ASA Petitions FAA for Extension of DAR-56 Program

Last week ASA submitted a petition to the FAA formally requesting the indefinite extension of the Limited DAR-F Program for Accredited Distributors–commonly known as the DAR-56 program–that is scheduled to expire September 30, 2017.  ASA further requested an expansion of the program to better reflect the needs of the distribution community.  You may also recall that ASA recently led an industry effort that secured the reissuance of FAA Notice 8900.380 for another year. Both of these efforts are in response to the 8130-3 tag requirements arising out of MAG 6, which put billions of dollars of distributor inventory at risk.

ASA explained in its petition to extend DAR-56 indefinitely that the facts that gave rise to the need for the DAR-56 program have not changed and that the need for the program to continue was therefore very important to distributors.  The DAR-56 program permits Limited DAR-F’s to issue 8130-3 tags for parts on the basis of specific indicia of sourcing from the PAH.

As attendees of the ASA conference heard from members, distributors have so much inventory that needs to be tagged under the DAR-56 program that it could literally take years to tag every part.  This includes vast numbers of small, low-dollar-value parts for which hiring an independent designee would be economically infeasible.  ASA therefore proposed an indefinite extension of the program with semi-annual meetings between the FAA, ASA, and interested parties to discuss the ongoing need for the program so that it can be discontinued after a permanent solution is developed.

In addition to proposing an indefinite extension of the DAR-56 program (rather than annual extensions requiring yearly petitions and discussions), ASA also recommended changes that would improve the effectiveness of the program and help distributors.

At present, the DAR-56 program permits Limited DAR-F’s to issue 8130-3 tags under the following criteria:

  1. The aircraft part was received by the distributor prior to November 1, 2016 and
  2. The aircraft part must bear specific indicia of production under 14 C.F.R. Part 21:
    1. A certificate or statement of conformity that was issued by the production approval holder (any documentation part numbers and serial numbers, if applicable, must match any part markings); or,
    2. A certificate or statement of conformity that was issued by the production approval holder’s supplier, and a verification of direct shipment authorization; or,
    3. Markings regulated under 14 C.F.R. 45.15 and describing the PAH’s name or other identification (for parts, this would typically be limited to PMA, TSOA or critical parts).

ASA recommended that the program be extended as follows:

  1. The program be expanded to include any aircraft part that was received by the distributor at any time when the distributor was accredited under the AC 00-56 program.
  2. Expand the acceptable indicia of production under an FAA production approval to include other documentation the FAA has previously recognized:
    1. For an aircraft part that was accepted into an air carrier’s inventory system as new article, and then subsequently released from that air carrier’s inventory system, a document from the air carrier identifying the part by part number, and by serial number where appropriate, and identifying the part as new (including new surplus); or
    2. A maintenance release document showing (i) that the part was inspected under 14 C.F.R. Part 43 by a person authorized to approve such work for return to service, (ii) that the part was found to be in new condition, and (iii) a part number that matches a number known to be a PAH part number, and that matches the part number on the part, where applicable.

These proposed expansions reflect the fact that the November 1, 2016 receipt date appeared wholly arbitrary and neither supported nor required by any regulatory basis, and that the two additional forms of documentation are commonly accepted in the industry under Part 21 of the regulations.  This would solve the problem of those parts that are currently still being received without tags (as they continue to be released from PAH’s who do not issue tags, or as new surplus from air carriers without tags) and those parts that currently have PAH documentation but are nonetheless excluded under the terms of the current program.

ASA appreciates the FAA’s collaborative efforts to work with us to extend the DAR-56 program as we work toward a permanent solution to the MAG 6 8130-3 tag issue.  We will keep our members updated as we hear more from the FAA.

 

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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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