Relevant Language from EASA’s Supplier Control Mechanisms

In an earlier post, we reported on EASA’s formal endorsement of FAA Advisory Circular (AC) 00-56 and the ASA-100 quality standard (endorsing them as an acceptable mechanism for ensuring that a supplier’s quality assurance system meets EASA expectations).

These two documents form an important part of EASA’s recent publication on supplier control mechanisms.

Some of the readers have asked me to provide the relevant language of EASA’s endorsement; they’ve noted that the entire Decision includes six annexes in addition to the actual EASA decision (and is thus too long to navigate).   In response to these inquiries, I have put together a short (five page) set of excerpts that show the supplier control implementation in the recently-published EASA AMCs and GMs.

You can find a copy of the excerpts here, at this link: ED Decision 2019-009-R – Supplier Control Mechanisms Added to European Law (excerpts).

In summary:

  • EASA AMC1 145.A.42(b)(i) provides that the procedures for the acceptance of components, standard parts and materials should include supplier evaluation procedures;
  • EASA GM2 145.A.42(b)(i) explains what a supplier is, in order to assess who must be controlled (find out more in our earlier article on supplier definition);
  • EASA GM3 145.A.42(b)(i) describes the elements that should be considered when evaluating a supplier’s quality system, and it explains that suppliers accredited to ASA-100 an AC 00-56 are acceptable;

 

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CCMA Kicks Off

CCMA opened with over 600 regular supplier attendees and over 70 airline participants. ASA was invited to address the airline closed meeting on strategies for airline use of additive manufacturing and we discussed the importance of both supplier control and manufacturing process control over n implementing additive manufacturing as a production method. We also discussed the proposition that additive manufacturing is a technology that suppliers may be able to use to better support airline needs, so air carriers should be prepared to work with their suppliers on additive manufacturing methods.

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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