Compliance Monitoring

Foreword

‘Compliance Monitoring’ is a misleading term; misleading in that it gives the impression that ‘compliance’ is about nothing more than auditing.  There is far, far more to the field of compliance than mere auditing (although, that is a considerable skill in itself).  A ‘compliance manager’ IS NOT an ‘audit manager’.  Nevertheless, ‘compliance monitoring’ is the term in widest use.  The oft-forgotten element is exploiting the specialist knowledge of the compliance post-holder, in the resolution of regulatory problems.

For the mentoring of staff, please refer to the ‘Training / Mentoring’ tab.

Review of the Compliance Monitoring System

I am able to review your CMS, either in the form of scheduled audits, on a continuous basis and / or a formal evaluation and report of recommendations.  I would take account of best practices observed during my 34 years of practical experience of holding 19 post-holder approvals from numerous jurisdictions

I would need access, under a non-disclosure agreement, to your past records of audit.  Those records would need to include, for all audits carried out:

  1. Non-compliances raised (dates, wording, references to regulations, due dates etc);
  2. Corrective actions;
  3. Root causes;
  4. Preventive actions;
  5. Supporting evidence;

Note:  Please read ‘Replying to Non-Compliances’ under the ‘Articles’ tab.

  1. Date of closure;
  2. Audit calendar;
  3. Compliance Monitoring System (CMS) Manual (or equivalent);
  4. Corresponding ops manual, maintenance organisation exposition etc.

The above would give me a reasonable picture of the health of the ‘core’ of your CMS.  It would, also, enable me to identify those deficiencies to which I would recommend specific responses.

I would need, also, to hold at least one on-line call prior to any site visit.

External Oversight

I could offer external oversight of your CMS and report annually on its performance.  This, in turn, would remove dependence upon your national authority and / or clients for detailed feedback on your CMS.  It would, also, provide for the importation of best practices. 

Finally, I strongly recommend investing in support in preparing for provider approval audits by significant clients.  In such situations, your CMS and SMS become the de-facto ‘public face’ of your operation and their performance is critical to success.

Problem-Solving

This is where specialist knowledge and imagination should be exploited.  Let me give you examples of issues I have been able to address:

  1. Gaining a one-off ‘B’ scope of approval, by engine serial number (the spare, on a transport stand) and SB number, so that a SB might be accomplished off-wing;
  2. One-off approval of a base maintenance provider for a C-check, to avoid loss of the only slot possible, arising from the non-availability of the NAA;
  3. Temporary variation of the MEL (with the permission, of course, of the authority), with mitigating measures, to avoid placing aircraft out of service prior to completion of permanent rectification action for a defect;
  4. Cancellation of fines arising from departure procedure violations;
  5. Reduction of fines for noise violations;
  6. Return of excess landing fees charged;
  7. Avoidance of re-certification of work during aircraft changes in register;
  8. Use of management of change hazard assessments for the approval of post-holders;
  9. Standing approval of TCCA maintenance technician licences under a foreign NAA (by introduction of a comparative analysis in the MOE).

The above is a selection of the successes I have had during my 34-year career – to date – as a practitioner.  If someone tells you that a certain thing cannot be done, remember that there is – often – more than one way to solve a problem.  Frequently, we are restricted by a lack of imagination and a reluctance to ask a novel question.

Please contact me to discuss further.