Should the Part-147 organisation’s quality system be audited?
147.A.130(b) states that the approved Part-147 organisation shall establish a quality system including:
- an independent audit function to monitor training standards, the integrity of knowledge examinations and practical assessments, compliance with and adequacy of the procedures, and
- a feedback system of audit findings to the person(s) and ultimately to the accountable manager referred to in 147.A.105(a) to ensure, as necessary, corrective action
This means that the quality system itself should be independently audited. The competent authority cannot perform this function on behalf of the organisation.
Within its approved procedures, the organisation has to monitor the quality system’s procedures. This implies that quality system monitoring itself must be subject to internal audits:
- no conflict of interest is allowed - it is not permitted that such a function be performed by quality system’s staff;
- This can be also outsourced;
- the right level of the auditor(s)’ position within the organisation shall be met in order to assure the objective of 147.A.130(b)2. (e.g. conflict of hierarchy, which could hinder an efficient and transparent report to the accountable manager).
In addition, the audit programme/plan needs to reflect this regulatory aspect.
The EASA Flight Standard Directorate consistently applies that policy during their standardisation inspections.