal factors were attributed to a Fuel tank explosion which itself was induced by system failures.
The investigations surrounding the accident led to many basic design and certification assumptions about installed fuel tank system safety to be substantially revised.
The events following the investigation into the causal factors surrounding the TWA 800 event created something of a shock for the industry, until this time it was not understood that the heated centre fuel tank actually led to a lowering of the safety standard to a level below that which was deemed acceptable. Obviously this was a situation which had to be addressed at the highest levels.
The connection between the discovery of the criticality of the Centre wing Fuel Tank Installation and fundamental design and certification assumptions ultimately had a major impact on in-service continuing airworthiness management and maintenance of aircraft. A global review across many different aircraft types of in-service fuel tank safety data demonstrated that fuel tank safety does not meet acceptable safety standards. It subsequently became apparent that steps had to be taken to redress these issues. Fuel Tank Safety Training is one element of these activities.
One example of a particular outcome was the need for management of the fuel tank related maintenance requirements and associated activities which have become known as CDCCL Critical Design Control Configuration Limitations. The comprehensive understanding of this is addressed during Fuel Tank Safety training.
CDCCL requirements have a direct bearing on the activities of the Part 145 maintenance organisation and the effective oversight by the operators Part M organisation
TWA 800 was not the only incident related to fuel tank safety, There have been a number of Fuel Tank Safety related issues over many years of commercial jet operation. In 1990 on the Ground in Manila Philippines a Boeing 737 belonging to Philippines airlines exploded, due to events surround the Centre Wing Tank, and again in 2001 a Boeing 737 belonging to Thai airways also exploded on the ground at Bangkok airport. The cause was attributed to an explosion in the Centre Fuel Tank Heating of the centre wing tank to temperatures that were higher than anticipated during design were apparent at an early stage, however the actions to be taken to mitigate the safety case were not immediately apparent. The understanding that one of the fundamental issues Heat transfer from externally mounted Air Conditioning Systems (ACS) was not only a large contributor to an explosive condition.
But was something which was going to be extremely difficult to address. A series of trial flights flown to replicate the TWA 800 final hours establishes CWT internal temperatures as high as 145f.(63’C)
Avisa-ee Fuel Tank Safety training which is normally delivered “In company’ address all regulatory issues associated with Fuel Tank Safety and satisfies the mandatory training including examination recommended by EASA. www.avisa-ee.com
office@avisa-ee.com