EASA Proposal Would Recognize ASA-100 Accreditated Suppliers

EASA has published a new draft rule for public comment.  This new rule would form the basis of European recognition of distributor accreditation.  Formal European recognition of distributor accreditation is something that ASA has been working on for many years; most recently as a member of the EASA Working Group that helped to craft the rule.

The draft rule is known as NPA 2012-03.  The title of the draft is ‘Control of suppliers of components and material used in maintenance.’

Under the new rule, maintenance organizations, like repair stations, are provided with guidance about acceptable practices for managing sources of supply.  The change is accomplished by a minor change to the EASA rules that apply to maintenance organizations, and a more significant change to the EASA guidance material.  The new rule language requires 145 organizations to “establish procedures for the acceptance of components and material.”  The proposal also includes substantial guidance material to explain what this means, from a practical standpoint. To begin with, the guidance material makes it clear that maintenance organizations can inspect parts to ensure airworthiness, but that reliance on credibility of sources to support the finding of airworthiness is also a piece of the analysis.

AMC 145.A.42 (a) Acceptance of components

The procedures for acceptance of components should have the objective of ensuring that the supplied components and material are in satisfactory condition and meet the organisation’s requirements. These procedures may be based upon:

1) incoming inspections which include:

  • physical inspection of components and/or material;
  • review of accompanying documentation and data, which should be acceptable in accordance with 145.A.42(e).

2) supplier evaluation and control.

The guidance goes on to explain that an organization may choose to directly evaluate sources (suppliers) or it may rely on a third party to do so.  The guidance material recommends the following standards as typical elements for a supplier’s quality system:

GM 145.A.42 (a) Supplier evaluation and control

1) The following elements may be checked for the evaluation and control of a supplier’s quality system, as appropriate, to ensure that the component and/or material is supplied in satisfactory condition:

a. Availability of appropriate up to date regulations, specifications such as component manufacturer’s data and standards;

b. Standards and procedures for training of personnel and competency assessment;

c. Procedures for shelf-life control;

d. Procedures for handling of electrostatic sensitive devices;

e. Procedure for identifying the source from which components and material were received;

f. Purchasing procedures identifying documentation to accompany components and material for subsequent use by approved Part-145 maintenance organisations;

g. Procedures for incoming inspection of components and materials;

h. Procedures for control of measuring equipment that provide for appropriate storage, usage, and for calibration when such equipment is required;

i. Procedures to ensure appropriate storage conditions for components and materials that are adequate to protect the components and materials from damage and/or deterioration. Such procedures should comply with manufacturers’ recommendations and relevant standards;

j. Procedures for adequate packing and shipping of components and materials to protect them from damage and deterioration, including procedures for proper shipping of dangerous goods. (e.g. ICAO and ATA specifications);

k. Procedure for detecting and reporting of suspected unapproved components;

l. Procedure for handling unsalvageable components in accordance with applicable regulations and standards;

m. Procedures for batch splitting or redistribution of lots and handling of the related documents;

n. Procedure notifying purchasers of any components that have been shipped and have later been identified as not conforming to the applicable technical data or standard;

o. Procedure for recall control to ensure that components and materials shipped can be traced and recalled if necessary; p. Procedure for monitoring the effectiveness of the quality system.

Finally. the new guidance explains that certain standards are known to be acceptable:

2) Suppliers certified to officially recognised standards that have a quality system that includes the elements specified in 1) may be acceptable; such standards include:

a. EN/AS9120 and listed in the OASIS database;

b. ASA-100;

c. EASO 2012;

d. FAA AC 00-56.

The use of such suppliers does not exempt the organisation from its obligations under 145.A.42 to ensure that supplied components and material are in satisfactory condition and meet the applicable criteria of 145.A.42(e).

The appendices to the proposal show correspondence tables that demonstrate the acceptability of each of the above standards.

The last element of the above guidance, explaining that use of accredited suppliers “does not exempt the organisation from its obligations under 145.A.42 to ensure that supplied components and material are in satisfactory condition and meet the applicable criteria of 145.A.42(e),” means that the other regulatory requirements, like documentation requirements, continue to apply regardless of source.

For Americans, it is important to remember that the all maintenance in the European system is performed by Part 145 organizations.  Even air carriers must have 145 certificates in order to maintain their own aircraft.  So a European rule that affects maintenance providers will affect all European purchasers of parts.  It will also affect many U.S. repair stations, because a significant number of U.S. repair stations are EASA 145-accepted, which means that they conform to both U.S. regulations and European regulations.

ASA is pleased that this allows the U.S. and Europe to rely on harmonized standards of distributor accreditation, that recognize popular accreditation standards like ASA-100 and the other standards accepted under FAA AC 00-56.

Comments on the draft rule are due July 12, 2012.  They may be submitted by posting them on the Comment-Response Tool (CRT) available at http://hub.easa.europa.eu/crt/, or by mail to:

Process Support
Rulemaking Directorate
EASA
Postfach 10 12 53
50452 Cologne
Germany

Please send copies of your comments to ASA as well, so we can be sure to reinforce and support our members’ comments.

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

One Response to EASA Proposal Would Recognize ASA-100 Accreditated Suppliers

  1. Pingback: EASA Takes Another Step Toward Formal Recognition of Accreditation | ASA Web Log

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