Who conducts oversight activities?

There are 3 types of oversight assessment activities, typically First, Second and Third party oversight assessment activities.

  • First party oversight assessment activities are internal assessments conducted by the approved organisation (ie: CAMO, DASR 145MO, MDOA, etc…).
  • Second party oversight is conducted by the customer (ie: CAMO, (SPO/FEG Quality Staff ) assessment of the DASR 145 MO or the MDOA).
  • Third party oversight activities which are conducted by the approval issuing authority, DASA. This applies to the Operator (MAO), Initial, (Continued ie: (MDOA)) and Continuing Airworthiness (CAMO/145 MO) organisations.

What areas are examined during these oversight activities?

First party oversight assessment concentrates on the activities of the organisation, they are carried out internally with a focus on the organisation's conformance to internal plans and procedures.

Second party oversight concentrates on the activities of the organisation and the Quality Management System from an external perspective. It concentrates on the organisation's conformance to the contract/tasking deliverable requirements. These oversight assessment activities are typically conducted by the CAMO, (SPO/FEG Quality Staff). The MAO will also conduct similar activities looking at the operational side of the organisation.

DASA conducts third party oversight assessment activities of the approved organisation. DASA assessments focus on compliance to the DASR through referenced plans (expositions, eg: CAME, MOE, DOE, etc…) and procedures (standing instructions, work instructions, etc…).. This provides assurance that the system is operating safely within the requirements of the regulations.

What is the difference between DASA assurance and FEG assurance?

Fundamentally, DASA’s independent (regulatory) assurance role is different to a FEG’s internal assurance role. DASA oversight assessment activities focus on the Present, Suitable, Operating and Effective (PSOE) aspects of an approved organisation’s QMS when assessed against the DASRs, whereas the FEG’s internal assurance is predominantly focuses on procedural QMS compliance. The FEG should therefore not be issuing findings against DASRs.

What are the Factors that affect combining oversight activities?

The frequency and extent of DASA oversight activities is stipulated in EMAR 145.B.30. Typically a FEG QMS audit program/schedule does not align with these requirements; however, FEGs could adjust their timings and scope to align with the timings of the DASA schedule of activities.

Although the FEG may desire to develop a ‘risk-based’ approach to the assessment frequency and level of oversight, DASA is required to assess all applicable DASR within a two year period as described in EMAR 145.B.30. The method of the assessment may be defined as ‘risk-based’ but this does not relieve DASA from maintaining alignment with the intent of EMAR 145.B 30.

The original proposal by the FEG was to combine activities and timings with the assumption that DASA and FEG QMS activities were comparable. Therefore an alternating schedule where both parties would share activities and resources would make sense, unfortunately, this is not the case.  In complying with the EMAR regulations, it has been stated DASA-DCA cannot adjust its schedules and the content of its oversight activities to match the FEG system or focus. This makes it unachievable to directly combine oversight activities and provide the current level of assurance.

Can oversight activities be combined?

DASA also conducts oversight on the FEG QMS, this means that DASA must continue to function separately to maintain its independence from the FEG QMS. Combined oversight activities have been trialled previously and, while realising some efficiencies, rub points emerged that negated the benefit; therefore it has not been adopted as common practise.

FEGs could choose to align their oversight schedule and activities with DASA’s program. Aligning timings of oversight activities is affected by the number of interested agencies and can prove complicated, this would require an agile program to accommodate contingencies.

Whilst it has been suggested that combined oversight will reduce the overall impost, it is clear that the activities may only be combined in that they can be conducted at the same venue at the same time, however some elements must be kept separate. Due to established DASA business processes, developed within the DASA QMS, it is important that DASA maintains lead for these activities.