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View Full Version : What actions the FAA can impose against a company? 21.303 (h) FIS.


Corsair
13th September 2008, 12:21 PM
What actions the FAA can impose against a company and the DMIR if you are not fully compliance with 21.303(h)?
Thanks.

Wes Bucey
13th September 2008, 01:43 PM
What actions the FAA can impose against a company and the DMIR if you are not fully compliance with 21.303(h)?
Thanks.It is my understanding the actions by FAA are a function of the nature of the noncompliance. Ultimately, if the noncompliance is severe enough, FAA withdraws all certification (and with the withdrawal of the certification, FAA can withdraw the "designation" as "Designated Manufacturing Inspection Representative" (DMIR) for failure to note noncompliance under his purview.)

Wes Bucey
13th September 2008, 02:00 PM
Just for laughs, here's a sample of a termination letter from FAA for a DMIRAPPENDIX 6. FAA DOCUMENTATION FOR TERMINATION
FIGURE 2. SAMPLE NOTICE TO A PRODUCTION APPROVAL HOLDER
ON TERMINATION OF A DMIR
[Date]
CERTIFIED MAIL NUMBER: ____________
File Number: ______________
Designee: Mr. John Doe
Designation Number: _____________
Mr. A. Hess, Director of Quality
c/o Concise Aircraft Parts
25 Shore Drive
Atlantic City, NJ 00000
Dear Mr. Hess:
This is to inform you that Mr. John Doe’s Federal Aviation Administration (FAA) designation as a designated
manufacturing inspection representative (DMIR) is suspended immediately and will be terminated on [date].
A copy of this letter is being sent to Mr. Doe. Mr. Doe’s designation will be terminated because [our records
indicate that he has had insufficient activity to warrant continuing the designation or the FAA has
learned that he issued an export airworthiness certificate on more than one engine without having
examined the appropriate paperwork to determine conformity].
[Cite the reference to the regulations/policy requirements that was violated/noncompliance.]
Concise Aircraft Parts may request an appeal of the termination in writing no later than 2 weeks from the date
of receipt of this letter. We would appreciate receiving any evidence or statement Concise Aircraft Parts might
care to make concerning this matter. This evidence or statement should be sufficiently detailed to establish
quantity, nomenclature, and part number of the items in question. In addition, the identification of items
previously installed in FAA-approved products is also requested. Representatives of Concise Aircraft Parts
may discuss this matter with us and be represented by legal counsel. If you elect to bring an attorney, an FAA
attorney will also be present. The FAA will maintain a record of the meeting.
Any discussions or written statements will be given consideration at the conclusion of our review. Unless
we hear from you in writing, Mr. Doe’s designation will be terminated as stated above in accordance with
14 CFR § 183.15(d)(4), for not properly performing his duties under his designation.
Sincerely,
[Manager]
Manager, [Branch or higher, as appropriate]

Al Rosen
14th September 2008, 12:38 PM
21.303(h) is the Inspection System Requirement

(h) Each holder of a Parts Manufacturer Approval shall establish and maintain a fabrication inspection system that ensures that each completed part conforms to its design data and is safe for installation on applicable type certificated products. The system shall include the following:
(1) Incoming materials used in the finished part must be as specified in the design data.
(2) Incoming materials must be properly identified if their physical and chemical properties cannot otherwise be readily and accurately determined.
(3) Materials subject to damage and deterioration must be suitably stored and adequately protected.
(4) Processes affecting the quality and safety of the finished product must be accomplished in accordance with acceptable specifications.
(5) Parts in process must be inspected for conformity with the design data at points in production where accurate determination can be made. Statistical quality control procedures may be employed where it is shown that a satisfactory level of quality will be maintained for the particular part involved.
(6) Current design drawings must be readily available to manufacturing and inspection personnel, and used when necessary.
(7) Major changes to the basic design must be adequately controlled and approved before being incorporated in the finished part.
(8) Rejected materials and components must be segregated and identified in such a manner as to preclude their use in the finished part.
(9) Inspection records must be maintained, identified with the completed part, where practicable, and retained in the manufacturer's file for a period of at least 2 years after the part has been completed.


It depends. Did you ignore a warning notice or letter of correction? Look at the attached order 2150-3b.

Corsair
21st September 2008, 12:26 PM
Al, I'm sorry for the delay.
No,we didn't ignore a letter of correction, but we skip some inspection steps on one of our PMA parts.We can be audit at any time now, I wonder if will be a good idea to write a letter to the FAA explaining what happen.Is the DMIR responsability to do that?:thanks.

Al Rosen
21st September 2008, 04:25 PM
Al, I'm sorry for the delay.
No,we didn't ignore a letter of correction, but we skip some inspection steps on one of our PMA parts.We can be audit at any time now, I wonder if will be a good idea to write a letter to the FAA explaining what happen.Is the DMIR responsability to do that?:thanks.Did you document why you skipped the inspection? Was it able to be evaluated at a later step in the process? How would it affect the product? If the inspection isn't necessary, change the process. Just some things to think about.

Corsair
26th September 2008, 08:01 PM
We did not documented, "why" because we did not have the inspection fixtures. All these parts were ship in a hurry because the customer was in urgent need.It was a management call.Now they are kind of worry.:thanx:

Al Rosen
27th September 2008, 12:54 PM
I hope they weren't critical to safety of flight.