Where to place the what/when/how/who/where procedures in a multi-regulation AS9110C organisation

#1
Hi All,

First time post here and I couldn't find a specific enough answer/topic which answered my question. Apologies, it might be a long post.

Background Information: The organisation I represent is AS9110C certified and holds approvals with both the Australian civil Part 145 approved maintenance organisation regulations (CASA) and the military Part 145 variation, known as DASA Part 145. We also have various other smaller certifications. As a result, we have two Maintenance Organisation Expositions (MOE's), which are roughly 100 pages each and satisfy each regulatory body (i.e. CASA & DASA). They are very similar but also different, so the decision was made originally to separate them. For non-Australians, CASA is basically Australia's version of EASA with some FAA type content and Australian peculiarities thrown in for good order.

We also have our AS9110C Quality Manual and a couple smaller volumes which are specific to the smaller standards. So, in total we have 5 'volumes' to our complete suite of quality manuals. As you might imagine, this becomes incredibly hard to manage and also train staff in our procedures. Currently, none of these volumes goes into the nuts and bolts of what a staff member should do for each procedure. They merely 'comply' and do not elaborate to the smaller details of how to perform each procedure. The AS9110C manual references the 'MOE's' a lot and I assume the idea was that for more detailed step-by-step guidance, the MOE's should be the place to look. However, the MOE's don't really go into any more details than the AS9110C manual.

What I want to achieve: I am wanting to add the specific 'how to' guidance on each procedure so that the suite of manuals is not just a compliance exercise but rather a living breathing suite which staff use for everything (i.e. more like an operations manual). I feel this will create the level of control required to better standardise what we do and remove important information from key peoples heads' so that we rely less on the people and more on the procedure. This is a key requirement of AS9110C and our auditor has mentioned this as an observation previously.

An example: Our calibrated tooling procedure mentions that we have a procedure, it involves a register, we allocate calibration intervals based on NATA guidance and other sources, we use an external calibration station, and we have a way of recording and tracking each item.

This is a very high-level description of what we do, designed around compliance with the regulations/standards. It doesn't provide enough information for someone unfamiliar with the process to perform the procedure in a step-by-step manner.

My Question/s: Where is the best place to put more detailed procedural information (e.g. it would include screenshots of software used, step-by-step guidance and other specific information like login credentials for software etc.) within a multi-layered QMS suite?

Placing this level of detail into the two MOE's would mean I need to do it twice (both CASA and DASA) or link one to the other with references, which might be confusing. It also means I would need to send both MOE's off to the regulator to approve/accept each time it changes.

Placing this into the AS9110C Quality Manual makes more sense to me because it doesn't need constant approval/acceptance and is less scrutinised word-for-word like the MOE's are during compliance audits. The confusing bit will be for the technical staff who might struggle to understand that the 'Quality Manual' has 'more information' than the MOE, which has historically been the document/s they would reference because AS9110 is a relatively rare and new concept for a business like us in Australia.

I want to streamline the whole system and remove the confusion over multiple manuals kind of talking about the same stuff but no one place doing a particularly good job of it. I also want the manual/s to be used as a genuine first reference point for everything we do, before engaging a senior member of staff. In flying operation businesses they usually use the 'Operations Manual' as the source of information for all matters and I would like our quality system to be used in a similar fashion.

For those of you who may of had exposure to multi-layered aviation QMS's, where do maintenance businesses typically put their operational procedures which go into great detail, their MOE's or their Quality Manual?

Any assistance would be greatly appreciated!

Thanks
 
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John Broomfield

Staff member
Super Moderator
#2
Agree with your idea that the Quality Manual could operate usefully as the key to the system but more as a website with hyperlinks than a hardcopy manual.

But should you have consulted the users on how they’d like to streamline “their” system?
 
#3
Agree with your idea that the Quality Manual could operate usefully as the key to the system but more as a website with hyperlinks than a hardcopy manual.

But should you have consulted the users on how they’d like to streamline “their” system?
Hi John,

Thanks for the suggestion of hyperlinks or some digital solution, I hadn’t considered having these digitally somewhere. I’m in the process of redoing our website too, so this might be a good time to have some form of intranet for staff setup.

The owner of the business is a bit afraid of modern cloud/digital storage services but this might be okay if it’s within our website server.

We’re a small team of 10 people and we have discussed how to make this information best available to all, however, there has not been much feedback. The aim of course is for it to be as simple and accessible as possible so that people actually use it when they’re unsure of a procedure. It will no doubt take time to change the culture within the team to use this ‘new’ source of information, rather than always asking the production manager everything first.
 

John Broomfield

Staff member
Super Moderator
#4
Another potential problem is repetition.

Does any requirement as a control, task or process need to be documented more than once? If so, how are you planning to keep track of all the instances?

For this you may need a database to share common documented requirements among the applicable subsystems within your organization working as a system.

...or is divergence to be expected and managed?
 
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