Enrico Deodati

Dear John, thank you for your post. I read the document and I would like to share some comments, because I’m afraid there are some ambiguities which might jeopardise the full understanding (either by the CAs or approved organisations) of the document itself. I list only some of them, referred to Subpart G.
The first ambiguity is the definition of a Quality Manager, with the functions of a Compliance Monitoring (or Quality Assurance) Manager.
The reason why is that the new Production Management System (PMS) consists of two elements: a Safety Management Element and a Quality Management Element.
In addition to these two elements, an independent function to monitor compliance needs to be created (21.A.139(e)), which is what was referred to in the previous regulation at 21.A.139(b)(2) as an "independent quality assurance" function.
If there is a need to suggest a name, "Compliance Monitoring Manager" or “Quality Assurance Manager” could have been preferred, whereas now, deliberately, in AMC 21.A.145(c)(2) it is referred to the nominated person responsible for this function as the Quality Manager, which by term-logical similarity should be linked to the Quality Management Element: if the Safety Manager is the nominated person responsible for the “supervision” of the activities entailed by the Safety Management Element, Quality Manager is the nominated person for the “supervision” of the activities related to the Quality Management Element? We know that he/she is not.
The role of the Quality Manager (AMC1 21.A.145(c)(2)(i)) should ensure that the organization's activities are monitored for compliance (with regulatory and organizational requirements), that the audit plan is implemented, etc., and that corrections and corrective actions are taken (i.e., exactly the activities of a Compliance Monitoring Manager or, if we prefer, a Quality Assurance Manager).
But the ambiguities begin as early as AMC1 21.A.139(d) when having to start providing AMC&GMs relevant to the "quality management element" in the title (in bold) they speak of "quality system element," indicating it in the AMC itself as "included in the production management system": if the Production Management System (renewed point 21.A.139) replaces the Quality System (old point 21.A.139) why we continue to speak of Quality System?
Same thing in GM1 21.A.139(d)(1) and in AMC1 and AMC2 21.A.139(d)(2)(ii): we continue to talk about "quality system" (while it is clear that we should talk about "quality management element" of the "production management system") and it refers to 21.A.139(b)(1)(ii) which, in addition, is the relevant point in the old regulation (this is really a mistake, I guess).
The inconsistency that jumps out at you the most, however, is the one related to GM1 21.A.139(d)(1) QUALITY SYSTEM (MANAGEMENT, I suggest) ELEMENT - PARTNER AND SUBOCONTRACTOR ARRANGEMENT
The content of this GM (written in the “AMC format”, with the verb "should") was provided, in the NPA, in AMC1 21.A.139(c)(3) SAFETY RISK MANAGEMENT - INTERFACES BETWEEN ORGANISATION and due to the topics dealt with, it should have been confirmed in AMC1 21.A.139 (c)(3), i.e. referred to the Safety Management Element, or, if they really wanted to link it to the Quality Management Element as well, the AMC could have been called "AMC1 21.A.145(c)(3) and (d)(1)."
Moreover, the International Industry Standard document SM-0001 "Implementing a Safety Management System in Design, Production and Maintenance Organization," which deals in detail with customer-supplier interfaces and is considered an AMC of Part 21 Sub G (for the Management System Element, of course) with very similar contents of the NPA AMC, becomes higher in rank than an EASA provision (we know GM is not an acceptable means of compliance).
Hope to receive clarification comments by our colleagues, even more if aimed at amending my misinterpretation. Thanks in advance

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