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									1/10/2011   Compliance Requires Objective Evidence   1
                     Welcome



                  C.A.S.E. Standard 3A
             Quality Program Requirements
            Distributors of New and Used Parts


1/10/2011          Compliance Requires Objective Evidence   2
            Course Outline
History of surplus parts
DOCUMENTARY - “the risk is onboard”,
 the illegal trade in BOGUS AIRCRAFT
 PARTS
C.A.S.E. Standard 3A
Review of AC 00-56



1/10/2011    Compliance Requires Objective Evidence   3
            Course Outline Cont’d
FAA unapproved parts video
Review
Test




1/10/2011      Compliance Requires Objective Evidence   4
   History of Surplus A/C Parts
After World War II
     Military surplus
     Start up of 707 & other commercial programs
     Big business - much money
       High demand = $$$
       Illegal trade & bogus parts




1/10/2011       Compliance Requires Objective Evidence   5
              It’s Show Time
NORWEGIAN DOCUMENTARY
     “The Risk is Onboard, the illegal trade in
      BOGUS Aircraft Parts”




1/10/2011        Compliance Requires Objective Evidence   6
              After The Show
NORWEGIAN DOCUMENTARY
     “The Risk is Onboard, the illegal trade in
      BOGUS Aircraft Parts”
COMMENTS




1/10/2011        Compliance Requires Objective Evidence   7
            C.A.S.E. Standard 3A
Why the 3A Standard
     Bogus / unapproved parts
       Not to specs
       Critical items with high $ value
     A system to prevent fraud




1/10/2011        Compliance Requires Objective Evidence   8
            C.A.S.E. Standard 3A
Things to keep in mind
     Auditing distributor
       Review P. O. History
       Review quality manual
         Say what you do
       Review quality system
         Do what you say
       Review self-audit system
         Are they policing themselves
         Part of management process
1/10/2011       Compliance Requires Objective Evidence   9
            C.A.S.E. Standard 3A
Thing to keep in mind (cont’d)
     Training vs. Qualification
     Purchases - Sales = Inventory
       Accountability for stock
     AIRLINES MUST COMPLY WITH FARs;
      Therefore, suppliers must provide proper
      documentation



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            C.A.S.E. Standard 3A
Things to keep in mind (cont’d)
     Traceability
            Suppliers must have traceability not
             only to the part source, but also to the
             purchaser of the part
              notify in case of an incident



1/10/2011           Compliance Requires Objective Evidence   11
            C.A.S.E. Standard 3A
Definitions (from AC 00-56)
     Distributors - suppliers, brokers, dealers,
      resellers, or other persons and agencies engaged
      in the sale of parts for installation in type-
      certificated aircraft, aircraft engines, propellers
      and in appliances
     Distributor Accreditation - recognition of the
      distributor’s quality system by an industry
      group. (CASE, SAE, ANSI, ASA, DOT)


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            C.A.S.E. Standard 3A
Definitions (cont’d)
     Quality System - distributor’s total network of
      administrative and detailed procedures, which
      is implemented to ensure that the parts sold by
      the distributor satisfy the customer’s
      requirement and the documentation accurately
      reflects the criteria identified in the purchase
      order



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            C.A.S.E. Standard 3A
Definitions (cont’d)
     Quality System Standards - criteria developed
      by various organizations that will provide
      means to ensure that parts reflect the
      appropriate quality
     Self-Evaluation - a continuous program that the
      distributor applies to evaluate its own
      compliance with its quality system



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            C.A.S.E. Standard 3A
Definitions (cont’d)
     Traceability (chain of custody) - the ability via
      documentation or electronic means to track
      parts, processes, and materials by such means
      as lot number, or serial number to the O.E.M.
      or other acceptable source
     Quality System Standards Organizations -
      organizations that have developed quality
      system standards to be utilized by others


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                     1) General
A. Describes minimum requirements for
 quality programs
     New aircraft parts / materials distributors
     Surplus aircraft parts distributors
            Designed to aid surveillance
            Used to determine adequacy of
             distributors’ quality program


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              1) General (Cont’d)
B. Compliance with standard
     Not an automatic entry into the C.A.S.E.
      Register
C. Distributors subject to audit
            any time during business hours
            conducted by customer or another
             CASE member
               May be scheduled
               May be unannounced
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              1) General (Cont’d)
D. Acceptable Audit
     Does not relieve distributors’ of responsibility
      for
            Maintaining consistently acceptable
             quality system standards
              FAA: any system that allows
               exceptions is no system


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            1) General (Cont’d)
E. Audit to C.A.S.E. Standard 3A
 Not interchangeable or substitutable with
   C.A.S.E. Standard 1A
            Repair stations provide services
             beyond scope of material control and
             distribution
            Exchange programs
              Add parts of 3A std. and
                Checklist to 1A to verify
                traceability on parts associated
                with exchange pool
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            1) General (Cont’d)
F. Quality Parts and Materials
 Necessary to Support Compliance to
   Applicable FARs as defined in AC 20-62
    21.303 (replacement and modification
     parts)
    121.215 (cabin interiors)
    121.312 (materials for compartment
     interiors)
    121.363 (responsibility for airworthiness)
    135.143 (general requirements)

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              1) General (Cont’d)
F. Quality Parts and Materials
     Suspected Unapproved Parts (SUPS)
            segregated and secured
            reported in accordance with AC 21-29
              FAA Form 8120.11



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              1) General (Cont’d)
F. Quality Parts and Materials
 Related Reading Material
     Advisory Circular AC00 - 56
              Voluntary Distributor Accreditation
            Advisory Circular AC20 - 36
              index; articles certified under TSO
            Advisory Circular AC20 - 62
              Aeronautical Replacement Parts

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              1) General (Cont’d)
F. Quality Parts and Materials Related
            Reading Material (cont’d)
            Advisory Circular AC21 - 2
              Export Airworthiness Approval
               Procedures
            Advisory Circular AC21 - 20
              Supplier Surveillance Procedures
            Advisory Circular AC21 - 29
              Reporting of Unapproved Parts
               FAA Form 8120.11
                (Malfunction and Defect Report)
1/10/2011           Compliance Requires Objective Evidence   23
              1) General (Cont’d)
F. Quality Parts and Materials
 Related Reading Material (cont’d)
     Advisory Circular AC21 - 38
            disposition of unsalvageable aircraft
             parts and materials
            may send letter to owner and have him
             sign it acknowledging the return of
             scrap parts
            may keep a file of scrap parts that are
             returned, including serial numbers

1/10/2011           Compliance Requires Objective Evidence   24
            1) General (Cont’d)
F. Quality Parts and Materials
 Related Reading Material (cont’d)
    Advisory Circular AC21.303 - 2
      announcement and availability:
       PMA
    Advisory Circular AC43 - 9
      Maintenance Records

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              1) General (Cont’d)
F. Quality Parts and Materials
            Related Reading Material (cont’d)
             Advisory Circular AC43 - 16
                General Aviation Airworthiness
                 Alerts
             FAA Order 8110.42
                Parts Manufacturer Approval
                 Procedures

1/10/2011          Compliance Requires Objective Evidence   26
            1) General (Cont’d)
F. Quality Parts and Materials
     Related Reading Material (cont’d)
       FAA Order 8130.21C (or as revised)
          procedures for completion and use of
            FAA form 8130 - 3, airworthiness
            approval tag
G. CACS - 30
 Checklist Associated with 3A Standard


1/10/2011      Compliance Requires Objective Evidence   27
            2) Quality System and Quality
                        Manual
A. Distributor SHALL have established
   Quality System
     Assure Quality Product
            that conforms to customer
             specifications
     Described in Detail (including procedures and
      operations)
            in Quality Manual or other appropriate
             document
1/10/2011           Compliance Requires Objective Evidence   28
            2) Quality System and Quality
                    Manual Cont’d
A. Established Quality System (cont’d)
 Minimum Elements Described in Manual
     1) Quality Organization
     2) Inspection Procedures
     3) Shipping Procedures
     4) Technical Data Control
     5) Record Keeping

1/10/2011         Compliance Requires Objective Evidence   29
            2) Quality System and Quality
                   Manual Cont’d
A. Established Quality System (cont’d)
 Minimum Elements Described in Manual
     6) Training Requirements
     7) Shelf - Life Control
     8) Measuring and Test Equipment
         Calibration (as applicable)
     9) Procurement


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            2) Quality System and Quality
                   Manual Cont’d
A. Established Quality System (cont’d)
     Minimum Elements Described in Manual
            10)   Material Control
            11)   Housing and Facilities
            12)   Internal Audit and Surveillance
            13)   Scrapped Parts Procedure
            14)   Certification Forms

1/10/2011           Compliance Requires Objective Evidence   31
            2) Quality System and Quality
                   Manual Cont’d
B. Quality Elements N/A to a Specific
   Organization
     Shall Be Included In The Distributor’s Quality
      Manual
            as “not applicable”
              insures the quality element was not
               overlooked



1/10/2011           Compliance Requires Objective Evidence   32
             3) Quality Organization
A. Organization Chart
     Shall be depicted
            showing relationship of quality
             department to the rest of the
             organization
              validate, if possible the Quality
                Department has real authority -- not
                just satisfying the requirement


1/10/2011           Compliance Requires Objective Evidence   33
    3) Quality Organization Cont’d
B. Personnel (by title)
            responsible for quality systems, including
            inspection
            tool and test equipment calibration
            technical data control
            shelf - life control
            scrap

1/10/2011            Compliance Requires Objective Evidence   34
    3) Quality Organization Cont’d
C. Quality Manual (or Document)
     Shall Be Kept Current
            identifying standards to which it was
             written
     Shall Be Available
            to employees
            to customers’ auditor (or designee)


1/10/2011           Compliance Requires Objective Evidence   35
    3) Quality Organization Cont’d
D. Distributors Roster of Personnel
     Shall Be Current
     Individuals Authorized to Perform Specific
      Inspection Functions
     Inspections Each is Authorized to Perform
            Training records must support this




1/10/2011           Compliance Requires Objective Evidence   36
    3) Quality Organization Cont’d
E. Distributors of New Aircraft Parts
     Shall Maintain Current List of Manufacturers


            that have officially authorized the
             company as a distributor




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                Questions
A. Is there an established Quality-Control
     Program?

B. Does the quality manual describe the
  Quality Department and its relationship to
  the rest of the organization?



1/10/2011     Compliance Requires Objective Evidence   38
                        Questions

C. Does a manual identify specific persons,
   by title, responsible for various quality
   functions and programs?
            1) Quality Program
            2) Inspection
            3) Tool and Test Equipment Calibration
            4)Technical Data Control
            5)Shelf Life Program
            6)Scrapped Parts

1/10/2011             Compliance Requires Objective Evidence   39
                         Questions
D. Is the Quality Manual current and
 available to all employees?

E. Is there a roster of:
            (1) Persons that are authorized to perform
             inspections ?
            (2) A list of inspections they are authorized to
             perform?

1/10/2011              Compliance Requires Objective Evidence   40
                Questions
F. Does the distributor maintain a current list
  of manufacturers who officially authorize
  them as a distributor?




1/10/2011     Compliance Requires Objective Evidence   41
             4) Inspection Procedures
              (Responsibility by Title)
A. Inspectors
     Verify Incoming Parts and Materials
            free from defects
            good state of preservation




1/10/2011           Compliance Requires Objective Evidence   42
                 4) Inspection Procedures
                        (Cont’d)
B. New Parts Distributor
    Maintain Inspection Program, including

            periodic verification that standard parts
             meet technical specifications applicable to
             P/N

            insure adequate specifications are available


1/10/2011            Compliance Requires Objective Evidence   43
              4) Inspection Procedures
                      (Cont’d)
B. New Parts Distributor (Cont’d)
            to support inspection process
            specifications are current
            maintain records of inspections and tests
             used to make verification
            physical / chemical tests
            check manufacturers’ test reports


1/10/2011            Compliance Requires Objective Evidence   44
            4) Inspection Procedures
                    (Cont’d)
C. Shall Have Receiving Inspection
         Program
     verify materials received
       appropriate quality
       lot / batch number
          as indicated on accompanying
            certifications and test reports



1/10/2011        Compliance Requires Objective Evidence   45
              4) Inspection Procedures
                      (Cont’d)
D. Receiving Inspection for Aircraft
   Fasteners and Raw Stock
     Visual Check
            general workmanship
            presence of certifications
            presence of test reports



1/10/2011           Compliance Requires Objective Evidence   46
            4) Inspection Procedures
                    (Cont’d)
E. Inspection Stamps
 Control System For Usage and Replacement
    procedure must include...
         1) facsimile of each stamp type
         2) identify who stamps are issued to
         3) policy for stamps that are lost or
             stolen
         4) requirement that no stamp be
              reissued within a six month period
              to two different employees
1/10/2011       Compliance Requires Objective Evidence   47
              Questions
A. Are all parts inspected for physical
   damage and preservation?
B. Are standard parts verified as meeting
   technical specifications?
C. Are there acceptable sampling procedures
   used?



1/10/2011    Compliance Requires Objective Evidence   48
                        Questions
            D. Are fasteners and raw stock inspected
             for condition, presence of certifications,
             and test reports?

            E. If inspection stamps are used, does the
             policy require a stamp to be retired for
             at least two years after an inspector
             leaves?


1/10/2011            Compliance Requires Objective Evidence   49
             5) Shipping Procedures
A.         Shipping Requirements
     ATA - 300 Specification Container
     Equivalent
     One Specified By Customer
            packed in manner to preclude damage
             by rough handling



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             5) Shipping Procedures
                     (Cont’d)
B. Procedure in Place and Trained
            Personnel
     Visual Inspection of Items Shipped
     1) obvious physical damage
     2) ALL appropriate caps and plugs installed
     WARNING...tape shall not be used to cover
      electrical connections or fluid fittings /
      openings. Adhesive residue can insulate
      electrical connections and contaminate
      hydraulic or fuel units
      ESDS caps
1/10/2011          Compliance Requires Objective Evidence   51
            5) Shipping Procedures
                    (Cont’d)
    Visual Inspection of Items Shipped (cont’d)
      3) verifying part matches documentation and
        the customer’s request / purchase order
     quantity
     part number
     including dash numbers and letters
     model number
     serial number
     etc.
     batch number
     lot number
1/10/2011        Compliance Requires Objective Evidence   52
            5) Shipping Procedures
                    (Cont’d)
     Visual Inspection of Items Shipped
      (cont'd)
     4) verifying packing slip information
     contains all information required by the
      customer
     5) shipping container and packing
       appropriate for item being shipped
       ATA 300 or equivalent...
       ...or as specified by customer
1/10/2011        Compliance Requires Objective Evidence   53
            5) Shipping Procedures
                    (Cont’d)
     Visual Inspection of Items Shipped (cont’d)
     6) verify required documentation
     maintenance release (airworthiness approval)
     “yellow tag”
     FAA Form 8130-3
     material certification
     traceability (chain of custody)
     etc. (export)
     are at hand, properly completed
     are signed
1/10/2011        Compliance Requires Objective Evidence   54
            5) Shipping Procedures
                    (Cont’d)
     Visual Inspection of Items Shipped
      (cont'd)
     7) verify materials classified as
         HAZMAT
     inspected by trained and qualified
      personnel



1/10/2011       Compliance Requires Objective Evidence   55
                Questions
A. Are all parts shipped in ATA 300
   containers or equivalent?
B. Do appropriately trained personnel
   conduct an inspection of items being
   shipped, including but not limited to:




1/10/2011     Compliance Requires Objective Evidence   56
                 Questions
1) Obvious physical damage?
2) Installation of plugs and caps?
3) Verification of quantity, part number, serial
   number, model number, etc.?
4) Packing slip information as required by
   customer?
5) Verification of airworthiness approval, material
   certification, traceability documents, etc.?
6) HAZMAT materials properly inspected?


1/10/2011      Compliance Requires Objective Evidence   57
             6) Technical Data Control
              (Responsibility by Title)
A. Technical Data Shall be
    Maintained
            Applicable To Products On Hand
            Current And Accessible
            Stored In Manner To Protect It From Dirt
             and Damage
            No Hand Entries
            No Hand Corrections

1/10/2011            Compliance Requires Objective Evidence   58
    6) Technical Data Control (Cont’d)
B. Airworthiness Directives
     Verify Status On Date Of Sale
C. Microfilm, Microfiche, CD
     Must Have Appropriate Viewing Device
            maintained in good working order
            protected from damage
            available to personnel


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                  Questions
    A. Is there a documented system for
    obtaining technical data and maintaining it
    up to date?

     NOTE: Technical data includes any documents
      used to determine that the part complies with
      OEM requirements. Examples are, but are not
      limited to drawings, manuals, parts catalogs,
      and cross reference manuals.

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                Questions
B. Is the appropriate, current technical data
  readily available to personnel that need it?

C. Is AD status verification provided on date
  of sale?

D. Is there a system to prohibit hand entries or
 corrections to technical data?
1/10/2011     Compliance Requires Objective Evidence   61
               Questions
E. Is technical data stored in a manner that
  will protect it from dirt and damage?




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            7) Record Keeping
A. New Parts Distributor
     System In Place Governing
       storage
       distribution
       retrieval
          of documents verifying
               fasteners & raw stock phys / chem
               properties conform to technical
               specifications
1/10/2011        Compliance Requires Objective Evidence   63
            7) Record Keeping (Cont’d)
B. Records Confirming Aircraft Fastener
            Integrity
     Including Physical / Chemical Test Reports
  retained for minimum of two years after date of
    sale
C. Records Verifying Conformance to
     Flammability Requirements
     Retained For Minimum Of Seven Years After Date Of
      Sale


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            7) Record Keeping (Cont’d)
D. Traceability and Certification
   Documents
     Maintained From Date Of Sale
            two years




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            7) Record Keeping (Cont’d)
E. Distributor must have documented
    traceability system-chain of custody
     To Trace Parts To
            source of production
            FAA certificate holder
            to end user (customer)



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            7) Record Keeping (Cont’d)
Traceability System (cont’d)
     Samples Of Traceability Documentation
       Statement of Conformance
       Material Certification
       Return to Service Tags
         Must be accompanied by the records of
          last maintenance action-tear down report




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            7) Record Keeping (Cont’d)
E. Traceability System (cont’d)
 Approval Status Of Each Part I/A/W
     FAR 21.303 (replacement & modification
      parts)
       (a) Except as provided in paragraph (b)
         of this section, no person may produce a
         modification or replacement part for sale
         for installation on a type certificated
         product unless it is produced pursuant to
         a Parts Manufacturing Approval issued
         under this subpart.
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            7) Record Keeping (Cont’d)
E. Traceability System (cont’d)
 Approval Status (cont’d)
     FAR 21.303 (cont'd)
       marking PMA parts I/A/W FAR 45.15
          1) the letters “FAA - PMA”
          2) name, trademark, symbol of PMA
           holder
          3) part number
          4) eligibility listing (name and model
           of each type certificated product)

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            7) Record Keeping (Cont’d)
E. Traceability System (cont’d)
 Approval Status (cont’d)
            FAR 21.303 (cont'd)
              exceptions to PMA
              1) parts produced under PC or TC
              2) owner / operator produced parts (for
               maintaining or altering own product)
                 Note: not acceptable for distribution (SALE)
              3) parts produced under TSO
              4) standard parts conforming to established
               U.S. or industrial standards (nuts & bolts)

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            7) Record Keeping (Cont’d)
F. Life - Limited Parts
     Records Confirming Life - Limited Status
       records from previous operators as
        applicable
G. Storage of Records
            Protected Against
              damage
              alteration
              deterioration
              loss
1/10/2011           Compliance Requires Objective Evidence   71
            7) Record Keeping (Cont’d)

H. Serviceable Parts
     Supplier Must Provide Airworthiness Approval
      Document
       from FAA certificated source
         FAR 121 (air carriers & commercial
           operators)
         FAR 145 (repair stations)
             * not applicable to new parts unless
               work or test was performed


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            7) Record Keeping (Cont’d)

H. Serviceable               Parts (cont’d)
     Document Must Contain
            certificate number
            maintenance release for RTS
              FAA Order 8130.21C (or as revised)
              FAR 43 Appendix B
              AC 145.3 Appendix 1
                  examples of airworthiness release
                    statements for air carrier work
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            7) Record Keeping (Cont’d)
H. Serviceable Parts (cont’d)
     Document Must Contain                      (cont’d)
            must be signed
             inspection stamps, symbols, printed
              names, and stamped names
               NOT ACCEPTABLE



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            7) Record Keeping (Cont’d)
H.         Serviceable Parts (cont’d)
     Document (Airworthiness Approval /
      Maintenance Release) Shall Be Physically
      Attached To Unit
          any format (usually tag or 8130-3)
             as long as required information is
              present, including part number &
              serial number


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            7) Record Keeping (Cont’d)
I. Distributor Shall Provide...
  Copy Of Teardown Report
    must contain
        condition at overhaul
       list of significant parts replaced
       tech data used (service bulletins, ADs)
       functional test




1/10/2011         Compliance Requires Objective Evidence   76
            7) Record Keeping (Cont’d)
J. Incident Related Parts
     Must Be Identified

            from aircraft or engine subjected to extreme
             stress or heat

            major engine failure/sudden stoppage




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            7) Record Keeping (Cont’d)
     J.     Incident Related Parts (Cont’d)
                 accident
                 fire
                 submersion in saltwater
            or parts themselves subjected to
             extreme stress or heat, i.e. warehouse
             fire….



1/10/2011           Compliance Requires Objective Evidence   78
                Questions
A. Does distributor request adequate test and
   inspection records with each order of
   parts?
B. Are records confirming fastener integrity
   maintained for 2 years? (i.e.; chemical and
   physical properties.)

C. Are certifications and test reports being
   received and filed as required?

1/10/2011     Compliance Requires Objective Evidence   79
                 Questions
D. Can each part or carton or package of
 parts be linked to its certification and/or test
 records by some unique identifier?

E. Does the vendor's purchase records/sales
  orders chain of custody lead to a production
  approval holder (PMA, TSO, PC, TC, STC
  Holder) or manufacturer of standard parts ?



1/10/2011      Compliance Requires Objective Evidence   80
                Questions
F. Is serial number traceability maintained
  when applicable?

G. Are export Certificates of Airworthiness
 obtained for all foreign manufactured parts?
 (Ref. FAR 21.502)

H. Are records protected against damage,
 alteration, deterioration and loss?

1/10/2011     Compliance Requires Objective Evidence   81
                    8) Training
A. Properly Trained and Competent
            Personnel
     Functions
       inspection
       parts handling
       record keeping
       documentation
       traceability requirements

1/10/2011          Compliance Requires Objective Evidence   82
              8) Training (Cont’d)
A. Properly Trained and Competent
        Personnel (cont’d)
     Personnel Requiring Training
            supervisors
            inspectors
            receiving personnel
            shipping personnel
            sales people

1/10/2011          Compliance Requires Objective Evidence   83
            8) Training (Cont’d)
B. Inspection Personnel
     Properly Trained and Authorized
       in inspection techniques
       in methods and equipment used to
        determine part quality
       this authorization criteria shall be identified
        in quality manual



1/10/2011         Compliance Requires Objective Evidence   84
              8) Training (Cont’d)
C. Shipping Personnel
      Trained and Competent In HAZMAT
            recognition
            packaging
            identification
            proper handling



1/10/2011          Compliance Requires Objective Evidence   85
              8) Training (Cont’d)
D. Personnel Training
     Shall Be Documented
             formal training (classroom)
            on - the - job (OJT)
     Must Be Retained
            minimum of two years
              after employee leaves company


1/10/2011           Compliance Requires Objective Evidence   86
               8) Training (Cont’d)
E. Training Records
     Shall Include
            description of the training
            date and number of hours of instruction
            name of instructor and student and / or
             signature of instructor and student
            name of organization conducting the
             training (if outside agency)


1/10/2011            Compliance Requires Objective Evidence   87
               Questions
A. Are personal who perform inspection,
 shipping and receiving functions properly
 trained?

B. Are inspection personnel properly
  authorized?




1/10/2011    Compliance Requires Objective Evidence   88
                Questions
C. Are both formal classroom and on-the-job
  training documented and maintained?

D. Is a roster of personnel authorized to
 perform specific functions maintained?




1/10/2011     Compliance Requires Objective Evidence   89
               9) Shelf Life Control
             (Responsibility By Title)
A. Distributor Shall Document and
   Maintain Program
     Program Must Assure
            identification of shelf-life items
            proper handling of shelf-life items
            no expired parts / materials will be
             issued


1/10/2011           Compliance Requires Objective Evidence   90
            9) Shelf Life Control Cont’d
B. Program Shall Include



     Component Assemblies Containing Shelf-Life
      Limited Items




1/10/2011         Compliance Requires Objective Evidence   91
                Questions
A. Is there a documented shelf life
   program?

B. Is there a list of shelf life limited
          materials / parts and their limits?




1/10/2011     Compliance Requires Objective Evidence   92
  10) Measuring and Test Equipment
       (Responsibility by Title)
A. Equipment Used to Verify
 Conformance
     Shall Be Periodically Calibrated
       N.I.S.T. (National Institute of Standards
        and Technology)
       other appropriate government standards
       check bi-lateral agreements
       must be traceable to standard used in
        calibration

1/10/2011        Compliance Requires Objective Evidence   93
  10) Measuring and Test Equipment
              (Cont’d)
B. Past Due Tools /Equipment
     Shall Have Procedure In Place To Prevent Use


C. Shall Maintain Documentation
     Current Calibration Status




1/10/2011        Compliance Requires Objective Evidence   94
               Questions
A. Does the supplier have the tools
   required to assure conformity of the
   inventory to specification?

B. Is there a documented program to
   maintain serviceability and calibration
   of those tools?


1/10/2011    Compliance Requires Objective Evidence   95
               Questions
C. Are historical records containing repair
   and calibration accuracy data for that
   tooling maintained?

D. If personally owned measuring tools are
   allowed on the premises are they
   controlled by the program?


1/10/2011    Compliance Requires Objective Evidence   96
                Questions
E. If in-house Calibration is performed are
    the standards used traceable to N.I.S.T.?

F. Is there current certification for each in-
    house standard use?

G. Are the precision tools stored in a
   manner that will prevent damage and/or
   adverse affects on the calibration of the
   tool?


1/10/2011     Compliance Requires Objective Evidence   97
                11) Procurement
A. Maintain System Such That...
     Only Approved Quality Materials Purchased
     Proprietary & Licensing Rights Observed
B. System Shall Assure...
     Special Requirements Are Adequately
      Communicated To Sources
            test reports
            physical / chemical analysis

1/10/2011           Compliance Requires Objective Evidence   98
        11) Procurement (Cont’d)

C. Distributors of New Aircraft Parts
     Purchase Materials Directly From Approved
      Manufacturers...or
     Purchase Materials From Distributors
      Authorized By Manufacturer To Sell Product
       deviations from this
          must be disclosed to customer
          must be approved by customer prior to
           shipment


1/10/2011       Compliance Requires Objective Evidence   99
        11) Procurement (Cont’d)

D. Distributors Shall ...

     Maintain List Of Approved Suppliers

     Maintain Quality History For Each Source




1/10/2011       Compliance Requires Objective Evidence   100
                   Questions

A. Does the system demonstrate the ability
   to:
     (1) Trace parts to the source of procurement
      and to the source production or to an FAA
      certificate holder and to end user.

      (2) Provide, upon request, information
      pertaining to the production approval status of
      each part in accordance with the applicable
      FAR'S?
1/10/2011        Compliance Requires Objective Evidence   101
                       Questions
B. Does the system assure that special
   requirements are adequately
   communicated to the supplier's sources?

C. Does the surplus suppliers system
 assure that:
            (1) parts subjected to extreme heat or stress
             are identified as such?


1/10/2011            Compliance Requires Objective Evidence   102
                    Questions
     (2) all parts procured have traceability and/or
       airworthiness certification as required by the
       FAR'S?
      (3) all Airworthiness Directives (A.D.s) which
       have been accomplished are documented
       appropriately?
     (4) part numbers conform to the customers
       purchase request?



1/10/2011         Compliance Requires Objective Evidence   103
                    Questions
     (5) items identified as "overhauled" were in
      fact overhauled and have appropriate
      documentation to substantiate the condition of
      the part?




1/10/2011        Compliance Requires Objective Evidence   104
            12) Material Control
A. Handling of Material

     Appropriate Manner
     Protected From Damage & Deterioration




1/10/2011       Compliance Requires Objective Evidence   105
   12) Material Control (Cont’d)
B. Packaging and Storage
     Special Packaging Maintained As Necessary
       electrostatic discharge sensitive (ESDS)
       temperature / humidity control
       magnetic control (radome)
     Storage Area Periodically Checked
       for overall effectiveness
          storage
          identification methods

1/10/2011         Compliance Requires Objective Evidence   106
   12) Material Control (Cont’d)
C. Close Loop Corrective Action System
     Implemented When Detecting...
            substandard / non-conforming parts
              these rejected parts
                Identified, segregated, and secured
                  from useable stock




1/10/2011           Compliance Requires Objective Evidence   107
   12) Material Control (Cont’d)
C. Close Loop Corrective Action System
 (cont’d)
     System Shall Include
            notification of each purchaser within
             24 hours of detection
            method to recall or rectify problem
            unapproved parts reported I/A/W AC
             21-29


1/10/2011           Compliance Requires Objective Evidence   108
   12) Material Control (Cont’d)
D. Segregation of........
     Aircraft Parts
     Non-Aircraft Parts




1/10/2011       Compliance Requires Objective Evidence   109
   12) Material Control (Cont’d)
E. Distributors of Aircraft Fasteners
        Shall
     Maintain Batch / Lot Segregation
     Maintain Batch / Lot Records
      quantities sold from Each Batch/Lot
      quantities sold to Each Customer
      Note: Purchases less sales should equal
                inventory
         this must balance on batch / lot
           numbered inventories
1/10/2011       Compliance Requires Objective Evidence   110
   12) Material Control (Cont’d)
F. Distributors of Materials Requiring
    Flammability Testing
            Maintain Batch / Lot Segregation
            Maintain Batch / Lot Records (flame certs)
             and for other items for which this is
              appropriate




1/10/2011            Compliance Requires Objective Evidence   111
   12) Material Control (Cont’d)
G. Sorting and Delivery
     In O.E.M. Packaging (when practical)
     Packaging Shall Identify
       manufacturer
       distributor
       part number
       batch / lot (if applicable)
       quantity


1/10/2011       Compliance Requires Objective Evidence   112
   12) Material Control (Cont’d)
H. Flammable, Toxic, or Volatile
 Materials
     Stored In Safe Manner
       manufacturers’ recommendations
       specified by local fire regulations
          distributor shall identify and maintain
           copy of applicable fire code



1/10/2011        Compliance Requires Objective Evidence   113
   12) Material Control (Cont’d)
I. Electro - Static Discharge Sensitive
    Materials (ESDS)
     Use Necessary Precaution In Accordance With
      Governing Requirements
            packaging
            handling
            protection


1/10/2011          Compliance Requires Objective Evidence   114
            12) Material Control (Cont’d)
J. Part Number Ambiquity
     Assure None Exists
       parts shall not be labeled with multiple part
        numbers
         if labeling may cause confusion
             to part manufacturer
             applicable specification
       Note: mod level of unit may indicate A/C
        applicability



1/10/2011          Compliance Requires Objective Evidence   115
   12) Material Control (Cont’d)
K. Alteration or Replacement
     Data Plate
     Manufacturers’ Part Number

            unacceptable




1/10/2011          Compliance Requires Objective Evidence   116
   12) Material Control (Cont’d)
L. System To Segregate & Identify

     Serviceable from Unserviceable Units
      in a manner that will preclude issuing
        an unserviceable part




1/10/2011      Compliance Requires Objective Evidence   117
                Questions
A. Is material handled in such a fashion as
   to preclude damage and deterioration?

B. Are storage areas periodically checked
   for overall effectiveness?

C. Is batch segregation utilized for aircraft
   fasteners and other material requiring
   batch control?


1/10/2011     Compliance Requires Objective Evidence   118
               Questions
D. Is the original packaging used as
         practical?

E. Does packaging clearly identify
    contents?

F. Does packaging conform to ATA
    specification 300 when appropriate?


1/10/2011    Compliance Requires Objective Evidence   119
                Questions
G. Is material susceptible to electrostatic
   discharge damage handled in accordance
   with proper requirements?

H. Are parts/components adequately
   protected against the environment and
   damage (including caps and plugs)?

I. Is a system in place to preclude part
    number ambiguity?
1/10/2011     Compliance Requires Objective Evidence   120
               Questions
J. Does the quality program provide a
    closed-loop system for implementing
    corrective action following the
    identification of non-conforming parts
    or material?

K. Is the non-conforming part/material
   segregated from usable stock?



1/10/2011    Compliance Requires Objective Evidence   121
               Questions
L. Is there a documented procedure in
 place     for mutilating scrapped parts
 which will     preclude their being returned
 to service?
M. Are records maintained on all
 serialized     scrapped parts?




1/10/2011    Compliance Requires Objective Evidence   122
               Questions
N. Is this requirement imposed on the
   subcontractors and/or suppliers?

0. Is there a balance procedure for
    quantities purchased less sales equals
    inventory?




1/10/2011    Compliance Requires Objective Evidence   123
             13) Housing And Facilities
A. Appropiate and Maintained
      Insure Storage Does Not Damage Inventory

B. Distributor Engaging in A/C or A/C
   Component Maintenance
     Storage Area Must Be Secured
            prevent cannibalizing by maintenance
             personnel


1/10/2011          Compliance Requires Objective Evidence   124
               Questions
A. Is ventilation, lighting, temperature, and
   humidity control adequate?

B. Are good housekeeping practices being
   maintained?




1/10/2011    Compliance Requires Objective Evidence   125
            14) Internal Audit And
                  Surveillance
A. Distributors Audit and Surveillance
            Function
     Periodically Self-audits Programs
       verify procedures are in place to assure
        compliance
          with CASE 3A Standard
          customer specifications
          regulatory requirements
          good industry practices
1/10/2011          Compliance Requires Objective Evidence   126
            14) Internal Audit And
                  Surveillance
A. Distributors Audit and Surveillance
   Function (cont’d)

     Verify Operations Are Being Conducted In
      Accordance With These Programs




1/10/2011       Compliance Requires Objective Evidence   127
             14) Internal Audit And
                   Surveillance
B. Self Audits
 Performed In Accordance With
  Checklists Or Other Written Procedures
            to determine the effectiveness of Quality
             Program
     Results Shall Be Documented
            for Non-Compliance and Corrective Action




1/10/2011            Compliance Requires Objective Evidence   128
             14) Internal Audit And
                   Surveillance
F. Self Audits (cont’d)
     Corrective Action Shall:
            be appropriate and prompt
            correct reported discrepancies
            locate and correct similar discrepancies
               in areas not audited
            correct the ROOT cause
            implement follow-up
             to eliminate recurrence


1/10/2011            Compliance Requires Objective Evidence   129
               Questions
A. Is there a self audit program in place?

B. Are self audits documented including
   non-compliance corrective actions?




1/10/2011    Compliance Requires Objective Evidence   130
    15) Scrapped Parts Procedure
        (Responsibility by Title)
A. Documented Procedures
 Mutilation
    drilling
    grinding
    cutting
    other appropriate means
 Extent Of Mutilation
    preclude restoration and return to service

1/10/2011      Compliance Requires Objective Evidence   131
    15) Scrapped Parts Procedure
              (Cont’d)
B. Life - Limited Scrap Parts
     Maintain Record
            description of part
            part number
            serial number (if applicable)
            date part was scrapped
            retain record for at least two years

1/10/2011           Compliance Requires Objective Evidence   132
    15) Scrapped Parts Procedure
              (Cont’d)
C. Verification of Mutilation
     Individual Responsible
   must be identified in procedure by
    position or title
D. Subcontractors/Repair Facilities of
   Distributors
     Imposed With Same Scrap Requirements


1/10/2011       Compliance Requires Objective Evidence   133
               Questions
A. Does the supplier have a documented
   procedure for the handling of scrapped
   parts?

B. Does the supplier identify by title or
   position the individual responsible for
   verifying compliance with the
   procedure?

1/10/2011    Compliance Requires Objective Evidence   134
               Questions
C. Does the supplier impose the procedure
   on subcontractors and repair facilities
   with whom they do business?




1/10/2011   Compliance Requires Objective Evidence   135
            16) Certification Forms
A. Quality Manual Requirement
     Forms Used By Distributor
   to certify parts
   show traceability of parts
      Shall contain samples
      Shall contain instructions
B. Instructions
     May Be Contained On The Forms
1/10/2011       Compliance Requires Objective Evidence   136
              Review Of AC 00-56
History
     Much Discussion On Having FAA Regulate
      Surplus Dealers
            aviation industry put a lot of pressure
             on FAA
     FAA Indicated That They Didn’t Have The
      Manpower and Resources To Regulate
     Established Guidance...AC 00-56


1/10/2011           Compliance Requires Objective Evidence   137
  Review Of AC 00-56 (Cont’d)
History (cont’d)
     AC 00-56 Lists Requirements
     Distributor Found Lacking After Accreditation
       many findings
       accredited against ISO Std. & placed in
        Airline Suppliers Association (ASA)
        Register
       manual did not address guidance offered in
        AC


1/10/2011        Compliance Requires Objective Evidence   138
   Review Of AC 00-56(Cont’d)
History (cont’d)
 Brought To The Attention Of The FAA
  At CASE Conference

     CASE Updating 3A Standard
      will be adopted by ASA as their own



1/10/2011     Compliance Requires Objective Evidence   139
  Review Of AC 00-56 (Cont’d)
Literature Referenced in AC
     AC 20-62 aeronautical replacement parts
     AC 21-20 supplier surveillance
     AC 21-29 suspected unapproved parts
     AC 21-38 disposition of unsalvageable parts
      and materials
     Ac 21.303-2 announcement and availability:
      PMA


1/10/2011        Compliance Requires Objective Evidence   140
  Review Of AC 00-56 (Cont’d)
Literature (cont’d)
     AC 43-9 Maintenance Records
     Order 8110.42 PMA Approval Procedures
     Order 8130.21C Completing 8130-3 Tag
     AC 20-36 Index; Articles Under TSO
     AC 21-2 Export Airworthiness Approvals
     AC 43-16 General Aviation Airworthiness
      Alerts


1/10/2011       Compliance Requires Objective Evidence   141
  Review Of AC 00-56 (Cont’d)
AC 00-56 States:
     “The purchasing organization who uses
      accredited distributors and receives
      noncompliant parts, and who voluntarily
      reports such occurrences to the FAA, will have
      such information considered as mitigating
      circumstance per current FAA enforcement
      policy. ...will allow the FAA to concentrate its
      surveillance resources on parts purchased from
      sources that may not be as reliable.”


1/10/2011        Compliance Requires Objective Evidence   142
  Review Of AC 00-56 (Cont’d)
Quality Systems Minimums
     Receiving Inspection
            approved parts
               PAH, TC, TSO, PMA
            ...from approved sources
               121, 145, etc.
            NOTE: Parts are not legal unless they are
             manufactured under FAA approval.

1/10/2011            Compliance Requires Objective Evidence   143
  Review Of AC 00-56 (Cont’d)
Quality Systems Minimums (cont’d)
     Trained Personnel
            in quality system
            regulations
            able to recognize approved parts
     Measuring Equipment Calibration
     Control Of Incoming Discrepant Material
     Self Audit Program


1/10/2011           Compliance Requires Objective Evidence   144
  Review Of AC 00-56 (Cont’d)
Quality Systems Minimums (cont’d)
     PAH’s IPC
     Inspection Stamp Control
     Packaging Control
     Recall System
            within 24 hours
            trace both ways
              source
              end user
            provide method to correct problem

1/10/2011           Compliance Requires Objective Evidence   145
  Review Of AC 00-56 (Cont’d)
Quality Systems Minimums (cont’d)
     Quality Organization That Knows Regulations And
      Requirements
     Environmental Control
     Procedure For Redistribution Of Lots
            must keep original certification on file
            procedure for accountability
     System To Prevent Fraud
     Parts Traceability


1/10/2011            Compliance Requires Objective Evidence   146
  Review Of AC 00-56 (Cont’d)
Quality Systems Minimums (cont’d)
            Notify Accreditation Organization
              any changes in quality system must
               be accepted before implementation
     Provide Certifications
     Customers Who Receive Discrepant Parts
            must notify distributor
            must notify local FAA (FSDO, CMO)


1/10/2011            Compliance Requires Objective Evidence   147
  Review Of AC 00-56 (Cont’d)
Reaccreditation Every Two Years
     Name Of Accreditation Organization
     Date Of Accreditation
     Date When Annual Check Is Due
            to monitor the effectiveness of programs
     Verify Required Documentation
            “The following signature attests that the
             documentation specified above and attached
             is accurate with regard to the item(s)
             described.”
1/10/2011            Compliance Requires Objective Evidence   148
  Review Of AC 00-56 (Cont’d)
Final Thought
     The FAA has recently sent a letter to CASE
      stating that they will make the same allowance
      (mitigating circumstances) if an airline has to
      make a self-disclosure relative to a distributor
      they use by virtue of being listed in the CASE
      register.




1/10/2011         Compliance Requires Objective Evidence   149
            It’s Show Time!
FAA Produced Video

     Unapproved Parts...What You Can Do
      To Prevent Their Use




1/10/2011     Compliance Requires Objective Evidence   150
            Let’s Review The Video
Know Your Suppliers
     Buyers 1st Line Of Defense
Unapproved Parts
     PC - Supplier - Airline Relationship
Exceptions to PMA
PMA Marking



1/10/2011        Compliance Requires Objective Evidence   151
            Case Standard 3A Course
                    Review
      General
      Quality System and Quality Manual
      Quality Organization
      Inspection Procedures
      Shipping Procedures
      Technical Data Control
      Record Keeping
      Training

1/10/2011        Compliance Requires Objective Evidence   152
            Case Standard 3A Course
                    Review
      Shelf Life Control
      Measuring and Test Equipment
      Procurement
      Material Control
      Housing and Facilities
      Internal Audit and Surveillance
      Scrapped Parts Procedure
      Certification Forms

1/10/2011         Compliance Requires Objective Evidence   153
              Test Time!
Let’s See What You’ve Learned
 Minimum Passing Grade...70%
After The Test (If you are interested)
 Bonus Video
      Electro-Static Discharge
      (ESDS)
        Run Time...18:44


1/10/2011   Compliance Requires Objective Evidence   154

								
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