Ever since the introduction of the Safety Management System (often referred to as the SMS), quality management in airlines and the aviation industry seems to have fallen second place with respect to safety assurance in general. It is now called compliance management (rather than quality management) and the compliance manager is often reporting to the safety manager (or safety director). The change in legislature seems quite justified, but compliance monitoring is still a crucial aspect of ensuring safety of flight and compliance will all required aviation regulations. Let’s take a look at what compliance monitoring is all about.
What is the quality system in an airline, airworthiness organization or MRO?
In plain words, the quality system of an aviation company is a set of procedures, which this company adopted to guide and describe its operations. In all cases, any AOC holder, Part M airworthiness organization or Part 145 maintenance organization is required by law to create a set of procedures, which must comply with the applicable regulations, but which also reflect the specific way in which a given company aims to fulfil those regulations and run its own business. This set of procedures is referred to as the “Operations Manual” for airline operators, the “Continuous Airworthiness Management Exhibition (CAME)” for Part M providers or the “Maintenance Organization Exposition” for Part 145 maintenance organizations.
Of course, the quality system is not limited those manuals alone. They are the core of the organization, and aim to describe all its aspects in required detail, but often do not go into specific details (especially in cases where certain procedures may often change). Therefore, those manuals often reference several other documents, such as Joint Procedures Manual (JPM) created when different companies cooperate with one another, Line Maintenance Manuals (when a Part 145 opens several line stations in different parts of the world), leasing agreements, ACMI agreements, and many other specific procedures like shop maintenance procedures or waste management procedures.
As you can well imagine, this creates a ton of writing. Particularly if the operation is very complex, i.e. an airline (AOC holder) with its own Part M organization and a Part 145 maintenance facility, which has line stations at different airports and also several shop maintenance capabilities. Nevertheless, it is crucial to ensure that:
a) All the procedures are always in full compliance with applicable, current aviation regulations; and
b) All employees adhere to those procedures without compromise.
As you can clearly see, those are two very different aspects, and both are crucial for safe flight operations.
Compliance of the quality system with applicable aviation regulations
Sometimes I have been asked what is the point in writing specific procedures for each airline if, at the end, all of them need to comply with the same regulations. The answer is of course very simple, yet some people tend to miss it – the regulations tell us what needs to be done, but they don’t (or at least they shouldn’t) tell us how to do it. Therefore it is always crucial that the procedures incorporated into an airline’s quality system really reflect the way a company intends to work. And one can really comply with most regulations in a huge variety of ways.
This brings another question, which comes up from time to time and is handled different by different companies: should the procedures be devised by their “owner” (i.e. should airworthiness procedures be created by the CAMO post holder, as he/she is the one who knows how things are done) or should they be created by the Compliance Manager (as he/she is the one who knows the regulations by heart)? This decision is up to the airline, although in my personal opinion it should be the manger (director) of the department. They are the right person to do it, as only they know exactly how the department will be ran (because they are the ones running it) and they are also required to have significant knowledge of the applicable regulations. The compliance manager, on the other hand, should be the one auditing and the procedures and making sure that they don’t violate any requirement but should not be telling department directors how to do their job.
Of course, last but not least, all the procedures must be approved by the local Airworthiness Authority. But make no mistake about it – just because an authority has approved a quality system and the procedure therein, does not mean that they are 100% correct. The authority will never take responsibility for that, and that responsibility will always lie on the operator and, particularly, on the responsible post holder.
Adherence to company procedures
The best company procedures are no good, if the company employees don’t follow them. One of the major tasks of a Compliance Manager is to check whether the company follows the approved company procedures. This is done by a series of quality audits (or compliance audits, as they are now called).
The quality audit schedule need to be planned for each year. It is crucial, that every area of operation (i.e. every applicable regulation) be audited at least once in every 12 month period (note that this is not the same as saying “once each year”).
Every audit is has its specific phases, depending on what specific area of operations is being audited. In most cases, however, it is made by observations, interviews with personnel, review of all records from the last 12 months and a study of all changes made to the relevant procedures.
An aviation compliance audit is followed by an audit report, which should specify which areas have been audited and list all the discrepancies which have been found in the process. The discrepancies are generally classified as category 2 or category 1 – the first one meaning a discrepancy (finding) which potentially could lead to compromised flight safety, whereas category 1 means a finding which directly compromises flight safety and must be rectified immediately. All findings should be very carefully worded in a way, which makes it clear what the discrepancy is and also why it, possibly, occurred.
The manager or director of the audited department must be made aware of the audit report and has a specific timeframe (normally up to 3 months for category 2 findings) to rectify them.
As you can see, even with the introduction of the safety management system, the compliance manager still is a crucial role in every aviation organization. Compliance monitoring is will remain crucial for flight safety.