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View Full Version : Small FAA Repair Station & ISO 9001 - I need Help!


FLYBOYJ
31st August 2005, 02:24 PM
Greetings! this is my first post on this site (great stuff) I am the QC Manager/ Chief Inspector at a small FAA Repair Station. We do contract aircraft maintenance for the government on light aircraft. We have a "Limited" Airframe and Powerplant rating.

We have just been mandated to comply with ISO 9001-2000. There are certain aspects of Chapter 7 "Production Realization" that I believe are not applicable to our operation (customer related processes, design and development, production & service provision) as we provide a basic service - aircraft maintenance. We don't manufacture anything here, we purchase OEM parts, and just provide a service - aircraft maintenance. My question; Are there any other members in this (or have been) situation? I've worked under Mil-45208A and ISO-9002 and it seems these requirements would be better tailored to my operation.

Last note - My FAA PMI has reviewed my Repair Station Manual and loves it, he could care less if I'm ISO compliant, as he says "I just care about FAR 145." In addition, the government just wants me to be ISO-9001-2000 compliant, no 3rd party registration. Any suggestions or comments?!? :confused:

Al Rosen
31st August 2005, 02:43 PM
Greetings! this is my first post on this site (great stuff) I am the QC Manager/ Chief Inspector at a small FAA Repair Station. We do contract aircraft maintenance for the government on light aircraft. We have a "Limited" Airframe and Powerplant rating.

We have just been mandated to comply with ISO 9001-2000. There are certain aspects of Chapter 7 "Production Realization" that I believe are not applicable to our operation (customer related processes, design and development, production & service provision) as we provide a basic service - aircraft maintenance. We don't manufacture anything here, we purchase OEM parts, and just provide a service - aircraft maintenance. My question; Are there any other members in this (or have been) situation? I've worked under Mil-45208A and ISO-9002 and it seems these requirements would be better tailored to my operation.

Last note - My FAA PMI has reviewed my Repair Station Manual and loves it, he could care less if I'm ISO compliant, as he says "I just care about FAR 145." In addition, the government just wants me to be ISO-9001-2000 compliant, no 3rd party registration. Any suggestions or comments?!? :confused:Perhaps design and development is not appropriate, but your product is a maintenance service. Customer related processes are also applicable. Can you specify which clauses you believe are not applicable and why?

scout
31st August 2005, 02:56 PM
I would suggest you get a copy of AS-9110. That standard is written for repair stations.
Steve

FLYBOYJ
31st August 2005, 02:56 PM
Perhaps design and development is not appropriate, but your product is a maintenance service. Customer related processes are also applicable. Can you specify which clauses you believe are not applicable and why?

The customer has not identified specific processes, unless you want to consider AFTO 00-20-1 (USAF Aircraft Maintenance Procedures) as a process. This basically is a guide to aircraft documentation and USAF aircraft maintenance procedures. Our other mode of compliance lies with the Federal Aviation Regulations

8.3 - control of nonconforming product, we don't manufacture anything?!?

FLYBOYJ
31st August 2005, 02:57 PM
I would suggest you get a copy of AS-9110. That standard is written for repair stations.
Steve


Thanks :thanx:

Randy
31st August 2005, 03:01 PM
Non-conforming product can relate to any of your activities that don't meet spec and also to purchased or supplied material.

Are you a cost plus or flat fee based contractor?

I have 18 years of gov't (DoD contracting, 12 with Lockheed on a USAF managed Army aircraft maintenance contract) and I'm an A&P mechanic

FLYBOYJ
31st August 2005, 03:05 PM
Non-conforming product can relate to any of your activities that don't meet spec and also to purchased or supplied material.

Are you a cost plus or flat fee based contractor?

I have 18 years of gov't (DoD contracting, 12 with Lockheed on a USAF managed Army aircraft maintenance contract) and I'm an A&P mechanic

The basic contract is flat fee. We do "over and aboves" when the customer "breaks" an airplane outside the contract maintenance scope.

scout
31st August 2005, 03:05 PM
Thanks :thanx:


No problem. Once you get the standard and look it over post any questions you may have on the site and I will help if I can. I came from the aircraft maintenace world and am a qualified AS9100/AS9110 auditor.

Don Palmer
31st August 2005, 03:11 PM
FlyboyJ, Welcome to The Cove. :bigwave: My organization has 25+ years as FAA Certified Repair Station, and we went ISO 9001:2000 a year and a half ago to accommodate a government contract.

I can't write a lot at the moment, but will do my best to share some answers with you this evening. Additionally, there are others here at the Cove who are well qualified to offer you some good food for thought.

Al Rosen
31st August 2005, 03:49 PM
The customer has not identified specific processes, unless you want to consider AFTO 00-20-1 (USAF Aircraft Maintenance Procedures) as a process. This basically is a guide to aircraft documentation and USAF aircraft maintenance procedures. Our other mode of compliance lies with the Federal Aviation RegulationsThat's one you've identified. What about contract terms and delivery and customer communications, etc.

8.3 - control of nonconforming product, we don't manufacture anything?!?How do you handle the defective parts removed from the aircraft? What about purchased parts that don't meet purchase order requirements.

FLYBOYJ
31st August 2005, 04:12 PM
That's one you've identified. What about contract terms and delivery and customer communications, etc.

There are basic contract requirments for mission capable rates (for the aircraft) and specified meetings. It's kept real simple....


How do you handle the defective parts removed from the aircraft? What about purchased parts that don't meet purchase order requirements.

If the defective part is a time changed item, it is removed and retuend to the customer (GFE). If it's defective from an OEM, it's returned and C/A is mandated. Believe it or not, I've returned maybe 4 items in 1.5 years! Our aircraft are very simple and we rarely have problems with purchsed parts.

Al Rosen
31st August 2005, 05:27 PM
There are basic contract requirments for mission capable rates (for the aircraft) and specified meetings. It's kept real simple....



If the defective part is a time changed item, it is removed and retuend to the customer (GFE). If it's defective from an OEM, it's returned and C/A is mandated. Believe it or not, I've returned maybe 4 items in 1.5 years! Our aircraft are very simple and we rarely have problems with purchsed parts.The point is it needs to be addressed in your system

FLYBOYJ
31st August 2005, 05:31 PM
The point is it needs to be addressed in your system

It is - it's in my FAA Repair Station manual, Where I'm going with this is much of the parts we changed or found defective are items "timed out," required to be changed by the manufacturer (magnetos, wheel bearings, ect.) I don't see things like this going through a formal MRB

Al Rosen
31st August 2005, 05:37 PM
It is - it's in my FAA Repair Station manual, Where I'm going with this is much of the parts we changed or found defective are items "timed out," required to be changed by the manufacturer (magnetos, wheel bearings, ect.) I don't see things like this going through a formal MRBWho mentioned MRB? Reference your RSIPM (Repair Station Ispection Procedures Manual) in your ISO 9000 QSM.

FLYBOYJ
31st August 2005, 08:33 PM
Who mentioned MRB? Reference your RSIPM (Repair Station Ispection Procedures Manual) in your ISO 9000 QSM.

I have a RSIPM and a Quality Control Program Plan (QAPP)that contains specific procedures for my operations. Do I need to write an ISO QSM or can I talior my QAPP for ISO?

Al Rosen
1st September 2005, 10:16 AM
I have a RSIPM and a Quality Control Program Plan (QAPP)that contains specific procedures for my operations. Do I need to write an ISO QSM or can I talior my QAPP for ISO?Tailor what you have. You can use one of the Gap Analysis documents found here (http://elsmar.com/Forums/attachment_browser.php?s=&pagenumber=1&sortfield1=timestamp&sortorder1=desc&sel_filename=*gap*&perpage=100&sel_extension=&sortfield2=filename&sortorder2=asc&sel_cutoff_days=-1&sel_cutoff_type=newer&sel_username=&sel_userid=&sel_forumid=) to first determine where in your documentation you address each requirement and then verify compliance.

Don Palmer
1st September 2005, 12:27 PM
FLYBOYJ,
Two years ago our Certified FAA Part 145 Repair Station organization was required by a major customer (government contract) to become ISO 9001:2000 compliant. We were not required to have 3rd party registration either, but went for registration anyway and got it.

Per ISO 9001:2000 Quality Management Systems Requirements (clause 1.2 Application) allows for exclusions within clause 7 of the standard. We excluded only clause 7.3 Design and Development requirements since we do not manufacture anything either. All other clauses of the ISO standard are included and covered in our ISO Quality Management System (QMS) documented Quality Manual (QM) and Quality System Procedures Manual (QSPM) and under totally separate cover from our FAA Repair Station Inspection Procedures Manual, etc.

My FAA PMI has interest only in the required FAR PART 145 RSM too. And I don’t want him to care in the least about our ISO QMS. If my FAR and ISO manuals were all rolled into one document system (as AS-9110 implies), we’d have a nightmare from h*ll on our hands. My PMI’s favorite speech about manuals is, “Say what you do, and do what you say”; “That’s what I’ll be looking at when I come to perform surveillance at your repair stations.” “If it’s in your RSM, you better be doing it.” That is why I have two separate documented quality systems, one to satisfy FAA regulatory requirements and the other to satisfy the ISO standard.

I wrote our repair station’s FAR Part 145 manuals when the new regulation went into effect. My PMI was very pleased with it, because it covered all the SHALLS required for the FAA manual and his acceptance. ALL PROCEDURES are fully contained and documented within the Repair Station Manual System. When I began writing the ISO documented quality management system manuals, a considerable amount of my PROCEDURES/PROCESSES were already in place in the FAR QSPM. So where I had existing PROCESSES/PROCEDURES, I made reference in my ISO manual documentation back to the FAA QSPM.

For instance ISO clause 7.6 Control of monitoring and measuring devices is already covered in my FAA QSPM so I make reference only in my ISO manual back to my FAA manual for tool calibration control processes (procedures).

My ISO Registrar Auditors are happy :drunk: with this setup and find it to be in conformance with the standard. Again, my FAA PMI cares only about FAR manual content and doesn’t see any of the ISO manuals content. On the other hand my ISO 3rd party auditors see both the ISO and FAR manuals.
Through the process of learning the ISO language, I came to realize that SERVICE IS our PRODUCT, that ISO was originally written for manufacturers, and that the ISO language has transitioned to cover service industry as well. So when reading the word PRODUCT in the ISO standard, I translate the word to mean SERVICE.

Excluding clause 7.3 Design and Development (as mentioned above for justified reason) ALL OTHER SHALL STATEMENTS of ISO 9001:2000 are included in our QSM QM and QSPM. Again, with emphasis I state that all requirements of the standard (with the exception of 7.3) are included in our QMS, and we work all of these processes every day.

In conclusion (for this message), I’d like to say that had the decision been mine, I would have only accommodated the government (military) contract request for becoming ISO 9001:2000 COMPLIANT only. But it was not my decision to make. The only thing my Government Flight Representative (GFR) and in-house DCMA representatives are interested in, regarding ISO 9001:2000 compliance, is that we have QMS processes that we follow regarding the terms of the contract.

In my opinion the reason these government military aircraft contract terms require ISO compliance ONLY is that it simplifies (for the government) the writing and enforcing of the contract, because then the ISO manuals can be referenced in the contract, rather than all the content that ISO 9001:2000 contains.

FLYBOYJ, do you have a full set of the ISO standard (e.g. ISO 9000:2000, ISO 9001:2000, ISO 9004:2000)? How much time have you been given to become ISO compliant? Are you attempting to write the manuals yourself? Do you have FULL commitment, support (resources) and understanding from you Top Executive Management?

I’ve been where you are now, and work every day in FAA/EASA/ISO world of compliance/conformance. It ain't easy but it is possible! :bonk:

Muleskinner – Quality Systems Director
FORUM MODERATOR @ The Cove

FLYBOYJ
1st September 2005, 03:02 PM
MANY MANY THANKS! YOU'RE EXACTLY THE PERSON I WAS HOPING TO REACH ON THIS SITE! I'M GOING TO TAKE YOU'RE SUGGESTIONS AND RUN WITH THEM - AGAIN MANY THANKS!!!! :thanx: :thanx: :thanx: :applause:

Don Palmer
1st September 2005, 03:47 PM
MANY MANY THANKS! YOU'RE EXACTLY THE PERSON I WAS HOPING TO REACH ON THIS SITE! I'M GOING TO TAKE YOU'RE SUGGESTIONS AND RUN WITH THEM - AGAIN MANY THANKS!!!! :thanx: :thanx: :thanx: :applause:
The Elsmar Cove Site Mission
A Primary, Personal Information Resource for ISO 9001 and the ISO 9000 Series, ISO 14001, ISO 19011, as well as the ISO/TS 16949 and QS-9000 automotive standards to Quality, Engineering and Management professionals. People Helping People! (http://elsmar.com/index.html)
Please keep us all (here at the Cove) in the loop, as you make progress and achieve the possible. :) GIT-R-DONE! :agree1:

FLYBOYJ
4th March 2006, 03:57 PM
Hey folks,

It's been a while since I've been on and once again I have to thank you all that gave me input. It turned out my customer just wanted us to go "ISO 9001-2000 Compliant." We rolled the cost of full compliance with a third party registry into the contract cost and they back off the full requirement. With that I put together an ISO 9001-2000 guide with a compliance matrix showing how we comply with all elements as a result of our Repair Station Manual, Operational Instructions (OIs), Quality Plan, and Air Force TOs - so far my customer loves it - as I put it, it like being a little pregnant. Anyway the customer's happy, my FAA PMI is happy, my boss is happy. Again I appreciate the input and the links I gathered from this site to assemble my ISO guide!!!:thanx:

qualityman46
5th March 2006, 12:17 AM
Flyboy,

In 1997 I helped develop and implement the first FAR 145- ISO 9002 compliant Quality Management System for a repair station in the US.

The first step was developing a cross reference matrix to both QMS requirements (145 & 9002) and keeping the local FAA inspector in the loop during the entire implementation project. We found that he had valuable input from a compliance aspect.

The key was in the planning stage to identify “common processes” and integrate the intent of the requirements to fit the organization.

Both the FAA and the company were very pleased with the end result, an effective QMS system which addressed both compliance and efficiency.

Contact me directly if you need more information