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Xxx AB
2015-10-30
Privilegiet Regeln
Produktion
Tillståndet
Oberoende granskning
CMM
SM
AM
Produkten
Circle of Life!
KUND
NPH
Låt oss se på regelverket… 21G
21.A.139 Quality System
• (b) The quality system shall contain:
• 2. An independent quality assurance function to monitor
compliance with, and adequacy of, the documented procedures
of the quality system.
• This monitoring shall include a feedback system to the person or
group of persons referred to in point 21.A.145(c)(2) and ultimately
to the manager referred to in point 21.A.145(c)(1) to ensure, as
necessary, corrective action.
2015-10-30
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Låt oss se på regelverket…21G
GM No. 1 to 21.A.139(b)(2) Quality System –
Independent quality assurance function
• The quality assurance function which is part of the
organisation is required to be independent from the
functions being monitored. This required
independence relates to the lines of reporting,
authority and access within the organisation and
assumes an ability to work without technical
reliance on the monitored functions.
2015-10-30
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Låt oss se på regelverket…21G
GM No. 2 to 21.A.139(b)(2) Quality System – Adequacy of
procedures and monitoring function
• Adequacy of procedures means that the quality system, through
the use of the procedures as set forth, is capable of meeting the
conformity objectives identified in 21.A.139(a).
• The quality assurance function to ensure the above should
perform planned continuing and systematic evaluations or
audits of factors that affect the conformity (and, where required,
safe operation) of the products, parts or appliances to the
applicable design.
• This evaluation should include all elements of the quality
system in order to demonstrate compliance with Part 21 Subpart
G.
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Låt oss se på regelverket…21G
• 21.A.139 Quality System
(b) The quality system shall contain:
• 1. as applicable within the scope of approval, control
procedures for:
• ……..
• (xiv) internal quality audits and resulting corrective
actions;
2015-10-30
7
Låt oss se på regelverket…147
147.A.130(b)
The organisation shall establish a quality system
including:
• 1. an independent audit function to monitor training
standards, the integrity of knowledge examinations
and practical assessments, compliance with and
adequacy of the procedures, and
• 2. a feedback system of audit findings to the person(s)
and ultimately to the accountable manager referred
to in point 147.A.105(a) to ensure, as necessary,
corrective action.
2015-10-30
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Låt oss se på regelverket…147
AMC 147.A.130(b)
• The independent audit procedure should ensure that all aspects
of Part-147 compliance should be checked at least once in every
12 months and may be carried out as one complete single
exercise or subdivided over a 12- month period in accordance
with a scheduled plan.
• 5. The independence of the audit system should be established
by always ensuring that audits are carried out by personnel not
responsible for the function or procedure being checked.
2015-10-30
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Låt oss se på regelverket…147
AMC 147.A.130(b)
The independent audit is a process of routine sample
checks of all aspect of the training organisation’s
ability to carry out all training and examinations to
the required standards.
• The management control and follow-up system should
not be contracted to outside persons. The principal
function is to ensure that all findings resulting from the
independent audit are corrected in a timely manner
and to enable the accountable manager to remain
properly informed of the state of compliance. Apart
from rectification of findings,
2015-10-30
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Låt oss se på regelverket…147
AMC 147.A.130(b)
• the accountable manager should hold
routine meetings to check progress on
rectification
except that in the large training organisation such
meetings may be delegated on a day-to-day basis
to the quality manager
as long as the accountable manager meets
at least once per year with the senior staff
involved to review the overall performance.
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Låt oss se på regelverket…147
PART 3 – TRAINING SYSTEM QUALITY
PROCEDURES
• 3.1. Audit of training
• 3.2. Audit of examinations
• 3.3. Analysis of examination results
• 3.4. Audit and analysis remedial action
• 3.5. Accountable manager annual review
• 3.6. Qualifying the instructors
• 3.7. Qualifying the examiners and the assessors
• 3.8. Records of qualified instructors & examiners
2015-10-30
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Låt oss se på regelverket…145
AMC 145.A.65(c)1
The primary objectives of the quality system are to enable the
organisation to ensure that it can deliver a safe product
and that organisation remains in compliance with the
requirements.
• 2. An essential element of the quality system is the
independent audit .
• 3. The independent audit is an objective process of routine
sample checks of all aspects of the organisation’s ability
to carry out all maintenance to the required standards
and includes some product sampling as this is the end
result of the maintenance process. It represents an
objective overview of the complete maintenance related
activities 2015-10-30
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Låt oss se på regelverket…145
AMC 145.A.65(c)2
The accountable manager should hold regular meetings
with staff to check progress on rectification
except that in the large organisations such meetings may
be delegated on a day to day basis to the quality
manager
subject to the accountable manager meeting at least
twice per year with the senior staff involved to review
the overall performance and receiving at least a half
yearly summary report on findings of non-compliance.
2015-10-30
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Summasumarum…
Del-21G;
• ”Quality system” inkluderar procedurer för oberoende granskning
(internaudit)
• ”Quality system” skall auditeras (som en ingående procedur i
21.A.139.
Del-147;
• ”Quality system” inkluderar procedur för oberoende granskning
• Quality system skall auditera ”Verksamheten”
• AM skall auditera Quality system
Del-145;
• ”Quality system” inkluderar procedur för oberoende granskning
• Quality system skall auditera ”Verksamheten”
• AM skall auditera Quality system
2015-10-30
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Summasumarum… 21G
Quality system skall auditeras systematiskt och
planerat av en oberoende funktion;
• Extern auditör
• Oberoende intern auditör
Eller
• AM
(förutsätter skrivna procedurer för
tillvägagångssätt och dokumentation i POE)
2015-10-30
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AM… 21.A.145 Approval requirements
(c) with regard to management and staff:
• 1. a manager has been nominated by the production
organisation, and is accountable to the competent
authority. His or her responsibility within the
organisation shall consist of ensuring that all
production is performed to the required standards
and that the production organisation is continuously
in compliance with the data and procedures identified
in the exposition referred to in point 21.A.143;
• Närvaro
• Kunskap om produkten
• Kunskap om regelverket
2015-10-30
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GM 21.A.145(c)(1) Approval
Requirements – Accountable manager
• Accountable manager means the manager who is responsible,
and has corporate authority for ensuring that all production work is
carried out to the required standard.
• The manager is responsible for ensuring that all necessary
resources are available and properly used in order to produce
under the production approval in accordance with Part 21
Section A Subpart G.
• The manager needs to have sufficient knowledge and authority
to enable him or her to respond to the competent authority
regarding major issues of the production approval and implement
necessary improvements.
• The manager needs to be able to demonstrate that he or she is
fully aware of and supports the quality policy and maintains
adequate links with the quality manager.
2015-10-30
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AM - SM - Safety Manager/CCM –
Compliance Monitoring Manager Focus on; Management system – including;
• Monitoring of Compliance,
independent auditing
• Reporting to management
• Effective corrective actions
• Follow up
• Hazard identification
• Risk assessment
• Mitigation
• Effective actions
• Safety reporting scheme
2015-10-30
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CMM
(QM)
SM
AM
FOKUS!