ASA Meets with Zhengzhou University of Aeronautics

May 10, 2019: Jason Dickstein meets with faculty from the Zhengzhou University of Aeronautics

May 10, 2019: Jason Dickstein meets with faculty from the Zhengzhou University of Aeronautics

ASA met today with a delegation from the Zhengzhou University of Aeronautics.

The Zhengzhou University of Aeronautics, is a university located in Zhengzhou, Henan, China.  University staff are helping to develop the Zhengzhou Airport Economy Zone, and are interested in learning about norms for aircraft parts distribution.

ASA discussed the international norms for design and production approval of aircraft products and articles.  We discussed the specific ways that those norms are implemented in Europe and North America.  We also discussed the EU and US standards for installing aircraft parts, and the role that distributors play in the chain of commerce from approved part manufacturing to installation of those same parts. We discussed ASA’s role in distributor accreditation and our recent meetings with CAAC and CAMAC to discuss partnering with them on safety promotion.

The group had a lot of questions about distributor accreditation and about business norms in our industry.

The University has more than 28,000 full-time students and appears to offer a wide variety of aviation-related degrees (they also offer non-aviation degrees in other fields like law).  Keeping the faculty informed about the industry’s opportunities is just the first step in ensuring that the next generation is prepared to improve safety and push the boundaries of excellence.

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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.”

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.

EASA Takes Another Step Toward Formal Recognition of Accreditation

Europe has taken the next step towards formal recognition of the distributor accreditation program.

On December 10th, the European Aviation Safety Agency (EASA) issued its Comment Response Document (CRD) for “Control of suppliers of components and materials used in maintenance.”  This CRD contains the comments received on the Notice of Proposed Amendment (NPA) for the Supplier Control rule.

This changes would require EASA 145 organizations to have a method for assuring the satisfactory condition of the aircraft parts that they receive, and would recommend receiving inspection and supplier control as methods to achieve that end.  Related guidance explains that reliance on accredited distributors (explicitly including ASA-100 accredited distributors) would be a satisfactory way to meet the supplier control element.  A complete discussion of the proposal can be found in an earlier blog post on the NPA.

This is not yet law in Europe.  The next step will be for the European Commission to issue an amendment that features the regulatory changes, and then EASA would issue a Decision that adopts the changes to the advisory/guidance materials.

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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