What will change for EASA Part-145 Approved Maintenance Organisations from EASA NPA 2019-05 (A) & (C) (Implementation of SMS)?
Introducing the new ‘MANAGEMENT SYSTEM’. 145.A.65 ‘Safety and quality policy, maintenance procedures and quality system’, will be changed into 145.A.65 ‘Maintenance System’. 145.A.65 ‘Maintenance System’ reproduces all elements of the management system requirements including the organisation requirements and related AMC. These changes are supported by a series of Guidance Material specific to the context of maintenance organisations, with particular focus on Human Factors and Safety Risk Management/Fatigue Risk Management.
The new management system provisions are introduced to ensure maximum flexibility by defining core requirements of the management system at Implementing Rule (IR) level, and including the detailed means to achieve these goals at AMC level. They also allow considering those elements that are already in place today in any Part-145 Approved Maintenance Organisation, in terms of quality system related provisions that deliver the ‘compliance monitoring function’ of the new management system requirements.
Most of the provisions related to ‘quality system’ in the current Part-145 deals with the monitoring of compliance and related reporting and corrective action processes. As there are multiple types of quality systems defined in different international or national standards, with different meanings and scopes, it is more appropriate to refer to compliance monitoring function when it comes to Part-145. This does not mean that organisations will be required to change designations of their quality system personnel. It is left up to each organisation to decide how to refer to this function. Conversely, at the level of the requirements, no reference to ‘quality system’ will remain.
No longer ‘Quality System’. The former term ‘quality system’ is not used any longer. It has been replaced by ‘management system, in order to define a consistent set of management system requirements that would be compatible with a wide range of management system standards. This new management system focusses primarily on the monitoring of compliance, a proper reporting to management, and the need to take effective corrective actions.
‘Quality Manager’ will be replaced by ‘Compliance Monitoring Manager’ and an additional manager function will be introduced in EASA Part 145: the ‘Safety Manager’. The Safety Manager is responsible for the development, administration, and maintenance of effective safety management processes as part of the management system in accordance with 145.A.65.
For non-complex organisations, the Compliance Monitoring Manager and Safety Manager can be one person, although this is not recommended for the larger, complex organisations.
‘Quality audit personnel’ will be replaced by ‘Compliance Monitoring and safety management personnel’. The organization’s compliance monitoring personnel performs the same work as it was described for the previous quality audit personnel and they may request the safety management personnel to perform a safety risk assessment.
All these changes and additions will mainly impact MOE chapter 1.1 up to 1.5 and chapter 3.
“MOE chapter 3 Management System Procedures” does no longer include “quality” in the title and the following altered and new paragraphs need to be developed and implemented in MOE chapter 3: