Concession control for deviations from an organization's procedures

          Concession control for deviations from an organization's procedures in an Approved Maintenance Organization (AMO) is a critical aspect of maintaining safety, compliance, and quality standards. Concession control involves the management of non-conformances and the authorization of deviations from established procedures under specific conditions. Here’s a detailed guide on how to establish and manage concession control in an AMO:

Key Elements of Concession Control

1. Definition and Scope:

   • Clearly define what constitutes a concession or deviation from standard procedures.
   • Establish the scope of concession control, including the types of deviations that can be considered and the limitations.

2. Authority and Responsibility:

   • Designate individuals or a committee with the authority to review, approve, or reject concessions.
   • Define the roles and responsibilities of personnel involved in the concession process.

3. Concession Request Process:

   • Develop a standardized process for requesting concessions, including the required documentation and information.
   • Ensure that concession requests include details such as the nature of the deviation, justification, potential impact, and proposed mitigation measures.

4. Review and Approval:

   • Establish criteria for evaluating concession requests, including safety, regulatory compliance, and operational impact.
   • Implement a review process involving relevant experts (e.g., engineering, quality assurance, safety) to assess the concession request.
   • Ensure that all approved concessions are documented, including the conditions under which they are granted.

5. Implementation and Monitoring:

   • Ensure that approved concessions are communicated to all affected personnel and properly implemented.
   • Monitor the implementation of concessions to ensure compliance with the specified conditions and to identify any unforeseen issues.

6. Record Keeping:

   • Maintain detailed records of all concession requests, including approvals, rejections, and associated documentation.
   • Ensure that records are easily accessible for review and audit purposes.

7. Review and Continuous Improvement:

   • Periodically review concession control processes to identify areas for improvement.
   • Analyze concession data to identify trends and implement corrective actions to minimize the need for future concessions.

Concession Control Procedure

1. Initiating a Concession Request:

   • Identification: Identify a situation requiring a deviation from standard procedures.
   • Documentation: Complete a concession request form, providing all necessary details, including:
     • Description of the deviation.
     • Reason for the deviation.
     • Impact assessment (safety, regulatory, operational).
     • Proposed mitigation measures.
     • Duration of the concession (temporary or permanent).

2. Review and Evaluation:

   • Initial Review: Conduct an initial review to ensure the request is complete and justified.
   • Technical Assessment: Involve relevant technical experts to evaluate the impact of the deviation and the effectiveness of the proposed mitigation measures.
   • Risk Assessment: Perform a risk assessment to evaluate the potential impact on safety and compliance.

3. Approval Process:

   • Approval Authority: Forward the concession request to the designated approval authority (e.g., engineering manager, quality manager, safety manager).
   • Decision: The approval authority reviews the request, considering the technical assessment and risk evaluation, and makes a decision to approve or reject the concession.
   • Documentation: Document the decision and any conditions attached to the approval.

4. Implementation and Communication:

   • Implementation: Communicate the approved concession and any conditions to all affected personnel and ensure it is implemented as specified.
   • Monitoring: Monitor the implementation to ensure compliance with the conditions and to identify any issues that arise.

5. Record Keeping and Reporting:

   • Record Maintenance: Maintain a comprehensive record of all concession requests, decisions, and related documentation.
   • Reporting: Periodically report concession activity to senior management and regulatory authorities as required.

6. Review and Continuous Improvement:

   • Periodic Review: Conduct regular reviews of concession control processes and records to identify trends and areas for improvement.
   • Feedback Loop: Use feedback from personnel and analysis of concession data to improve procedures and reduce the occurrence of deviations.

Best Practices for Concession Control

• Clear Criteria: Establish clear criteria for what constitutes a deviation and when a concession can be granted.
• Thorough Documentation: Ensure all concession requests and approvals are thoroughly documented, including justifications and risk assessments.
• Stakeholder Involvement: Involve relevant stakeholders (e.g., engineering, quality assurance, safety) in the review and approval process to ensure a comprehensive evaluation.
• Transparency: Maintain transparency in the concession process, ensuring that all decisions are well-documented and communicated to relevant parties.
• Continuous Improvement: Regularly review and refine concession control processes to enhance efficiency and effectiveness.

Conclusion

Effective concession control is essential for managing deviations from established procedures in an AMO. By implementing a structured process for requesting, reviewing, approving, and monitoring concessions, an AMO can ensure that deviations are managed in a controlled and transparent manner, maintaining safety, compliance, and quality standards.