Hello,

We are a small stocklist broker and would normally be going after a 9120 cert but as we obtain AR stock and outsource the repair to a 145, our certification auditor has required us to go instead for AS9100. We've had our certication audit and I have a CAR stating we did not propertly address First Article.

I have talked to several auditors and all are scratching their head as to how we are to comply with 8.2.4.2. Parts come in with trace, we do a visual inspection and out the door they go. We do not have any design or production capability.

Any advice would be appreciated. Thanks.

This section of 9100 appears to call for something similar to the automotive industry's PPAP. And in the auto industry one must get PPAPs from supplies for new parts and parts after engineering and/or process changed.

It would appear to not apply to each production run, but only the original run prior to you accepting and shipping. That is, how did you confirm that the product you ordered met all requirements before you released the supplier for ongoing production?

The parts we purchase are either New Surplus, Serviceable or Overhauled and come with trace paperwork and 8130's. Most are years old.

The small amount we distribute directly I'm sure have been through First Article Inspection but I'm not sure how we can side-step our FAI responsibility and just flow new and excess inventory all back to the OEM.

We represent 20,000 line items so it is not feasible to require FAI paperwork with each item we resell.

Make sense?

We represent 20,000 line items so it is not feasible to require FAI paperwork with each item we resell.

For items that we do not produce ourselves, we flow the AS9100 FAI requirement down to our sub-tier suppliers via our PO terms and conditions. We do not ask for delivery of a FAIR in every case but we do require that the supplier have a system to produce and maintain one, including a delta FAI following the implementation of a change.

I would ask the auditor for clarification. IMO, the FAI needs to get done. You can flow the requirement down or you can do it yourself upon receipt of the product.

You are a distributor not a manafacture (you do not hold a PAH) and so the 9120 is the correct certification to obtain in my view.
Your suppliers work to CMM's if the are doing 145 work which may not even represent the exact requirements of the original design print.
You "control" parts for airworthness thru the use of the 8130-3 tag and the guidance given in 8130.21 to reissue this tag.
I would ask the certification auditor why in the aerospace world in the context that you opperate he thinks you need to comply to 9100.
:2cents:

Hello roonyg

Andygr is right (again!). You are using the wrong standard, the only standard you are capable of meeting is AS9120. It doesn't matter that you outsource the 145 repair, it is not you that issues the Form 1 or 8130, it is the 145 repair station, you simply pass it on to your customer.

Your auditor does not understand the regulatory environment with respect to the aerospace supply chain. The reason you won't comply with the FAI requirement is because you can't. I would be extremely surprised if a stockist has the necessary technical data to complete a FAI, particularly for the equipment you are selling. Why would you need it?

Having you try to meet the FAI requirement sounds about as silly as all the 145 repair stations attempting to do so and we all know how many AS9100 approved repair stations there are in the US. (Sorry, just a bee in my bonnet over that one)

IMO, you should get a new auditor or another registrar; preferably one that actually knows what they're doing. Send your original query to ANAB and ask for a ruling, that should get your registrar in order fairly quickly.

Cheers

We are a large aerospace supplier (distributer, Inventory management organisation) and are certified to ISO 9001:2000 and comply to the requirements of FAA AC 00-56A. I would recommend that you appoach the ASA (http://www.aviationsuppliers.org/) for advice. I agree that as a distibuter you cannot be expected to comply with AS 9100. most of out parts that we resell come from the OEM (with 8130-3 or EASA Form One) or from the surpus market and can be traced back to a approved organisation ie 121, 129 or 145.

I appreciate the input. Being new to the industry this has been confusing but a learning experience for me. I am writing the FAI portion and flowing it down to the supplier. If the auditor won't accept that, I'm afraid we will have to appeal as we have a great deal of money tied up into the certificaton process at this point and I hate to start over with another registar.

The whole FAI issue for us seems like a game we are playing to finesse language to get around the fact we can't comply and in the end, that seems to be counter productive to what quality is all about.

Hi ronnyg
The reason why you see it as a game is because there is absolutely no value in you doing it. It offers nothing to your customer nor is there anything in it for anyone in the supply chain. Even if you flow the requirement down to the 145 repair station, they probably won't be able to do it anyway. FAI is First Article -First production part or Delta FAI when one of the triggers occurs.

You are now in the situation where you have spent a lot of money on audits against a standard that does not apply to you. Like you, I wonder just how it can happen.

My advice to you is to appeal now, go to ANAB and tell them the Registrar is trying to audit you to the wrong standard and you have only realised it as there are requirements in the A9100 standard that you just can not comply with. Don't waste any more time finesse'ing (if there is such a word). It is a total waste of your valuable resources and adds nothing to the supply chain.

Tell the Registrar you want your AS9120 Registration from the audit they have already completed. Don't pay them another cent.

Cheers, and good luck!