GM2 21.A.139(d)(1) Production management system

CAA ORS9 Decision No. 40

QUALITY MANAGEMENT ELEMENT — PARTNER AND SUBCONTRACTOR ARRANGEMENTS

When defining the arrangements between the production organisation (PO) and its partners and subcontractors, both elements of the production management system should be taken into account, i.e. the safety management element and the quality management element. The following guidance should therefore be considered applicable to both elements.

  1. When the PO subcontracts activities, the arrangements should consider the safety risk management process that is part of the PO’s safety management element (see point 21.A.139(c)(3)). When the subcontractor does not have a safety management element, the subcontractor should be integrated into the safety management element of the PO; when the subcontractor has implemented a safety management system (such as for design organisation approval (DOA) or production organisation approval (POA)), the two safety management systems, i.e. of the PO and of the subcontractor, should be harmonised.

  2. Depending on the complexity and criticality of those arrangements, the following elements within the arrangements should be addressed:

    1. coordination and interfaces between all the parties involved;

    2. applicable procedures;

    3. safety culture, including internal safety reporting schemes (see point 21.A.3A);

    4. communication between all the parties involved, including reporting, regular meetings, and feedback channels;

    5. allocation of tasks, of clear accountability, and of responsibilities; and

    6. the qualifications and competency of key personnel with reference to point 21.A.145.

  3. The safety risk management should focus on the need to exchange safety data and safety information that are deemed significant for the determination of relevant risks in terms of likelihood, severity, impact, and acceptability, such as, wherever appropriate, but not limited to the following:

    1. (at product level) failure, malfunction, defect, or other occurrences, non-conformity or outcome of the compliance monitoring function, quality escape, process failure, foreign object damage (FOD), deviation (e.g. calibration of tools), component failure analysis, in- service event, etc.;

    2. (at documentation level) key processes (e.g. airworthiness directives, production documentation, production processes); and

    3. (at organisational level) organisational changes, disruptive events, resources’ issues, human performance (HP) issues.

  4. Regular communication should be ensured between all the parties involved, to discuss work progress, risk mitigation measures, changes to the arrangements, as well as any other significant issues.