audit preparation

An aviation school under EASA 147 will be subjected to at least an annual audit. As such the audit preparation is very important. Many may be wondering, including the management and the staff of a 147 school, what to do to prepare for the audit. This is mainly caused by the misconception that audit and quality is the concern of quality department. In reality, in is the opposite, it is an issue for everyone, especially for the managers in production units (or training for 147 organisation)

Definition of Quality

There is a slight different between the ISO system and the aviation counterpart. For ISO, the customers is of pinnacle important, so the quality will relate to customers satisfaction, whereas the Civil Aviation will be more on meeting the requirements of the regulations.

Sources of the audited elements

What are the process or procedures to be audited. We may track the flow of the actual regulations and the sources of the important procedures and processes.

The local authority in Malaysia is following the EASA system. The requirements are republished with some changes to adapt to the local needs in 2 documents, AN 1201 on the training organisation and 1101 on the syllabus.

A training organisation is required to have his own MTOE, Maintenance Training Organisation Exposition, with the policy and processes to show compliance to the local requirements.

Under the AN 1201, the main headings includes...

1. facilities requirements - It gives a broad requirements which can be open to interpretation. The classroom must be conducive for learning, good light, low noise level etc..

2. Under personal requirements, it mentions about the needs to have the accountable manager who will have the resources to enable the training quality is observed. There is the need to have the management team to ensure compliance to the regulations.

2a. The requirement on instructors, examiners and assessors - qualification and maintenance of skills and knowledge.

3. The Process include, how you select your trainers and keep them current. It will include the selection of students and the training and examination processes.

Expected Audits Proceeding

We can divided the audits into 2 groups:

1. The initial Audit - This is normally a thorough audit to enable the organisation to be qualified for the 147 status. It should cover the major processes and at least complete a cycle of the product.

For example:

a. It will include the elements of 147 requirements qnd the part 66 requirements.

b. It will include a batch of students - for the intake to the graduation, including how the trainings were planned and implemented.

Conclusion

As mentioned earlier, the approach to audit is different from ISO and the Department of Civil Aviation. The ISO will definitely concern about the business and the products, but Aviation is too focused on process compliance, so it is possible to have a 147 school with tip-top processes BUT not producing the qualified students.

External Audit Second Day

As I had mentioned yesterday, our training school is subjected to an external audit. It is a normal procedure to be audited. It is one of the way to maintain the standard and quality in the aviation sector.

Today is the second day of the audit. We are continuing from what we had left yesterday. Yesterday the auditors were working on the documentations, and today, they are physically checking on the facilities and the implementation of the procedures and processes.

The followings are the areas of audit...

a. Technical Library

The technical library are the place where the reference documents are kept. It is necessary to maintain a suitable and functional library in view of the needs of the documents for training.

... the notice from our local civil aviation authority says... i) A library shall be provided containing all technical material appropriate to the scope and level of training undertaken...

The audit revealed many problems. The water leak at the windows left the room stuffy and smelly. I think the leak problem was known well in advance, but the solution may not be satisfactory. A raised wooden floor with carpet was installed, now they are showing sign of rotting. The other issue is the control, books appeared to be borrowed and not returned.

After the library, the auditors moved to workshop. The engines, the electrical workshops and the hanger is covered. Overall, the auditors are happy, there were some comments and some tools not available, for example, the t-bat for the sockets, the easy-out tools to removed the damaged screws.

Then we moved to the examination strong rooms. There were some comments too. The no entry sign was put, but we need to put another sign to show who are approved to enter the room.

The audit completed at arounf 1700 hours. The they spent some time to write the findings and we were set to close at at about 1830hrs

Our External Audit

One of the activities that has to be taken by an aviation training school is to be subjected to the external audit by the authorities. It can be audited by it own quality department, an airlines or a client, or the airworthiness authority.

We wanted to market our product to another country, and the clients, being international airlines, need to get the green light from its airworthiness authority. With the approval of the country's authority, our courses can be sold to another country.

Three auditors came from the country, two from the DCA, or department of civil aviation and one of the client airline.

The preparation was made months in advance. A welcoming dinner was arranged on the night before the event at a local restaurant. There were 10 or us and 3 auditors, the CEO, the SGM, Training Manager, The School Manager, Quality Manager, Executive, Ceo officer, two drivers and another Dato' came. It was a oversized gathering at the expense of our hard stressed company. The food was ample followed by the local delicacy of the king of the fruit, durian. It was about $750 for the total.

The next day, the audit started. The opening was suppose to be at 9 am, the auditors came late about 930 am, and the CEO and SGM were much later. So the auditors had to wait for the them, something that I thought was of of place.

The audit started by the opening remark by the CEO, giving some overview about the company and the vision, followed by opening remarks by the quality manager giving more details about the structure and the awards acquired by the company.

Then it was given to the auditor to start the external audit.

It had been the practice to audit the company exposition, a policy and procedure manual giving the details of how the company is operating. However as opposite to a normal ISO audit, we are guided by the EASA documents of part 147 and part 66.

The first day audit had uncovered many areas of improvements, some are about processes where were not documented, while others about proving that we followed the processes.

Basically this is how it works...

a. The part 147 and 66 give the requirements on how to run an aviation school and what syllabus to follow.

b. The school has to write a manual to comply to the requirements. There are more documents required.

c. The school has to be operated based on the school's manual

The auditors will check on section b above... questions, is the manual comply to the requirements. Then they will check.. is the school operated in accordance to the manual.

Tomorrow will be another long day, the external auditors will be visiting the premises.

Getting a new batch of students

We will be have a whole day session tomorrow, Thursday 22 Dec 2011, to meet our potential students. Following the interview, a couple of hundreds had applied.

This is what had been set for tomorrow...

a. A briefing session about the job in aircraft maintenance engineering.

b. The assessment session

c. The interview session.

A. The Briefing

This will be a sale talk. Basically we want to tell the parents as well as the students that there is a good future in the career of LAE, licensed aircraft engineer. They can choose to work in this country as well as overseas. The EASA licensed obtained will have the global recognition.

Then we will talk about the licensing system itself. This may be able to explain the misunderstanding by some quarters, about the career of aircraft engineer.

B. The assessment session.
This is checking four areas, the english language, the mathematics, physics knowledge and logical skill. A multi-choiced questions will be given to the students.

C. The interview will judge the language skill, the motivation and interest as well as the ability to pay.

We were hoping to get 3 class or 60 students.

UPDATE...

That was an interesting session. About 68 potential students came and if you add the parents and friends, there was about 100. So we did a group interview, and there were a total four concurrent interviews.

The efforts to get new students will be a continuous efforts. We will be doing it every 6 months.

Getting English Instructor

The ICAO requirement is very clear on the education requirement to become an aircraft engineer. It is the ability to read and write English.

I can imagine the difficulty faced by the peoples involved in drafting the requirements, as it had to satisfy the 100 over countries. If I were a British, I may like to put the "O" as the minimum requirement, but that may be accepted by the Russian or even the France. So to be safe, no education requirements were put. However each of the country can insert his own requirements.

In our school for aircraft maintenance in Malaysia, English is a core subject. It becomes necessary as english is not the mother tongue and neither it is the language in the education system. So most of the students are not able to express themselves and the understanding of the technical instruction is limited.

The teaching of English is given in the first semester. The total of 400 hours is dedicated to the subject. This is enough to give the student the skill and the confidence to communicate. This is important as the new EASA system is done in the modular format, as the first module, mathematics is conducted in a short period of 3 weeks, then the students will sit for the first module.

.. to be continued..

Visit To Dilog

Dilog is one of the five approved maintenance training organisation approved in Malaysia. It is a relatively new company, established in collaboration with MAS, Malaysia Airlines to venture into the training of airforce personnel in Alor Star.

Dilog had the profitable business of airforce training for about 8 years, when he lost it to MATA, another company owned by ex-airforce personnel. Dilog had diversified its business to become the contractor of MAS and trained the corporate clients of MAS. At one time, it was going the training for the basic courses for MAS.

The company is located at Subang Airport, now renamed as Skypark. It is using the whole building of old MAS Electrical and Avionics workshop. It is on the airside at hanger one, so the access is controlled by the airport authority.

I had made the appointment to see my friend at Dilog. The process of getting the pass can be lengthy. I had to go to the MAB (malaysian airport authority) security office at the skypark terminal to pick up the door pass. But I need a letter from Dilog. So at 0930 I reach at the security, but unfortunately the letter from Dilog was nor given to them.

At last, I got my pass and I decided to walk to the office. I left my car the airport parking, which later cost me rm7/= . We talk about Aviation School, and his vision of running the school. He was on his high mode, talking about his high expectation on his staff. I casually as him to elaborate on what he mean by high expectation, and I know for, the answer may not be as easy as saying it. The reason is simple, the term high expectation is a emotional description, the answer to what it really mean is from the cognitive domain, and need to be given in process description.

Dilog is proud to be the first school in Malaysia to obtain the full EASA approval, Categories A1, B1 and B2. It also have the approval to conduct Assessment exam.

About the assessors, my friend mentioned that every students has to do 80 orals. So I asked, what was the oral about, is it focused on practical or knowledge.

marketing in Bangladesh

Our company is going full steam to market our product. We are eyeing the Bangladesh market for the B1 and B2 courses.

A team of 4 marketing went on Friday 9 Dec and returned on 12 Dec. Our partner in Bangladesh had made the arrangement to advertise for the potential students, so our team is set to conduct the written assessments and interview.

The result is frustrating. There were 40 responds and out of which only 10 came for the assessment.

It was a trying experiences. We were stretching our head trying to find out the reasons for the low performance. "Why was it so?". Talking to those who came, we can only suggest some of the reasons:

a. Possibly we had wrongly target the wrong segment. The poor population are definitely unable to effort it. So we target the rich population. However it seem that the rich are mainly business men, and as far as they are concerned, their children will inherit the business, so they are trained in business related studies, and not aircraft maintenance.

b. we may be in a hurry, we are not even sure of the school calender, and when the selection of course of study are made.

marketing Sri Langka

It had been more than 1 month since our team was in Sri Langka doing its marketing show. On his return from Sri Langka and in the brief, things appear to be extra exciting and promising. The team was making instant MOU to cater for the "demand" from the customers in Sri Langka.

They were talking about 100 students in Jan 2012, and the implementing team was getting worried about meeting the demands.

Now that it has been more than one month has passed, the mode is getting more realistic.

May be there will not be any student after all.

The the marketing team is getting worried, where is the students?

Why worry, let us try Bangladesh.

So a team of 4 was sent on Friday 9, and back on Monday 12. Mission, to get students from Bangladesh. Are we ready for them? The answer is likely to be no.

Getting a student is a long term effort. I dont thinh you can get the student by a short 2 or 3 nights efforts. There dont seem to be any plan for marketing, it is like operating decision were made based on the gut feeling.

Ideally, there should be a marketing research to identify potential market, forecast the demand and the competitors and draw the marketing plan.

ADMAL Aviation Colleage

One of the colleges that offers aviation course in Malaysia is Admal College located near KLIA airport. The college was formed through collaboration with MIAT, or Malaysian Institute of Aviation Technology, who had became part of University Kuala Lumpur.

About MIAT - Miat was an independent school established to build up manpower competent in aircraft maintenance and manufacturing. With the government vision to establish the Kuala Lumpur university, MIAT was renamed and the training focus was changed to tertiary education rather than vocational.

Admal offers 2 of the MIAT diploma programs:

- Diploma in Maintenance Technologies - Airplane Maintenance

- Diploma in Maintenance Technologies - Avionics

The courses are conducted in 3 years or 7 semesters plus 6 month industrial training. The subject taught is designed to meet MQA, Malaysia Qualifying Agency that approved the courses for Malaysia Private colleges and universities.

Based on the subject taught, it is not exactly aligned to DCA or EASA part 66 requirements.

The subjects for part 66 are as follows:

module 1 - maths

2- physics

3. Electric

4. electronic

5. Digital Techique

6. Material

7. Maintenance Practices

8. Basic Aerodynamics

9. Human Factor

10. Air Legislation

11. Aircraft Systems

15. Engine

17. Propeller

Looking at the subjects covered, it is difficult to say that the course covered the EASA requirements. It certainly will not cover the practical requirements.

Organisational Structure for 147 School

If you are running a maintenance training school under EASA part 147, one of the issue will be setting the organisation structure.

The Thought In Organisational Design

On what basis do you organize you organisation?. This may not be such a simple question, and whatever approach you take, always bear in mind that it is not perfect. The approach is always situational and we are in constant efforts trying to optimize our existing structure, resources and processes.

I tend to favor the simple process model in the thinking process of developing organisation structure....

Input -------> Process ------------> output

Looking at this simple process model, the organisation can be organised based on:

a. The customers - We can organise our structure based on different customers, for example, the military, the civilian or different groups such as company A, company B or company C.

b. Based on the outputs - we can structure with grouping based the courses that the students do. A group to handle category B and another group to handle category A courses.

c. Base on the processes - Looking at the process alone, there are many options open. We have opted to divide it according to:

- Training and assessment - the separation of training and assessment is in line with the DCA requirements. Training is under Training Manager and Assessment is under Quality Assurance.

- The training is grouped under competency grouping. ( the other option is by training processes or classroom/workshop ). The grouping by competency grouping will provide the distinct advantage of optimizing the competencies delivery to the students.

THE CONCEPT BEHIND OUR STRUCTURE

1. We want to be customers' focused - For that reason we have different group to handle the MOE, DCA qualification and military. The head of each group reports to Training Manager.

2. Each of the group, for example the DCA MATA school will be divided into competency groupings, Engines, Airframe, Avionics and General Study. The MOE school may be structured differently.

3. Each of the competency grouping will need to develop both the teaching of knowledge and practical works. The measures and expectation need to be outcome driven. That mean the airframe groups is tasked with the expectation to get the students proficient in airframe competencies and the mean of measure is the DCA exam.

(we could easily focus on process efficiency, focusing on delivery quantum of measures. This method will lead to process efficiency and may not produce the outputs that we wanted).

TYPICAL STRUCTURE BASED ON THE CONCEPT

(Actual Structure is still under Discussion)

POSSIBLE DESIGN OBJECTIVES

In designing the structure we may like to keep some objectives. For examples:

a. Equitability - There need to be a way to related one position in one organisation to to its sister company.

An instructor at MATA DCA school need to be related to an instructor at MOE school. Relate does not mean equal, either in pay of opportunities.

b. Efficiency - In organisation , jobs are done by groups, and it is rare to have organisations design according to work process. However to be efficienct, the groups need to be able to handle the processes smoothly.

c. Accountability - This is important for process improvement. When we measure the outputs, we can identify where the shortcomings are, and improve accordingly.

Looking for English Language Trainers

The country's civil aviation authority, the body that manage the running of civil aviation including the airlines, put a very minimum requirements to be a student of aircraft maintenance engineer. In fact the quoted requirements is in relation the English language proficiency.

Being a non english native country, the training of english language is necessary. This is in fact a necessary requirement because the technical documentations such as the training manuals, the maintenance manual and the wiring diagrams are all written in english intended for native speakers.

We had divided the course delivery unit into 4 areas:

- engine group

- airframe

- avionics

- general studies

Each headed by its own unit head.

General Studies

The general studies unit will deliver trainings for English, Mathematics, Physics, human factors, air legislation,

The main contents will be english.

To meet the requirements, we were looking for s suitable trainers to conduct english courses. It will be more of english for specific purposes, focusing on aviation language. However the fundamental is still the general english. The students needs to demonstrate the basic skill in english communication before they are put to english for specific purposes.

The requirements to be an Knowledge Instructor

EASA system had totally changed the way the aircraft engineers are qualified. In the earlier system, the local civil aviation authority us responsible to conduct the examination, both written and oral.

Under EASA, the responsibility to qualify the a person for the license rests on the training organisation under part 147. The qualificati

Myanmar EASA part 66

Myanmar, a country formerly known as Burma needs no introduction. The aviation industry is by any standard behind the neighboring Thailand.

My aviation school is involved in some work to train the staff of some of the airlines. These are some facts that we found.

a. The knowledge level of the population is below the average. It may have something to do due the long isolation and the trade sanction imposed by USA lead power. Many of the licensed engineers are expatriates.

b. The education is good. However the command of english is rather low. English is the language of aviation and important for the technical understanding of the engineering documents.

c. We look at the EASA 66 syllabus and came with a pleasant surprise. The Modules 1,2,3,4 were removed and not considered necessary to get the license. We asked them why, their answer was, the basic technical knowledge was not necessary as those applying for license has to hve the minimum qualification of technical university graduates.

d. The engineering maintenance capability is limited to lower check of Check A and B. The higher check C are done in Singapore or Malaysia.

We feel an introduction course to aircraft maintenance will help the existing workers. At least the course will introduce some basic skill and safety awareness that is so critical to aircraft maintenance.

Welcoming a new trainer

A trainer is often considered the most important asset an aviation school can have. It is him that can make the different for a school. Accepting his importance, the aviation authority has stipulated the requirements who can be a trainer.

Basically, in a simple term, a trainer should have:

a. the knowledge to deliver the course: Thus he must have been trained in delivery technique and attended the Instructional Technique Course. This requirements can be replaced by teaching experience.

b. He has the knowledge of the modules, there 13 modules as per the EASA part 66.

c. He has the working experience in the aircraft.

So Mr P reported for duty on the 1 Dec 2011. I had prepared a few topics for a short informal briefing. If it is more than 2 new staff, then I have to give a proper presentation. Among the topics are:

- The company's MTOE or maintenance training organization exposition. All approved company under part 147 have to have the MTOE. It is like a policy and operating mannual.

- The local requirements for training school. This include the EASA 147 requirements and the part 66 examination requirements.

- The company's requirements to be included in the list of approved instructors.

Then I brought him around to introduce to all the staff.

I have to put him under probation for 6 months, then confirm him he can prove his worth.

Requirementss to be trainer

Aviation school needs to engage trainers to prepare the students for the examinations and their careers. Luckily CAA had given the guide line under part 147 regulation 46.

The guide gives a working guide for 147 organisation to select their trainers and subsequent training. The important points are given below:

A. General Requirements

a. All the trainers or instructors have to show their familiarization of the requirements from the airworthiness authority. Depending on your situation and location, you may need to comply to CAA UK. The instructors are also required to understand the requirement of the TOE, training organisation exposition. It is normal that the TOE will include the requirements of the civil aviation authorities plus additional companies requirements. The TOE is always more stringent compared to CAA or DCA.

b. The profile of the trainers to be included in the TOE

c. The trainers can also acts as knowledge examiner or practical assessor.

B. Basic Instructor

a. He or she has the relevant EASA license in the area she is teaching. OR

b. Shows evident of working experience in the relevant areas OR

c. Experience in teaching

I like the guidelines given by CAA as it caters for operating schools as well as the new setup.

trip marketing to bangladesh

Next week my school team will be going to bangladesh to market aviation courses. We were encouraged by the positive response that we received from our agent that we met in Sri Langka.

In preparation for our visit, I had made a quick research on the demands and the maintenance licensing system in Bangladesh.

a. - About the civil aviation authority - The Civil Aviation Authority of Bangladesh was established in 1985 when two authorities, the Department of Civil Aviation and Airport Development Authority were merged in 1985.

b. - Licensing System for aircraft engineer - I would like to know, which licensing system does the country follow. I was thinking that the system will be likely linked to UK system, because Bangladesh is a commonwealth country. I also wanted to see whether they had converted to follow the part 66 EASA. To my surprise, there is just to little information in the web.

Reading the ANO, it appears to be the original version of ICAO, Chicago convention 1944.

c. - Check the number of aircraft in the country.

i. Airlines -

-Biman Airlines - The biggest operator sets to expand its fleet with the order of 10 new aircrafts from Boeing, to include 777, 787 and B737. Currently, its fleet makes up of 2 B737, 4 DC 10 and 3 F28. Its base is at

BIMAN BANGLADESH AIRLINES LTD.

HEAD OFFICE, BALAKA

KURMITOLA, DHAKA-1229

BANGLADESH

- Bismillah Air -

- Easy Fly

- Royal Bengal Air

d. Check for competitors

When I conducted the search for the approved training organisation ATO bangladesh, I received no indicator of any company conducting EASA 147

Venturing To Education Project

We are expanding the business to include education business. All our previous experience was providing training for students ex- o' level working towards EASA licenses. If things work out according to plan, by next year, we will be conducting programs in support of the government transformation program.

Malaysia was feeling the pinch of the shortage of qualified technical personnel to support the industry. When the department of civil aviation made the decision to subscribe to EASA licensing system, many of the airlines were caught with their pants down, the creation of the technician grade had left a vacuum at the work place. The airlines have to rely on the imported workforce from Philippine and India and added cost.

The secondary school had undergone massive changes. The issue of the teaching of science and mathematics has not been resolved yet. The issues started when the government changed the teaching of science and mathematics to english language. It was unknown whether a thorough study had been conducted, but it was done in such a rush. From memory, the changes was made within 6 months from the date of the the announcement.

Now with a new minister for education, he wanted to revert to dual system of vacational and academics. He might have been impressed by the teaching vocational subjects in Germany.

THE NEW SYSTEM

The new system will require streaming of students from the year 10 of schooling. In Malaysia, students will have the PMR at year 9, and the streaming will be done based on the results of the PMR.

One of the course of study for the students will be aircraft maintenance engineering. The program offered will be three years.

a. year 1 - year 10 of schooling - the students will undergo foundation courses

b year 2 - year 11 of schooling - Basic, then the student will take the o level

c. Year 3 - Category A EASA license

If he compete the Cat A, he can further himself to get the B1 license.