Europe Formally Recognizes AC 00-56 and ASA-100

The European Union has formally recognized FAA AC 00-56 and ASA-100 as acceptable methods for supplier evaluation.

Some of you will remember that ASA was working with the European Aviation Safety Agency (EASA) to establish protocols for aircraft parts suppliers.  EASA examined various proposals for regulating distributors, and ultimately concluded that the FAA’s Voluntary Industry Distributor Accreditation Program was an appropriate model upon which to rely.  EASA sought comments on the proposal and ultimately issued a recommendation to the European Commission.

The first part of that recommendation was acted upon in August when the European Commission issued a new rule that required repair stations (EASA 145 organization) to

“establish procedures for the acceptance of components, standard parts and materials for installation to ensure that components, standard parts and materials are in satisfactory condition and meet the applicable requirements”  EASA 145.A.42(b)(i).

The second part of that recommendation has been implemented in ED Decision 2019/009/R.  This Decision provided guidance on what it means to establish the above procedures.  First, the guidance clarifies that “[f]or the acceptance of components, standard parts and materials from suppliers, the [] procedures should include supplier evaluation procedures.” AMC1 145.A.42(b)(i) Components, section (b).   At first glance, this appears to impose a huge new obligation on repair stations to evaluate suppliers.  But EASA has offered an easy way to meet this evaluation obligation, by relying on the existing infrastructure for supplier evaluation.

GM3 145.A.42(b)(i) Components explains how to evaluate suppliers.  It explains that a suppliers’ quality system should have certain elements.  It also permits reliance on suppliers known (through external auditing) to meet four standards that are considered acceptable: AC 00-56, ASA-100, AS/EN9120 and EASO 2012.  This means that a 145 organization can rely on a supplier that was audited to such a standard, and does not have to perform its own evaluation.  The basis for endorsing each of these standards was an analysis of each standard by EASA that found that each was in compliance with the list of elements published in this GM.

I was part of the EASA rulemaking team that performed the evaluations, so I know that EASA put a lot of effort into validating that the Voluntary Industry Distributor Accreditation Program was acceptable for use in Europe.  The entire industry of accredited distributors should be proud of this recognition, because it is the result of 25 years of commitment to safety and quality.

This is great news for the community of accredited distributors.  This verifies that aircraft parts installers who rely on AC 00-56 as an element of their supplier selection process are doing the right thing.  It also confirms that the global norms for supplier evaluation are working to enhance safety.

 

Look for tomorrow’s article on how broad is the European definition of “supplier.”

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ASA in China

Next week, ASA will present at the 2016 China Aviation & MRO/Aftermarket Conference.  We will be discussing the value that AC 00-56B brings to air carriers and MROs, and explaining how Chinese air carriers can use the FAA’s accreditation database to identify foreign aircraft parts distributors with effective quality assurance systems.

We will also participate on a panel discussing how to “Improve the Information Sharing Level of Air-material Supply Chain and Optimize the Inventory Management Mode.”

According to the organizers’ website, they expect the attendance of 26 airlines from China and surrounding nations.  This should be a great opportunity for ASA members to network and build business relationships in China.

If you haven’t yet registered, and you do business (or want to do business) in China, then now is the time to register!

 

ASA Quality Assurance Commitee Meets this Sunday (June 7)

Don’t miss the ASA Quality Assurance Committee meeting, coming up in a week.  We will focus on the newly revised FAA Advisory  Circular, AC 00-56B.  This update to the Voluntary Industry Distributor Accreditation Program reflects the next evolution for our industry.  The FAA will be on-hand to answer your questions.

In addition, the agenda will feature some new changes to the program and some new tools to help support compliance (including new corrective action forms, and new guidance on self evaluation and corrective action procedures).  The afternoon will feature a look at the new ASA guidance on electro-static discharge (ESD) sensitive equipment, best practices for drop shipments, disclosure statements (like non-incident statements), and a system for labeling chemicals in your facility.

When: June 7, 2015 from 8:30 am until 3:00 pm

Where: Hyatt Regency at Gainey Ranch Resort, 7500 E Doubletree Ranch Rd, Scottsdale, AZ 85258

Cost: None!

Please register online if you intend to be there, so we can have an accurate headcount for lunch and breaks.  There is no cost to register for the ASA QA meeting!  The meeting is open to all ASA members.  If you are not an ASA member but want to attend, then please contact us, as we frequently welcome non-members to attend.

TENTATIVE MEETING AGENDA (subject to change)

 

8:30 am Welcome and Introductions; Antitrust Statement Anderson, George, J Dickstein, Committee
8:40 am ASA Announcements M Dickstein
8:50 am ASAAP Update M Dickstein
9:00 am FAA Presents AC 00-56B (Revision) Martineau
9:55 am Discussion of ASA-100 revisions necessary to support the AC 00-56 Revision J Dickstein, M Dickstein, Resto, Committee
10:15 am BREAK
10:45 am Continued discussion of ASA-100 revisions necessary to support the AC 00-56 Revision J Dickstein, M Dickstein, Resto, Committee
11:00 am ASA Corrective Action Form O’Connor
11:30 am ASA Corrective Action Letter of Interpretation J Dickstein, Lyon, O’Connor
Noon LUNCH
1:00 pm ESD Best Practices Resto
1:20 pm Drop Shipment Procedures Resto
1:40 pm OSHA’s GHS (Globally Harmonized System of Classification and Labeling of Chemicals) Regulations Chen
2:10 pm Disclosure Statements J Dickstein
2:30 pm Putting Together an Education Program Related to Disclosure Statements Anderson
2:50 pm New Business/Next Meeting Committee
3:00 pm ADJOURN

 

Thank you to AerSale, Inc. for sponsoring this meeting!

FAA issues REVISED AC 00-56B – Voluntary Industry Distributor Accreditation Program

The FAA has issued the long-awaited revision to AC 00-56. This advisory circular describes the Voluntary Industry Distributor Accreditation Program (VIDAP).

This is the “B” revision, and it includes statements about a number of issues that have been part of the FAA’s understanding of the program (so they were part of the ASA implementation based on FAA input) but that had not previously been in print.  It also updates the language to a “plain language” format as well as clarifying some points that had been vague.

The updated version of the AC will be available on the main FAA website; however as of 1:00 pm today it was not yet available.  This is not unusual, and we expect that it should be available on the FAA’s main website by Monday.

However, it *IS CURRENTLY AVAILABLE* in the Regulatory and Guidance Library (RGL).   If the link to the RGL does not work then just go to rgl.faa.gov and use the search engine to find 00-56B.

The ASA Quality Assurance Committee (QAC) will meet on June 7, 2015 in Scottsdale Arizona (click here for more information on the meeting) to discuss the changes in-depth and to consider whether any additional changes to ASA-100 are necessary to reflect the changes to the AC.  The FAA is expected to present the AC at this meeting, and to be available to answer questions.

This ASA QAC meeting is part of the ASA Annual Conference.  We look forward to seeing you there!

ASA DRAFT Comments on AC 00-56B are available for member review before we submit them to the FAA

As we noted in an earlier post, AC 00-56B is out for comment.

ASA will be filing comments on this important document; we encourage everyone to review this document and to provide constructive comments to the FAA to improve the document.

Here are our DRAFT comments:  2015-01-04 – AC 00-56B Comments from ASA (DRAFT for member review). Anyone that wants to provide ASA with additional comments for consideration should get them in to us by noon on January 2, 2015.

Accreditation Alert! DRAFT AC 00-56B is out for comment!

The FAA has released for public comment AC 00-56B, which is the draft revision to the Voluntary Industry Distributor Accreditation Program (current version is AC 00-56A).

This draft FAA advisory circular (AC) describes a system for accrediting aircraft parts distributors based on compliance to a standard and certification of that compliance by FAA-acceptable accreditation organizations.  ASA has been part of this program since the beginning, and is an important FAA partner in the mission to improve aviation safety through effective management systems.

The FAA has strongly endorsed participation in the AC 00-56 program.  FAA is revising this AC to reflect the changes in regulatory requirements and industry practices since the last revision.

ASA met with its Quality Assurance Committee (QAC) on December 5 to review and examine this proposed change.  The QAC was generally supportive of the draft AC, and spent its time examining ways to further improve the document.  ASA is in the process of developing comments based on that QAC meeting.  Those comments will address subjects like these:

  • A transition mechanism for ensuring that industry has time to come into compliance with the new standards
  • Firming up an accurate description of the the relationship between the accreditation organization and the quality system standard holder
  • Firming up an accurate description of the the relationship between the accreditation organization and the FAA
  • Clarifying the definition of distributor
  • Clarifying the definition of Distributor Accreditation
  • Clarifying the definition of Quality System
  • Clarifying the definition of Traceability so it is consistent with current industry connotations
  • Using terminology that is consistent with other FAA guidance
  • Ensuring that FAA audit expectations are adequately described
  • Ensuring that FAA requirements for auditors adequately reflect current industry best practices
  • Clarifying the FAA’s changes in the quality system elements
  • Ensuring that citations to statutes and standards are correct
  • Updating the documentation matrix to reflect current standards and also to reflect the current global nature of the AC 00-56 program

The documentation matrix was subject to significant discussion, and the QAC worked on a proposal to further strengthen the matrix in order to support both current and future industry ‘best practices.’

The draft is open for public comment through January 4, 2015.  Comments should be delivered to

Robert McDonald
1625 K Street NW
Suite 300
Washington, DC 20006

Comments can also be emailed to Robert.CTR.McDonald@faa.gov or faxed to (202) 223-4615, Attn: Robert McDonald.

Please also send a copy of your comments to ASA, so that we can be sure that your views are reflected in the Association’s comments.

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