Distributor Quality Questionnaire: Questions About Your Library

I recently heard from an ASA member who had received a distributor quality questionnaire.  The questionnaire asked whether the company maintained current copies of certain documents in their files.  The documents requested were:

Questions from Supplier Questionnaire

Questions from Supplier Questionnaire

  • AC 20-62D
  • AC 21-20B
  • AC 21-29C
  • Order 8110.42

While it is useful for distributors to draw upon FAA guidance documents for reference, it is important to make sure you are referencing documents that are useful to your business, and that reflect current guidance.  Some of the documents requested in this distributor questionnaire failed to meet either of these criteria.

It is also useful to remember that so much guidance is readily available online, and it is normal for distributor personnel to have internet access today, so it may no longer be necessary for businesses to maintain actual paper libraries. Knowing where to access these documents online or maintaining electronic copies may be adequate for many distribution businesses, especially if that is part of your method for ensuring that you are relying on the most recent revision levels of the guidance.  I have included links to the relevant documents, below (NOTE: for some businesses, the easiest course of action in responding to a question like this is to simply download the documents and then check “Yes” on the form).

The ASA member asked whether, as a distributor of aircraft parts, his/her company was obliged to comply with the four guidance documents listed. The short answer that I gave the ASA member was that an aircraft parts distributor who does not possess any additional FAA certificates is not required to comply with any of them, but some of them may be useful to a distributor.  Others, however, do not apply to a distributor’s business model and are useful only for achieving a better understanding of other sectors of the industry. Here is some more specific information on each of the four documents:

AC 20-62D: First of all, the most current revision level is AC 20-62E, so that is the one that should be referenced. While this guidance is not mandatory, AC 20-62E does provide some useful information about identifying replacement parts (e.g. by documentation or by parts marking), which is especially useful for a distributor’s receiving inspectors and quality department.  I recommend that this be part of a distributor’s library and also be used as part of the internal training program.

AC 21-20B: This advisory circular was meant to provide guidance for production approval holders who perform supplier surveillance.  While you mighty glean some ideas from it, it is outdated – it was supplanted by the “C” revision in 1996 and the “C” revision was cancelled in 2009 when the new quality assurance regulations were published (the current version of 14 C.F.R. 21.137 establishes a different model for supplier oversight).  Today, you can find supplier oversight discussions in AC 21-43.  Distributors who are supplying material to production approval holders may want to read AC 21-43 in order to better understand the obligations imposed on their business partner.

AC 21-29C: This advisory circular provides guidance distinguishing approved parts from unapproved parts. This can help in distinguishing parts that are considered acceptable by the FAA from unacceptable ones, but you should remember that these distinctions are not always perfectly aligned with the regulations.  Nonetheless, this was originally written by the FAA as a tool to assist industry in identifying aircraft parts that the FAA considers to be categorically acceptable for installation, and it remains an excellent tool.

Order 8110.42: This is the FAA’s Order explaining how to process PMA applications. The current revision level is 8110.42D.  Prior revision levels had included guidance that was really aimed at industry, but this Order has been redrafted to separate out the industry guidance and move it to advisory circulars.  If you want to learn more about test-and-computation PMA applications from the applicant’s side, then you should first study AC 21.303-4. But Order 8110-42 guidance, per se, does not apply to a distributor – it is meant for the FAA employees who interact with PMA applicants.

Given the fact that many years have passed since some of these documents were superseded, it appears that the questionnaire that was sent to this member may need to be updated.  A safer way to reference FAA guidance is to drop the revision letter and simply ask for the current revision level (so when a revision level changes, the document may not need to be changed).  But this does not mean that you should ignore a periodic review of your questionnaires!  AC references can change, specially when there are major changes in the underlying regulations.  For example, AC 21-20C was cancelled and replaced by AC 21-43 after major changes in part 21 (AC 21-43 pulled together a set of guidance and took the place of several different guidance documents).  So this underscores the importance of checking your distributor quality questionnaires, to make sure they remain current!

Got questions about the FAA’s regulations and policy?  Want to make sure you are keeping safe and compliant?   Attend one of the ASA Regulatory Workshops!  We have regulatory workshops coming up in Newark (next week!), South Florida (October 14) and Los Angeles (October 16).  The agenda is available online and you can register on ASA’s website.  These classes are an inexpensive way to train your staff about the changes in regulations and policy that affect your business.  I hope that I will see you there!

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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.

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