Getting Ready For DCA Audit

The school I am working with is an approved school under the NAA, national airworthiness authority. The approval was awarded under part 147, (equivalent to EASA 147) and the curriculum are as per Part 66.


Some of the topic covered in the briefing were:
1. Linking the approval to ICAO.
2. Role of the ATO (approved training school) in the country.
3. Brief on part 147 and part 66
4. The MTOE - Maintenance Training Organisation Exposition.
5. Guides to be a Good auditee.

Malaysia is one of the contracting states, meaning that we had signed the agreement to comply to the regulations formulated by ICAO.  The set of regulations are organised into annexes. There are a total of 18 annexes, the part about personal licensing is in annex 1.

As ICAO is not a regulatory authority, the regulations issued have to be changed into law by individual country.  The regulations are enforced through the country's legal system. Beside ICAO, there are other bodies that monitor the aviation operation in this country.

USOAP - is the safety oversight audit program conducted by ICAO. The detail is given in this site (jan-2014) .. http://www2.icao.int/en/usoap/Pages/default.aspx

FAA, the aviation authority of USA also monitors the aviation safety through the program known as IASA. Sample of the result of the audits are given below...

IASA by FAA

  EU does not have similar program, but rely of inputs from third parties to regulate the safety matters of other countries. Airlines from "unsafe" countries may be banned from flying to Europe.

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.