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MO COMPLIANCE
Compliance Monitoring Manager
MO Management System
Compliance Monitoring Manager
MO Management System
In accordance to Part 145.A.200 (a) 6) the Maintenance Organisation (MO) shall establish, implement and maintain a management system that includes a function to monitor the compliance of the organisation with the relevant requirements.
Compliance monitoring shall include a feedback system of findings to the accountable manager to ensure the effective implementation of corrective actions as necessary.
The accountable manager nominates a person or group of persons with the responsibility to manage the compliance monitoring function as part of the management system. A maintenance function cannot be combined with the compliance monitoring function.
These key safety management processes are supported by a compliance monitoring function as an integral part of the management system. Most aviation safety regulations constitute generic safety risk controls established by the ‘regulator’. Therefore, ensuring effective compliance with the regulations during daily operations and independent monitoring of compliance are fundamental to any management system for safety.
The compliance monitoring function may, in addition, support the follow-up of safety risk mitigation actions. Moreover, where non-compliances are identified through internal audits, the causes will be thoroughly assessed and analysed. Conversely, the output of the safety risk management processes may be used to determine focus areas for compliance monitoring
As indicated in the AMC1 145.A.200(a)(6) in accordance to ED Decision 2022/011/R the primary objectives of compliance monitoring are to provide an independent monitoring function on how the organisation ensures compliance with the applicable requirements, policies and procedures, and to request action where non-compliances are identified. The independence of the compliance monitoring should be established by always ensuring that audits and inspections are carried out by personnel who are not responsible for the functions, procedures or products that are audited or inspected.
As reported in the GM1 145.A.200(a)(6) the compliance monitoring function is one of the elements that is required to be in compliance with the applicable requirements. This means that the compliance monitoring function itself should be subject to independent monitoring of compliance in accordance with 145.A.200(a)(6).
As indicate in the GM1 145.A.30(b) Personnel requirement the Compliance Manager is responsible, in the day-to-day maintenance activities, for ensuring that the organisation personnel work in accordance with the applicable procedures and regulatory requirements.
Compliance Monitoring Manager role and skill
Compliance Monitoring Manager role and skill
He demonstrates a complete understanding of the applicable regulatory requirements, and ensure that the organisation’s processes and standards accurately reflect these requirements. It is his role to ensure that compliance is proactively managed, and that early warning signs of non-compliance are documented and acted upon.
As indicated in AMC1 145.A.30 more if than one person is designated for the compliance monitoring function, the accountable manager should identify the person who acts as the unique focal point, i.e. the ‘compliance monitoring manager’.
The role of the compliance monitoring manager should be to ensure that:
(i) the activities of the organisation are monitored for compliance with the applicable requirements and any additional requirements as established by the organisation, and that these activities are carried out properly under the supervision of the nominated persons referred to in points (b), (c) and (ca) of point 145.A.30;
(ii) any maintenance contracted to another maintenance organisation is monitored for compliance with the contract or work order;
(iii) an audit plan is properly implemented, maintained, and continually reviewed and improved; and
(iv) corrections and corrective actions are requested as necessary.
The compliance monitoring manager should:
not be one of the persons referred to in point 145.A.30(b);
be able to demonstrate relevant knowledge, background and appropriate experience related to the activities of the organisation, including knowledge and experience in compliance monitoring; and
have access to all parts of the organisation, and as necessary, any subcontracted organisation.
Knowledge, Background and Experience of
Compliance Monitoring Manager
Knowledge, Background and Experience of
Compliance Monitoring Manager
The Compliance Monitoring Manager to be nominated in accordance with point 145.A.30 (c) should have:
(a) practical experience and expertise in the application of aviation safety standards and safe operating practices;
(b) knowledge of:
(1) human factors principles;
(2) EU management system requirements and their application (including safety management systems and compliance monitoring);
(c) 5 years of relevant work experience, of which at least 2 years should be from the aeronautical industry in an appropriate position;
(d) a relevant engineering or technical degree, or an aircraft technician or maintenance engineer qualification with additional education that is acceptable to the competent authority. ‘Relevant engineering or technical degree’ means a degree from aeronautical, mechanical, electrical, electronic, avionics or other studies that are relevant to the maintenance and/or continuing airworthiness of aircraft/aircraft components.
The provision set out in the first paragraph of point (d) may be replaced by 2 years of experience in addition to those already recommended by paragraph (c) above. These 2 years should cover an appropriate combination of experience in tasks/activities related to maintenance and/or continuing airworthiness management and/or the surveillance of such tasks.
(e) thorough knowledge of the organisation's MOE and safety policy;
(f) knowledge of a relevant sample of the type(s) of aircraft or components gained through a formalised training course. These courses could be provided by a Part-147 organisation, by the manufacturer, by the Part-145 organisation or by any other organisation accepted by the competent authority. Aircraft/engine type training courses should be at least at a level equivalent to the Part-66 Appendix III Level 1 General Familiarisation.
‘Relevant sample’ means that these courses should cover typical aircraft or components that are within the scope of work of the organisation.
(g) knowledge of the relevant maintenance methods (and how they are applied in the organisation) and/or specific knowledge relevant to the area for which the person will be nominated;
(h) knowledge of the applicable regulations;
(i) adequate language and communication skills.
STEIA AVIATION supports MO INDIPENDENT COMPLIANCE MONITORING MANAGER for MO Training and Management
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