ASA Continues to Work with EASA on Distributor Issues

In November, ASA will meet again with EASA to discuss the proposed Supplier Control rule for Part 145 maintenance organizations.

Under the proposed rule, Part 145 maintenance organizations would be required to take steps to ensure the airworthiness of the parts that they receive.  This is already a part of the EASA guidance, and is merely being made more explicit in the rules.

The real change under the proposed rule is expanded guidance about methods for effective quality assurance.  The guidance recommendations are focused on two elements that should come as no surprise to anyone in the aviation parts industry: (1) effective receiving inspection, and (2) robust supplier control.

The proposed rule recognizes that the industry has developed a very effective mechanism for aftermarket supplier control, and it endorses this effective mechanism.  It explains that although a Part 145 maintenance organization can perform its own supplier auditing, reliance on certain industry-accepted third party auditing mechanisms has become standard in the industry.  Based on nearly twenty years of success, the proposed rule recognizes that AC 00-56, and the standards that it endorses, represents a sound method for ensuring that effective quality controls are exercised in the aircraft parts distribution chain.

In addition to recognizing reliance on AC 00-56 as an effective tool to support supplier quality assurance, the proposed guidance also lays out the elements of an effective distributor quality system (the proposed rule includes an analysis in the appendices to show that ASA-100 already meets the new European requirements).

This European effort helps to validate the notion that companies that voluntarily adopted AC 00-56 (and ASA-100) compliant systems were doing the right thing.

When ASA meets with EASA in early November, we will be discussing the industry comments on the proposed rule, and how best to adopt those comments into the final rule.  Any ASA members who has comments on the proposed rule or the related guidance should make sure to get them to ASA before the end of October.

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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 ASA Continues to Work with EASA on Distributor Issues

  1. dauphin17 says:

    We appreciate your work and efforts in having EASA move towards accepting AC 00-56 as the aerospace industry standard for distributor approval Jason. Also hoping that this won’t mean National Aviation Authorities becoming responsible for auditing whichever standard they choose to adopt however; that would be a bureaucratic bundle of non-fluffiness IMO.

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