I need a little clarification, please.

Is the rating on the certificate similar to the scope on our ISO certificate? For ISO our scope is "New and reconditioning of ballscrews, acme lead screws, spindles and related machine components."

For AS9100 our scope is going to be "OEM and aftermarket manufacture of ballscrews, ballnuts and assemblies."- or something to that effect - we are only making new screws, nuts and various components like flop over inserts and retaining tangs, etc. We don't supply assembled ballscrews to any of our current aerospace customers.

We are only going to be repairing ballscrews under our Repair Station certificate. So I think our rating should just say "Ballscrew Repair". :confused:

I need a little clarification, please.

Is the rating on the certificate similar to the scope on our ISO certificate? For ISO our scope is "New and reconditioning of ballscrews, acme lead screws, spindles and related machine components."

For AS9100 our scope is going to be "OEM and aftermarket manufacture of ballscrews, ballnuts and assemblies."- or something to that effect - we are only making new screws, nuts and various components like flop over inserts and retaining tangs, etc. We don't supply assembled ballscrews to any of our current aerospace customers.

We are only going to be repairing ballscrews under our Repair Station certificate. So I think our rating should just say "Ballscrew Repair". :confused:


Cari,
What if????
I don't know your customer base, but what if your customer's ask you to do more than a ballscrew repair? I would have your certificate cover the same areas as your AS scope.

I have to come up with a repair station capability list. The list has to "(145.215b) "...identify each article by make and model or other nomenclature designated by the article's manufacturer..." and we can only list an article after we have (145.215c) "...performed a self-evaluation in accordance with ...145.209(d)(2)." and every time we add a new article we must (145.215d) "...provide [our] certificate holding district office with a copy of the revised list in accordance with...145.209(d)(1)."

145.209 referenced above is the clause describing the procedures that need to be in the manual - basically I need to write a procedure for (d)(1) revising the capability list and notifying the FAA Inspector and for (d)(2) self-evaluation for revising the capability list.

I'm figuring we'll add a description of this initial article specific self-evaluation to the scope of our existing internal audit program and then establish a frequency for incorporating article specific surveillance audits into our regular internal audit schedule. AC145-5 says that the auditor should have "...knowledge of the maintenance requirements for the particular make/model of article to be added to the list." I think our estimators are the best candidates - they are the ones who have all of the requirements and initially quote new articles. Part of the estimating process is determining feasibility (can we do it?) which is basically what this self evaluation is - a feasibility review - do we have all of the housing, equipment, know-how, etc. needed to repair this article.

If our estimators (the technically qualified auditors) create a checklist from the requirements when we first add an article to the list, then a regular auditor can be assigned for surveillance using the checklist created by the estimator.

What do you all think? What do you do at your repair station? Do you choose to audit your capability list on a regular basis? Do you incorporate the initial self-evaluation into your internal auditing program? Or do you keep it with your contract review records?

Good Morning, Carol. :bigwave:

We will have what's called a "limited rating" and our limited rating will be "specialized". The only work we'll be doing under FAA regulations is repairing and maintaining ballscrews - we may at some point consider accepting the mating gearboxes or assemblies that the ballscrew attaches to. We will not be manufacturing anything from scratch for these customers - if we report the item unrepairable, then they contact their aftermarket suppliers - which happen to be the type of customers we are satisfying with our AS9100 registration. Your question leads nicely into something else I'm a little confused about.

145.215(a) A certificated repair station with a limited rating may perform maintenance, preventive maintenance, or alterations on an article if the article is listed on a current capability list acceptable to the FAA or on the repair station's operations specifications.

I think OpSpecs are for places that do routine maintenance and repairs for an aircraft or a certain system of an aircraft - like routine instrument checks or regular checklist inspections of the whole landing gear system, etc. I think we will have a capability list instead of OpSpecs because we'll have a specialized limited rating - we don't repair the landing gear, we're the place that those people would send the ballscrew to.

For our limited rating for specialized services, I think our operation specifications will be our article specific repair procedures that are either provided to us by our customer, or that we've developed with input from our customer and approved by the FAA.

I think.

Cari:
With a limited rating, I believe, you must list each part no. on your capability list. The requirements are described in FAA Advisory Circular 145-9 (http://elsmar.com/Forums/attachment.php?attachmentid=1874) Section 4-3, Capability List.

Thanks Al - I am working with that document; I love that all of these documents are free! Actually I started another thread with specific questions about the capability list and the self evaluation required for adding articles to the list.

I think I'm more unsure about the OpSpecs - am I correct in my thinking above: that our operation specifications will be the repair procedures per article part number?

Thanks Al - I am working with that document; I love that all of these documents are free! Actually I started another thread with specific questions about the capability list and the self evaluation required for adding articles to the list.

I think I'm more unsure about the OpSpecs - am I correct in my thinking above: that our operation specifications will be the repair procedures per article part number?

The OPs Spec is a document the FAA issues as part of your Certificate. I will try to find an example. Their are repair stations that have their certs on the web.

From AC 145-9 Definitions:

o. Operations Specifications (OpSpecs). The official document that describes the authorizations, ratings, and limitations of the repair station.

Your capability list is the major part of your ops spec.

Cari, if you follow this link, (http://www.aircraftbraking.com/QA_Akron.php) you will find examples of the Quality System and FAA certificates for an organization that is a manufacturer with a 145 Repair Station.

Can anyone shed any light on this?

Good Morning, Marc -

Thanks for bringing this back up to the front. Most of the handful of covers who are Repair Station savvy aren't daily visiters - I figured it might be a little while for some responses.

Al - thank you so much. I was trying to make things more difficult than they are, as usual. :rolleyes: I see now - the OpSpecs is the document that "sums it up".

After following your link to the example - I started google searching for companies listed in the Repair Stations Directory advisory circular. Some of their websites have their certificates and OpSpecs and even their manuals - so I'm a little more enlightened.

Thanks for the nudge in the right direction. :agree:

You're right - It looks like there aren't many repair station folks who stop by.

Some of this I addressed in the other post that was started about capability list. This requirement about auditing the Capability list was "introduced"http://elsmar.com/Forums/images/smilies/rolleyes-a1.gif since my involvement in FAA Repair Stations ended, but I had to periodically update our capability list. If you are the manufacturer of the parts, you might want to add an item at the Final Design Review or Design Transfer. That item might also include verifying that all the approved data is available for maintenance. As far (pun intended) as it's concerned, KISS.

Some things to keep in mind for a Limited Rating:

If a part is not listed on your OP Spec, you cannot legally perform maintenance on it.
To add it to your OP Spec, you must first add it to your Capability List.
Submit your Capability List to the FAA.
The FAA will revise your Op Specs after verifying you have met all the requirements (approved data, tools & equipment etc.) for maintaining the new part. This could be a facility visit (inspection). This is what I dealt with each time I made a change. The inspector visited with the revised OP Spec, verified we met all the requirements and swapped the new OP Specs for the old ones. (This wasn't difficult for us being the manufacturer.)
The reason I mention this is that it could take some time between you submit the change and the FAA issues you new OP Specs. They are not, exactly, able to turn on a dime. http://elsmar.com/Forums/images/smilies/wink.gif See # 1 above. So plan ahead.

Cari, Here is the procedure for our Capability List included in our Repair Station Manual that has been accepted by our Administrator (FAA). I am also going to try to paste the Capability Verification Form.

"The capability list is a separate document from this manual and shall incorporate those items that comply with _________________, Limited Accessory Ratings. It is controlled by revision number and date. A current Capability List is maintained by the General Manager of this repair station.


The Capability List is available for review to all personnel of this repair station. During receiving/inspection, the receiving inspector shall refer to the capabilities list to verify that the article to be serviced is listed. The information is recorded on the Receiving Inspection Log. If the article is not on the list, the General Manager is notified immediately, the article is identified with a Rejected Parts Tag, (Form 6) and placed in the bond locker until further processing. Once the General Manager has verified and/or obtained that the Repair Station has all required tooling, documentation and experienced personnel to service the equipment, then that equipment shall be added to the capabilities list and work would be able to commence on that equipment. If the article cannot be added to the Capability List it is returned to the customer. A capabilities verification form (see Forms Section “C” GI-11) shall be completed to determine if a component can be added to the capabilities list.


The capabilities list shall be reviewed periodically in accordance with the internal audit programs schedule and not to extend a period of more than 90 days. If it is found at that time that the technical data and/or tooling is not current, and current technical data or tooling cannot be obtained, then that article's part number shall be removed from the capabilities list.

The General Manager shall be responsible for any revisions to the capabilities list and shall notify the appropriate personnel of the repair station and the FAA of such revisions. A revised capabilities list shall be sent to the FAA with a highlight sheet showing the revision number, revision date and what equipment was added or deleted from the previous list. The revised capabilities shall be sent to the FAA within 7 working days of the revision date by email, fax or hand delivered."


CAPABILITIES VERIFICATION FORM







Manufacturer: ______________ Part Number: _____________ Description: ______________






1. Does component fall within the scope of the repair stations' Operational specifications?




2. Does the repair station have the current technical data?




3. Does the repair station have the proper Equipment/tooling?



4. Does the repair station have the proper parts for OHC/repair?



5. Are the repair stations personnel trained for this component?





If items 1-5 above are all marked YES, then this component may be added to the capabilities list and the repair station may proceed with the overhaul and/or repair of this component.



Component was added to the capabilities list on: _______________________



If any one of the items 1-5 above is marked NO, then this component may not be added to the capabilities list and the repair station may not overhaul or repair the component.





APPROVED ______ NOT APPROVED _______



General Manager




This form shall be retained on file by the General Manager, for a period of not less than two years.

Thanks Paula - big help!!

You've also inadvertently given me some help with an issue we have been discussing: how to separate the FAA repairs from our regular repairs back in receiving. We receive so many items for repair - and the usual practice is for the tear down guys to take pictures as received, log the item in and give it an eval #, then the item is moved to tear down where they...tear it down. These are the guys that clean all the components up and write up the initial observations like visibly obvious galling, broken balls, stripped threads, etc. Then the estimator comes out to give it the thorough inspection to determine if we can fix it or if it has to be remade.

We don't want our tear down guys doing anything to the FAA repair evaluation items - we want those set aside for the estimators. So, if we do like you guys do and have the capability list back in receiving...maybe with an attachment for a list of customers sending us FAA repairs in case we are sent an item not yet on our capability list...

I see that the regulations were re-written to allow maintenance to be performed before the ops specs are revised, as long as the article is within the scope of your ratings and you determine you have all of the housing, facilities, equipment, material, technical data, processes, and trained personnel in place to perform the work on the article as required by part 145 (ref:21cfr145.215 (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=cd70c6a59d6bc1d3c9ef1ce9533e060a&rgn=div5&view=text&node=14:3.0.1.1.5&idno=14#14:3.0.1.1.5.5.1.8))
I appologize for the misinformation in my previous post.

Oh yeah, I forgot that I meant to post that, Al. I found that out from one of the potential customers our Mil/Aero Sales Rep is working with. The only thing it doesn't say is a specific timeframe for notification to the FAA.

Paula - is the 7 days in your procedure what your FAA Inspector asked for, or did you guys determine that and the FAA said "OK"?

Hi Cari,

Well in fact I just finished revising the RSM to state that we will notify the CHDO within 30 days of revisions made to give us a little break.

145.161(a) A certificated repair station must maintain and make available in a format acceptable to the FAA the following....
The Three Rosters are to be revised within 5 business days of the change in accordance with 145.161(b)

Our Administrator requires us to notify him in the manner we spell out in our Repair Station Manual.

So pretty much what ever works for the repair station!

Keep in mind, I am also the Chief Inspector for another Certificated Repair Station, pulling double duty these days. Not much time to post!:(

Wow - busy girl!!

Thanks so much! :agree:

Hi Cari,

Looks like you've received a lot of good input here.


For AS9100 our scope is going to be "OEM and aftermarket manufacture of ballscrews, ballnuts and assemblies."- or something to that effect - we are only making new screws, nuts and various components like flop over inserts and retaining tangs, etc. We don't supply assembled ballscrews to any of our current aerospace customers.

We are only going to be repairing ballscrews under our Repair Station certificate. So I think our rating should just say "Ballscrew Repair".

One question if I may ask it...Do you have SEPARATE facilities whereby you manufacture ballscrews exclusively in one facility, while repairing ballscrews in another?

Hi Muleskinner -

Yes, I have received a lot of help here! In addition to the responses to my questions here at the cove, I have made friends with an FAA Inspector who has been most gracious in answering my endless emails!! It just occurred to me that I should probably have been sharing my questions and his responses with my friends here at the cove - I'll do that from now on.

In answer to your question (yes, you may certainly ask :bigwave: )- no. We have one building/facility. In addition to repairing or remanufacturing ballscrews (MRO), we are also an OEM supplier of various machine details that one might call "linear movement actuators" - ballscrew assemblies being one type - we also provide various machining, grinding and thread grinding that we like to call our "backdoor work".

I have made friends with an FAA Inspector who has been most gracious in answering my endless emails!! It just occurred to me that I should probably have been sharing my questions and his responses with my friends here at the cove - I'll do that from now on.


Yes, it's important to have a good rapport with your PMI, and anything you can share regarding your experiences is much appreciated.

About the first post here, there is a world of difference when you opt to list only as "repair of ball screws" vs. "manufacturing and repair", you will eliminate the enitre design section in 7.3. If at a later date you want to add the function of "manufacturing" in, this can be accomplished through one of the annual surveillance audits.

For ISO our scope is "New and reconditioning of ballscrews, acme lead screws, spindles and related machine components."

For AS9100 our scope is going to be "OEM and aftermarket manufacture of ballscrews, ballnuts and assemblies."- or something to that effect - we are only making new screws, nuts and various components like flop over inserts and retaining tangs, etc.

We are only going to be repairing ballscrews under our Repair Station certificate. So I think our rating should just say "Ballscrew Repair". :confused:
Hi Blue Tuna - I'm not sure what you're saying in your post above. We manufacture new only for aerospace customers. We are getting our part 145 repair station certificate to cover repair and maintenance. We may at some point also apply for part 21 - but our customers are asking for AS9100.

I'm not sure what you're saying in your post above. We manufacture new only for aerospace customers. We are getting our part 145 repair station certificate to cover repair and maintenance. We may at some point also apply for part 21 - but our customers are asking for AS9100.
As a manufacturer of NEW PARTS for aerospace customers, are you currently doing so as a subcontractor?

No doubt it is difficult to follow my rambling. AS9100 is a manufacturing standard, the AS9110 is a maintenance standard (which no one has the capability to certificate yet). However, many maintenance organizations (FAA Part 145 Repair Stations) opt for the AS9100 with the design function of 7.3 removed. If you are not going to manufacture under the AS9100 then your work in writing to the standard is much easier. For example the entire design section is moot as is First Article etc.....

With that said, if you are manufacturing parts for aerospace it may be to your advantage and include the manufacturing element.

If you opt for maintenance only, then there will probably be a time in the near future when you can "upgrade" to the AS9110 (when certification becomes available). The only problem here is the additional elements for 9110 over 9100.

AS9100 is a manufacturing standard, the AS9110 is a maintenance standard (which no one has the capability to certificate yet).
With that said, if you are manufacturing parts for aerospace it may be to your advantage and include the manufacturing element.

If you opt for maintenance only, then there will probably be a time in the near future when you can "upgrade" to the AS9110 (when certification becomes available). The only problem here is the additional elements for 9110 over 9100.

WE MANUFACTURE NEW PRODUCTS FOR THE AEROSPACE INDUSTRY - SO WE ARE GOING TO BE AS9100 REGISTERED.

We also repair and manufacture new for at least a dozen different industries from machine tool to medical equipment to sporting goods.

We are also going to get Part 145 Repair Station certificated in order to repair and maintain ballscrews for commercial aircraft.

We are not opting for maintenance only; I'm not sure how you got that from what I'm saying.

As a manufacturer of NEW PARTS for aerospace customers, are you currently doing so as a subcontractor?
Yes. Our customer has the contract for a landing gear assembly or a brake actuating system, for example, that has 2 or 3 ballscrews in it. We are subcontracted for the ballscrews.

It's the same tier(s) as our non-aerospace OEM work. One of the B3 contracts our customer to build a dozen of this machining center. Our customer subcontracts the ballscrews, spindles, etc. to us.

Sometimes we're tier 2, sometimes tier 3.

WE MANUFACTURE NEW PRODUCTS FOR THE AEROSPACE INDUSTRY - SO WE ARE GOING TO BE AS9100 REGISTERED.

We also repair and manufacture new for at least a dozen different industries from machine tool to medical equipment to sporting goods.

We are also going to get Part 145 Repair Station certificated in order to repair and maintain ballscrews for commercial aircraft.

We are not opting for maintenance only; I'm not sure how you got that from what I'm saying.

Hi Cari,

Hope you are not getting frustrated with us. We are trying to understand your situation. I feel confident you are moving forward. Your posts do indicate that in a positive mode. We are here to learn from others as well as help when we can.

I am just so curious as to HOW your organization can, as you say, "MANUFACTURE NEW PRODUCTS FOR THE AEROSPACE INDUSTRY", without having Part 21 certification from the very beginning. Can you in fact manufacture aircraft parts as O.E.M., and sell these parts to your aerospace customers without FIRST having Part 21 certification. WHO determines Airworthiness?

Best regards! :)

Yes. Our customer has the contract for a landing gear assembly or a brake actuating system, for example, that has 2 or 3 ballscrews in it. We are subcontracted for the ballscrews.

It's the same tier(s) as our non-aerospace OEM work. One of the B3 contracts our customer to build a dozen of this machining center. Our customer subcontracts the ballscrews, spindles, etc. to us.

Sometimes we're tier 2, sometimes tier 3.

OK! I fully understand now. Makes sense! Full speed ahead. :applause:

Can you in fact manufacture aircraft parts as O.E.M., and sell these parts to your aerospace customers without FIRST having Part 21 certification. WHO determines Airworthiness?
We can and are. The customer determines airworthiness and they excercise control over their suppliers. We also make aftermarket / replacement ballscrew components for aerospace customers.

We are being considered as a subcontractor for a Part 145 certificated Repair Station right now. They can subcontract work to a non-certificated repair station, but we have to agree to let their FAA inspector come in and they have to ultimately determine airworthiness.

There may come a time when we are registered to both AS9100 and AS9110 and also certificated to Part 145 and Part 21. :mg: Whatever the customers want - most of the FAA requirments are paralleled in the AS standards anyway.

:2cents:Let me guess. Cari's organization does not hold any certificates. It sells to the approval holder who is responsible for airworthiness and holds the proper certs.

:2cents:Let me guess. Cari's organization does not hold any certificates. It sells to the approval holder who is responsible for airworthiness and holds the proper certs.
Exactly. :agree1: (not yet anyway ;) ) Our customer is responsible for ensuring that our work is done to their quality standards / regulatory requirements. Our work is certified as part of their receiving inspection procedures.

Cari, sorry for the confusion, I had gone back to the top of the thread and was responding to "repair of ball screw" and I was trying to make the point, it is much easier to write to AS9100 with manufacturing and design excluded and going maintenance only. That was the only point I was trying to make.

I had gone back to the top of the thread and was responding to "repair of ball screw" and I was trying to make the point, it is much easier to write to AS9100 with manufacturing and design excluded and going maintenance only. That was the only point I was trying to make.
We don't want to exclude manufacturing for AS9100 - we make new parts. At the top of the thread when I said "repair of ball screw" that was in reference to our Part 145 certification. We are doing both. AS9100 registration will not satisfy the Repair Stations and Airlines - they want Part 145 certification.

Exactly. :agree1: (not yet anyway ;) ) Our customer is responsible for ensuring that our work is done to their quality standards / regulatory requirements. Our work is certified as part of their receiving inspection procedures.When you get your FAR 145 Cert, where will you get the your parts to do the R&O (Repairs and Overhaul)? You do know that you must used Approved parts and since you do not hold the approvals, you will need to "purchase" the parts or assemblies from youir customer since they hold the airworthiness approvals.

We can and are. The customer determines airworthiness and they exercise control over their suppliers. We also make aftermarket / replacement ballscrew components for aerospace customers.

We are being considered as a subcontractor for a Part 145 certificated Repair Station right now. They can subcontract work to a non-certificated repair station, but we have to agree to let their FAA inspector come in and they have to ultimately determine airworthiness.

There may come a time when we are registered to both AS9100 and AS9110 and also certificated to Part 145 and Part 21. :mg: Whatever the customers want - most of the FAA requirements are paralleled in the AS standards anyway.

Since you manufacture and repair & overhaul [as I understand - within the same facility] has the subject of clearly defined separation of facilities come into play?

Al - if, in repairing or maintaining a ballscrew, we need to replace some component - like a retaining tang, wiper, ball bearings, flop over, etc., the customer will either supply those items or direct us to an approved source so we can purchase them.

Muleskinner - we do not need to separate our facility.

Muleskinner - we do not need to separate our facility.That's surprising, we had to maintain a dedicated area for R&O activities. Our Repair Station Manual identified it, in detail, within our facility and any changes required notification to the FAA. They inspected and verified the changes. Of course, the regs may have changed in the past 5 years since I was involved with it?

That's surprising, we had to maintain a dedicated area for R&O activities. Our Repair Station Manual identified it, in detail, within our facility and any changes required notification to the FAA. They inspected and verified the changes. Of course, the regs may have changed in the past 5 years since I was involved with it?
Al, I'm still involved and haven't seen a change in the regulation.

Cari, Glad to hear you are NOT being hassled about this but I am surprised.

Best regards!

Hmmm, I will double check with our guy to make sure I understood him correctly when I asked him about this.

We have receiving; where we receive everything - repair evaluations whether they're ballscrews or acme lead screws or a churning auger, and whether they're FAA work or some guy whose machine crashed and they found us in the phone book. We don't need a separate dock for FAA repairs, we just need to show him how we delineate FAA work from others.

We have tear down; where we tear down everything. I don't need a separate tear down area for FAA work, I need to show him how FAA work is identified as such so that our tear down guys know not to tear it down because John is the only one authorized to tear down FAA work.

We have assembly; where all ballscrews are assembled. Again - I don't need an entirely different room for FAA assembling only - I need to show him how we ensure that only a designated employee will assemble the unit.

I'll send him an email today and let you know what he says. I believe Paula's repair station does work that is not in the scope of their certification - non-FAA work - maybe she'll pop in soon and catch up on this thread.

Cari,
My total experience is with repair stations that have class ratings. That's probably the main difference. And I agree that as long as things are properly labeled, tagged, segregated, etc., and you consistently demonstrate control; you should be ok. Also, the regulations are the same for all, but PMIs have their own ways too. I'm certain you are in compliance with Part 145 after all you have your certificate. :agree1: :)

That's surprising, we had to maintain a dedicated area for R&O activities. Our Repair Station Manual identified it, in detail, within our facility and any changes required notification to the FAA. They inspected and verified the changes. Of course, the regs may have changed in the past 5 years since I was involved with it?

Hi ALL!

Al, the regs have not changed. You are correct that the facility must be identified within the RSM of the area dedicated to the Repair Station.

Please see the attachment for an example. :D

These are two totally separate company's:
1. OEM
2. Certificated Repair Station
AS9100 Certificate may include both, that is up to your you and Registrar.

The Repair Station Manual can reference to some of the AS9100 procedures that are used by both company's.

Cari,
Well now that I read more of this thread, I will have to take a moment to review some of the posts to add more.:bonk: Be back soon!

Cari,
Well now that I read more of this thread, I will have to take a moment to review some of the posts to add more.:bonk: Be back soon!
Raptorwild,
Glad to see your involvement with this thread. Yes! Upon further review, please do, add more. :agree1:
Muleskinner

When you get your FAR 145 Cert, where will you get the your parts to do the R&O (Repairs and Overhaul)? You do know that you must used Approved parts and since you do not hold the approvals, you will need to "purchase" the parts or assemblies from youir customer since they hold the airworthiness approvals.

Hi Cari, Do you send a Certificate of Conformance along with the new manufactured parts and as well as the repaired/overhauled parts to your customers now?
Keep in mind I am only asking about the AS9100 side of the company not the soon to be Repair Station.

Since you are AS9100 already, we know you purchase parts and material from only approved vendors. Can you see where I am going with this?

Back soon!

Hmmm, I will double check with our guy to make sure I understood him correctly when I asked him about this.

We have receiving; where we receive everything - repair evaluations whether they're ballscrews or acme lead screws or a churning auger, and whether they're FAA work or some guy whose machine crashed and they found us in the phone book. We don't need a separate dock for FAA repairs, we just need to show him how we delineate FAA work from others. "This area would be designated as a part of the Repair Station"

We have tear down; where we tear down everything. I don't need a separate tear down area for FAA work, I need to show him how FAA work is identified as such so that our tear down guys know not to tear it down because John is the only one authorized to tear down FAA work. "This may be accomplished by the Roster and by identifying the FAA work with an "unserviceable parts tag" or something like that and information filled out on the applicable work order."

We have assembly; where all ballscrews are assembled. Again - I don't need an entirely different room for FAA assembling only - I need to show him how we ensure that only a designated employee will assemble the unit. "This may be accomplished by the Roster and by identifying the FAA work with an "unserviceable parts tag" or something like that and information filled out on the applicable work order."

I'll send him an email today and let you know what he says. I believe Paula's repair station does work that is not in the scope of their certification - non-FAA work - maybe she'll pop in soon and catch up on this thread.
Hope that helps!
Paula:tg:

Raptorwild,
Glad to see your involvement with this thread. Yes! Upon further review, please do, add more. :agree1:
Muleskinner

Thanks Muleskinner!

I have recently moved on to another Repair Station and have the position of "Return to Service Inspector". We are also a manufacturer of PMA switches and test equipment, which is completely segregated from the Repair Station. Unfortunately...we are not AS9100 or ISO9000 certified :( Our customers do not require it at this time so the owners have not YET looked into it. They knew when they hired me that I am involved since the phone interview took place when I was catching a plane to do an ISO9000 Surveilance audit in OK City. I am hoping that is one of the reasons they hired me, but I have not had the nerve yet to approach them on the subject. SOON! Thats why I have not been able to post lately! I will make more of an effort to add to this thread because I, like Cari have received a ton of knowledge from the Cove. This is my favorite site!:applause: Thanks Marc!

Raptorwild, it's great you have some time to post again. No doubt you've been busy with your recent move to another Repair Station. Are you now with a totally NEW organization, or have you transferred to another division of the company listed in your profile?

Ahh!..."Return to Service Inspector"...IMO those were the good ol' days. :)

PMA...completely segregated from the Repair Station...That's where I was coming from when I 'posted' to Cari. Our organization is required by FAA to have Totally Separate Facilities. They are housed within the same building, but clearly defined and segregated with physical barriers and separate access. Of course as you are most likely aware, Part 145 Repair Station is a matter of FSDO oversight, while Part 21 PMA belongs to REGIONAL.

Unfortunately...we are not AS9100 or ISO9000 certified Our customers do not require it at this time so the owners have not YET looked into it. They knew when they hired me that I am involved since the phone interview took place when I was catching a plane to do an ISO9000 Surveilance audit in OK City. I am hoping that is one of the reasons they hired me, but I have not had the nerve yet to approach them on the subject. SOON!

No doubt you will be ready at any time to step up to the plate regarding AS9100 or ISO9000 certification. You'll find your nerve as gap analysis builds its case. :D

In the meantime an occasional ISO9000 Surveilance Audit might just be the ticket to keep you content while you play the waiting game. :bonk:

Meanwhile, any thread you can post responses to, or for that matter any threads you choose to generate in this Aerospace/Aviation Forum is greatly appreciated. It's good to know there are other 'Covers' here who daily APPLY/WORK the regs and standards.

I'd like to see the AS9100 FORUM BOK expand and grow, so that when likeminded seekers of knowledge search the web, they can find it here at 'The Elsmar Cove Web Site.'

this is my favorite site! :applause: Thanks Marc!
Ditto!

Do you know of others (by User Name) besides Cari who are working at Part 145 Repair Stations with or without AS9100 and/or ISO9000 certification?

Thanks,

Don
AS9100 FORUM MODERATOR

I have read the questions and answers listed for the question Cari posted.
Apples and oranges are being mixed in the same basket.

FAA FAR 145 is directed toward controlling the product.
AS 9100 is a control of the process for controlling the product. I have audited several companies that have a great inspection system that meets the requirements of FAR 145 but do not come close to meeting the requirements of AS9100. The requirements of FAR 145 are treated a subset of requirements to AS9100. A company that has a well implemented AS9100 Quality Management System will most always reference FARs as separate document sets.
I hope this helps.

Having written more than 80 plus RSMs this past year and 7 AS9100s and 2 9110s I can say that, AS9100 auditors don't look at the facilities in the same way as the AS9100 auditors do. I wrote four PMA manuals this past year and all of the FAA inspectors wanted seperation when it came to the production of parts. I know after writing to the new rule (Part 145) that IPs vary some. But all I have encountered have insisted on seperation when it came to the production of the parts.

Having written more than 80 plus RSMs this past year and 7 AS9100s and 2 9110s I can say that, AS9100 auditors don't look at the facilities in the same way as the AS9100 auditors do. I wrote four PMA manuals this past year and all of the FAA inspectors wanted seperation when it came to the production of parts. I know after writing to the new rule (Part 145) that IPs vary some. But all I have encountered have insisted on seperation when it came to the production of the parts.

Blue Tuna...would you care to clarify your statement... :rolleyes:

I have read the questions and answers listed for the question Cari posted.
Apples and oranges are being mixed in the same basket.

FAA FAR 145 is directed toward controlling the product.
AS 9100 is a control of the process for controlling the product. I have audited several companies that have a great inspection system that meets the requirements of FAR 145 but do not come close to meeting the requirements of AS9100. The requirements of FAR 145 are treated a subset of requirements to AS9100. A company that has a well implemented AS9100 Quality Management System will most always reference FARs as separate document sets.
I hope this helps.

Bill, Welcome to 'The Cove'! :bigwave:

Glad to see you here. Wouldn't you agree that AS9100 has more to do with FAR Part 21 than it has to do with FAR Part 145 Repair Stations. It is my understanding that AS9110 is actually best fit for Part 145 Repair Station MRO.

You may take your choice. When comparing the requirements of AS9100 to the requirements of AS9110 you will find that AS9110 is almost identical to the requirements of AS9100. I found there is little difference. AS9110 is AS9100 with some incorporated requirements from the newly revised FAR145. I have compared AS9110 and AS9100 word for word the changes incorporated in to AS9100 that makes the AS9110 are nearly identical to the recent revisions to FAR 145. The standards are so nearly identical you have to compare them paragraph by paragraph to identify the areas changed.

You may take your choice. When comparing the requirements of AS9100 to the requirements of AS9110 you will find that AS9110 is almost identical to the requirements of AS9100. I found there is little difference. AS9110 is AS9100 with some incorporated requirements from the newly revised FAR145. I have compared AS9110 and AS9100 word for word the changes incorporated in to AS9100 that makes the AS9110 are nearly identical to the recent revisions to FAR 145. The standards are so nearly identical you have to compare them paragraph by paragraph to identify the areas changed.

Bill, in the Aerospace Industry, "almost identical" is NOT good enough!

Would you share with us what you have found to be of little difference between the two standards. If you where fitting/implementing one of these standards to a FAA Part 145 Repair Station, which would you choose?

AS9100 or
AS9110

Thanks for your response! :)

There are some major differences between the two. First AS9100 is a manufacturing standard, while 9110 is maintenance focused. I have never counted but my guess is there are well over "30 add ins" to the 9110. On the other hand while the 9110 requires this extra work, you don't have the first article issue nor the design and development sections which are major. Many of the add ins to the 9110 are the types of things you would expect to find for a Part 145 Repair Station. A few of my customers wanted their QMS written to AS9110 even though it is not presently being certificated. One of these companies is a major aerospace company with 12 depots here in the U.S. So, now they are waiting for 9110 auditors to be approved before they can seek certification. Another customer has a prime leaning on them for certification so they decided on AS9100 because certification is available now. As a Part 145 repair station they simply opted out first article, and design elements in the AS9100. They were just certificated this past month for maintenance only. If they decide to add elements of manufacturing they can do so at a later date during an annual audit.

A quick glance at the two standards side by side and the differences begin to emerge. The cool thing about working with repair stations is they already have much of the supporting documentation in place for a AS9110 or 9100 quality systems. It is a matter of becoming process oriented and added the elements unique to the standard.

Blue Tuna...would you care to clarify your statement... :rolleyes:
About facilities AS9100 auditors don't have the same fascination with the facility as does a FAA inspector would. The last few FAA PMAs I wrote, the inspectors wanted separation in facilites.

Blue Tuna, Thank you! You put the major differences between the two in proper perspective. :agree1:
There are some major differences between the two. First AS9100 is a manufacturing standard, while 9110 is maintenance focused. I have never counted but my guess is there are well over "30 add ins" to the 9110. On the other hand while the 9110 requires this extra work, you don't have the first article issue nor the design and development sections which are major. Many of the add ins to the 9110 are the types of things you would expect to find for a Part 145 Repair Station. A few of my customers wanted their QMS written to AS9110 even though it is not presently being certificated. One of these companies is a major aerospace company with 12 depots here in the U.S. So, now they are waiting for 9110 auditors to be approved before they can seek certification. Another customer has a prime leaning on them for certification so they decided on AS9100 because certification is available now. As a Part 145 repair station they simply opted out first article, and design elements in the AS9100. They were just certificated this past month for maintenance only. If they decide to add elements of manufacturing they can do so at a later date during an annual audit.

A quick glance at the two standards side by side and the differences begin to emerge. The cool thing about working with repair stations is they already have much of the supporting documentation in place for a AS9110 or 9100 quality systems. It is a matter of becoming process oriented and added the elements unique to the standard.

About facilities AS9100 auditors don't have the same fascination with the facility as does a FAA inspector would. The last few FAA PMAs I wrote, the inspectors wanted separation in facilities.

True, most FAA inspectors I know consider themselves to be prime stakeholders of Part 145 Repair Stations for which they have granted Air Agency Certificates. :D

Having written more than 80 plus RSMs this past year and 7 AS9100s and 2 9110s I can say that, AS9100 auditors don't look at the facilities in the same way as the AS9100 auditors do. I wrote four PMA manuals this past year and all of the FAA inspectors wanted seperation when it came to the production of parts. I know after writing to the new rule (Part 145) that IPs vary some. But all I have encountered have insisted on seperation when it came to the production of the parts.

WOW! 80 plus RSM's in one year? I am suprised that there are so many company's getting their Air Agency Certificate, and good for you Blue Tuna getting all that business! Are these re-writes or implementation RSM's? :bigwave:

Raptorwild, it's great you have some time to post again. No doubt you've been busy with your recent move to another Repair Station. Are you now with a totally NEW organization, or have you transferred to another division of the company listed in your profile?


Thanks,

Don
AS9100 FORUM MODERATOR

I have to check my profile but this is a totally new organization.:D

I have to check my profile but this is a totally new organization.:D

You may want to check your web-link. :)

All but one was a re write to the new rule. I was a very busy boy last year. !00% pass rate. Very funny, my only real problem was one particular region up in the northeast part of the country. The FAA inspectors wanted it a little different than the rest of the country.

All but one was a re write to the new rule. I was a very busy boy last year. !00% pass rate. Very funny, my only real problem was one particular region up in the northeast part of the country. The FAA inspectors wanted it a little different than the rest of the country.

WOW! 80+ re-writes to the new rule. I had to do three for my company and thought I was busy. Yes, you where 'a very busy boy'! :applause:

'FAA inspectors want it a little different'...I know what that's like. In the early 1990's my repair station (I was Chief Inspector at the time) went through a NASIP Inspection. A team of 7 FAA Inspectors from different regions all over the country converged on our repair station at once.

Our name had been pulled out of the hat. Well, throughout the course of their FIVE DAY visit (grueling to say the least), each inspector brought up findings for their area of inspection. When we challenged them, they would all team together and begin to :argue: between themselves, stating differing interpretations. :bonk:

The end results for us was a pass with flying colors. :cool:

WOW! 80+ re-writes to the new rule. I had to do three for my company and thought I was busy. Yes, you where 'a very busy boy'! :applause:

'FAA inspectors want it a little different'...I know what that's like. In the early 1990's my repair station (I was Chief Inspector at the time) went through a NASIP Inspection. A team of 7 FAA Inspectors from different regions all over the country converged on our repair station at once.

Our name had been pulled out of the hat. Well, throughout the course of their FIVE DAY visit (grueling to say the least), each inspector brought up findings for their area of inspection. When we challenged them, they would all team together and begin to :argue: between themselves, stating differing interpretations. :bonk:

The end results for us was a pass with flying colors. :cool:If you ask two FAA Inspectors the same question you will get at least three different answers.

If you ask two FAA Inspectors the same question you will get at least three different answers.

Some folks get three different answers from just one FAA Inspector. :soap:

WOW! 80+ re-writes to the new rule. I had to do three for my company and thought I was busy. Yes, you where 'a very busy boy'! :applause:

'FAA inspectors want it a little different'...I know what that's like. In the early 1990's my repair station (I was Chief Inspector at the time) went through a NASIP Inspection. A team of 7 FAA Inspectors from different regions all over the country converged on our repair station at once.

Our name had been pulled out of the hat. Well, throughout the course of their FIVE DAY visit (grueling to say the least), each inspector brought up findings for their area of inspection. When we challenged them, they would all team together and begin to :argue: between themselves, stating differing interpretations. :bonk:

The end results for us was a pass with flying colors. :cool:


Wow! A team of inspectors. I would have had to suddenly gone on vacation!