How PIA Acquired International Aviation Approval of EASA - part-145 for its Engineering And Maintenance Department From European Aviation And Safety Agency
NEED OF EASA PART-145 (JAR-145) APPROVAL TO PIA ENGG & MAINT. DEPTT:
In the past, PIA Engineering & Maintenance had been holding International Quality approvals of two major and Internationally accredited organisation ie.
-- The approved repair station by FAA (USA), and
-- The approval of Civil Aviation Authority (UK)
These were in addition to the approval granted by local regulatory body CAA, Pakistan. The reasons for acquiring EASA PART-145 (JAR-145) approval are:
1. In early 90's, FAA did not renew PIA's approval certificate, for the reasons that PIA engineering is not performing maintenance on any US registered aircraft / equipment, anymore. Finally in February 1993, CAA (UK) informed PIA that their overseas approvals were revoked, because CAA (UK) became the member of ECAC (European Civil Aviation Conference) and JAA (Joint Aviation Authorities of Europe).
2. A very strong factor pushing this decision emerged, in 1997, when it was decided in airlines rotable spares pools meeting, that any maintenance organisation, which is non JAR-145 approved, would not be entitled for rotable pool arrangements / facilities after 31 December 1999.
3. During the deal with Cathay Pacific (CX) for Boeing 747-300 aircraft in 1998, it was badly felt, that the cost of the dry lease of these five jumbos could have been reduced, if PIA Engineering could have accomplished the major checks C & D at its Karachi base. Hong Kong regulatory authority was reluctant to grant the approval of maintenance of their leased aircraft to PIA Engineering in the absence of JAR or FAA approval.
4. Meanwhile CAA (Pak) also informed PIA engineering, that they are actively considering adopting the JARs as its regulatory requirements operative under CARS/CAA regulations.
The advantage of adopting JARs is evident while it would satisfy the ICAO, it would also be an accepted recognised standard in Europe, USA and rest of the world. When initiated by CAA (Pak), the adoption of JARs will be implemented over a period of time in Parts.
5. Last, but certainly not the least reason for PIA engineering to go for EASA PART-145 (JAR-145) approval was, for interaction with the aviation world. The need for adapting to some aviation quality approval was increasing day by day, whereas all the benefits of ISO 9000 or any other industry quality standard would be available in EASA PART-145 (JAR-145).
HOW EASA PART-145 (JAR-145) PROJECT PROGRESSED IN PIA ENGG. & MAINT:
Actually, the project was formally launched in October 1998, when Director Engineering, formed a 'Project working team'.
In March 1999, working team was Successful in identifying the major issues, problems and pre-requisites to fulfil JAR-145.
In co-ordination with Airbus, work on developing the Company Procedures manual, named as 'Maintenance Organisation Exposition' (MOE) started. Purpose of MOE is to set forth procedures, means and methods of the organisation. Compliance with its contents is a pre-requisite, and audited by JAA to issue JAR-145 approval. It contains five parts, namely:
(i) Management: It includes duties & responsibilities of management personnel, organisation charts, manpower resources, details of facilities and premises, and certifying staff.
(ii) Maintenance procedures: A total of 28-maintenance procedures, and 7 additional Line Maintenance Procedures detailing them in the "AMP" (associated maintenance procedures).
(iii) 14 Quality systems procedures: which include procedures; which include procedures defining product and system audits, qualification of auditors, quality inspectors and mechanics, training and authorisation system of certifying staff etc.
(iv) Contracted JAR-Ops Operator; containing operator's procedures and operator record completion.
(v) General Appendices & List of Forms used in the organisation.
Unfortunately, for various reasons enthusiasm for project accomplishment did not maintain the required momentum in the next few years.
Until middle of 2001 JAR-145 Project had been decelerated mainly due to;
-- Poor financial condition of the airline from 1999 to 2001.
-- Frequent changes in top management resulting in lack of its commitment to the project.
However, with the airline's new top management, when Mr Ahmed Saeed took over as Managing Director, (later on as Chairman PIAC), and AVM (R) Niaz Husain as Director Engineering, the whole project was rejuvenated. A new project working team was formed and Aircraft Engineering Zafar Ahmad Khan appointed as Project.
In October 2001, under the leadership of new Director Engineering, JAR-145 Project team reviewed the project progress and evolved a new strategy to yield quick results in a more efficient manner.
Director Engineering was declared as the "Accountable Manager" for the JAR-145 approved maintenance organisation, having the corporate authority/independence for ensuring all resources and facilities to carry out all the maintenance required by aircraft operator as per JAR-145 standards.
Close liaison with the Project consultant M/s Airbus and the JAA authorities was established for better understanding of requirements and justification of need to issue JAR-145 approval to PIA could be ascertained.
The Quality policy and the Quality objectives of PIA Engineering were developed, approved, declared, displayed and thus established. Planning and implementation of various quality tools to initiate a change in organisational culture, leading towards a quality-conscious working environment was accomplished.
Re-writing of MOE & AMP (in the light of newly issued amendments 3 & 4 of the JAR-145 requirements) commenced, after getting adequate professional training for technical / quality procedure writing by M/S Airbus in Toulouse, France. Work instructions and procedures for floor level workers in the light of MOE/AMP/EMPM was then completed, and a controlled list of identified tages and forms, used in various sections of engineering organisation were developed. A massive task of inventory stock-taking was undertaken for the first time, and the 22 technical stores were re-vamped, renovated and re-organised to be only 12 stores. This included establishing special stores like "chemical", "rubber" and "environmental" as per requirements of JAR-145.
A section for JAR-145 Project having dedicated and full time Project co-ordinators cum internal quality auditors was established. They were trained for audit skills to professional level and responsible to facilitate and co-ordinate various activities of project implementation.
To gauge and analyse gaps in all eight divisions of PIA engineering, internal auditors executed a program of preliminary audits. Based on their reports, corrective / preventive actions were implemented with target dates. In this way the organisation culture started to conform to this basic principle, "write whatever you are doing, & do whatever is written".
Continuous review started by the top management through project coronation meetings, JAR internal audits statistical analysis presentations and audit reports.
A detailed stepwise target Action Plan was developed by the Project Manager and approved by Director Engineering for the pre-certification and JAA certification audit, in consultation with the consultant. Accordingly, formal application on JAA Form-2 was submitted to French authorities, GSAC, who were the designated authorities by JAA to evaluate, audit and issue JAR-145 approval to PIA Engineering & Maintenance.
Thus the lingering Project of JAR-145 picked up pace under the dynamic leadership of AVM Niaz Husain as Director Engineering.
In January 2002, JAR-145 Project / Quality Audit Section launched a JAR-145 AWARENESS CAMPAIGN, including:
-- Technical Workshop / Seminars on JAR-145 and Quality concepts.
-- Establishing JAR-145 Implementation Review Groups in each division.
-- Artifacts, such as Quality Policy and other Posters & paintings, on Quality concepts.
-- Presentations on Analysis of internal audit results conducted by internal auditors.
From February 2002 to June 2002, Quality Audit section conducted 4 internal audits of Quality Systems, Avionics O/H, Power Plant O/H and Base Maintenance divisions. Where as Gap Analysis of Line Maintenance and Cabin Maintenance division were also performed.
In March 2002, PIA Engineering submitted second draft of MOE / AMP to Airbus for assessment, after updating tem to Amendment 3 & 4 of JAR-145 Requirements.
In August 2002 MOE Procedure Writing Training at Toulouse was obtained along with English Translation of GSAC Fascicule stating requirements MOE and Approved Vendors List & Company Capability List. Having reached this stage, a Formal Application for JAR-145 approval was submitted to GSAC, France, by the Accountable Manager, AVM Niaz Husain, through Airbus providing the "Justification of need".
In September 2002 an acknowledgement receipt for PIA's Application was received from GSAC clearing the path for subsequent approval. This was the first major achievement in the entire process.
In January 2003 Boeing team visited GSAC and then PIA Engineering & Maintenance. After their visit they provided PIA Engineering with suggestions to improve and prepare for GSAC meetings.
In March 2003 First Meeting between PIA Engineering team comprising of Director Engineering and Manager JAR-145 Project and GSAC was held at Paris. In that meeting GSAC agreed with the PIA's proposed Project Plan.
In April 2003 Third Draft of MOE was prepared and submitted to consultant "Bureau Veritas" France for their review, corrections and comments and in May 2003, after a corrected Fourth Draft of MOE / AMP was finalised and submitted to GSAC. With the submission of the MOE the "official" audit of PIA Engineering commenced.
In August 2003 JAR-66 Modules 9 & 10 training program from SR Technics & Lufthansa instructors for certifying staff started to comply GSAC requirements for all 410 Aircraft Engineers who were in the certifying list. This training continued until December 2003.
In August 2003 "Traila Audit" of PIA Engineering was conducted by M/S Bureau Verities auditors, and in September 2003 Internal Audit training was provided by M/s Bureau Verities to 20 Aircraft Engineers.
In October 2003 Second Meeting between PIA Engineering team and GSAC was held at Paris. GSAC suggested changes in MOE as per Amendment 5 of JAR-145 requirements, and finalised the Certification audit schedule for 13th to 23rd January, 2004.
In November 2003 Fifth Corrected MOE / AMP draft was prepared and submitted to GSAC.
In November 2003 Boeing team visited PIA Engineering and performed evaluation audit of PIA Engineering.
In December 2003 Product Audit of Power Plant Overhaul and Avionics Overhaul was conducted by internal Auditors.
On 12 January, 2004 a three member GSAC team arrived at PIA Engineering to conduct the formal audit for certification. This was an intensive, detailed product and procedures audit which lasted ten days. A few observations were made and a period of four weeks was given for corrective actions.
From 20-24 February, 2004 Follow Up Audit was conducted by GSAC Auditors and with the blessings of Almighty Allah all observations made in January were cleared. GSAC auditors expressed their satisfaction to recommend positively to EASA for Part-145 approval to PIA Engineering.
On 15 April, 2004 EASA issued Part-145 approval to the ENTIRE PIA Engineering Department consisting of its eight divisions. This was a unique distinction for a non-European Engineering & Maintenance Organisation to attaining approval for the entire department in the first attempt.
DIFFICULTIES & LESSONS LEARNT: To give a slight idea of the difficulties faced by the organisation and specially those who are responsible directly for the JAR-145 Project, during these two and a half years, I would like to tell you the major hurdles faced by us.
1. We were very clear in our minds, from the beginning, that it was not only the piece of paper of JAR-145 approval we were striving for, but the European Quality Standard for which we have to change the mind sets of our people at all levels.
2. Secondly, a general notion prevails among people that organisations like PIA Engineering can never acquire international Quality approvals like JAR-145 through their merit, and would only be awarded by virtue of buying European aircraft like Airbus A340. During August 2002, when PIA had finalised its decision for buying Boeing 777 instead of Airbus A340, many red buttons in the organisation had declared this project abandoned. Nevertheless, with undaunted commitment we are standing here today with a smile of success and accomplishment.
3. Thirdly, the JAR-145 Requirements have continuously been changing. In October 2001, our organisation started preparing for amendment 2 of the JAA-European Authorities requirements, bridging the GAP of approximately 10 years in a two year period. In the next two years, from 2002 to 2003, three additional major amendments were instituted. Thereafter JAA evolved into European Aviation Safety Agency (EASA) and issued yet another, first draft of regulations, EASA Part-145. So altogether we have prepared our MOE ie Maintenance Organisation Exposition five times.
4. Last but not the least, I would like to point out the peculiar nature of assignment of Quality audits. It is very obvious that audit is not a very pleasant job to do. Nobody wants to be audited. No Aircraft Engineer would like to become an Auditor without any adequate Quality Assurance career plan. But in spite of all these hurdles we stuck to the task enjoying the full support of the Accountable Manager, the Director Engineering, for meeting the rigorous training requirements of the Auditors.
With the blessings of Almighty Allah, and undoubted hard work of my Part-145 Project & Quality Audit team, the support and co-operation of the whole Engineering & Maintenance Organisation, all the given tasks were met and finally we all have become ONE team.
CONCLUSION: We can now claim that Engineering & Maintenance Department is the only department in PIAC, where all working procedures are documented in line with European Quality standards for aviation, and verified by the auditors of French authorities GSAC.
Today we can proudly say we match any good aviation maintenance organisation in the world, in quality of maintenance and in the depth of approval scope and expertise of work. Above all, our organisation is committed to continually improve our Quality standard and keep pace with emerging Aviation Standards.
(The author is Zafar Ahmed Khan Manager Engineering, Part-145 Project)