Part 145 Repair Station Rating and Capability List vs. ISO 9001 certificate Scope

[Cari Spears]

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".

[CarolX]

In Reply to Parent Post by Cari Spears

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".

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.

[Cari Spears]

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?

[Cari Spears]

Good Morning, Carol.

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.

[Al Rosen]

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 Section 4-3, Capability List.

[Cari Spears]

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?

[Al Rosen]

In Reply to Parent Post by Cari Spears

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.

[Al Rosen]

Cari, if you follow this link, you will find examples of the Quality System and FAA certificates for an organization that is a manufacturer with a 145 Repair Station.