Have our DOA (EASA Pt21 Subpart J) the authority to audit our suppliers?

[Matrix45]

We are an EASA Pt21 Subpart G (POA) and have selected another organisation as our DOA (EASA Pt21 Subpart J). Have our DOA the authority to audit our suppliers or can this only be performed by our regulatory authority should they wish to do so? Or can the DOA request to conduct audits on our Suppliers with our organisation being present?

[Angelika]

Hi Matrix 45,

is the relationship between your POA and the DOA covered by a DO/PO-agreement i.a.w. 21A.133(c)?

Could you please describe your question more clearly? Who requires your suppliers to be audited - besides the competent aviation authority?

Maybe I can give you further help if you give some more information.

Thanks!

[Matrix45]

Angelika
The relationship is covered in our agreement/arrangement. Basically the problem is that they are not happy with the way we deal with our configuration issues. They have asked to conduct an audit on us-I have no problem with this but they have furthermore asked that they are present when we conduct audits on our suppliers.
I hope this helps

Regards

[Angelika]

As far as I understand, the 21J-DOA (TC-Holder/STC-Holder) is your customer who provides you with the approved design data in order to enable you production and to issue the EASA Form 1. Your POA produces the relevant products/component/parts and supplies these to the DOA and/or to those parties agreed upon in the DDA of the DO/PO-agreement.

§ 21A.239 (c) says:
(c) The design organisation shall specify the manner in which the design assurance system accounts for the acceptability
of the parts or appliances designed or the tasks performed by partners or subcontractor according to methods which
are the subject of written procedures.

It mainly depends on the procedures of a DOA in what depth they need to monitor their subcontractors. That may also include witnessing audits of manufacturers who work under the quality system of a POA (non-approved organisations) or even approved 21G-POA who act as subcontractors of your POA.

Especially if there is an unclear situation, e.g. configuration management issues, it may be helpful if the DOA itself is also available when you audit your supplier to clarify such matters. However, try to make that not a general rule but to limit it to certain cases.


If you have further questions, you may contact me at any time.

Regards,
Angelika


Addition:
Have our DOA the authority to audit our suppliers (depends on what you agreed with them)

or can this only be performed by our regulatory authority should they wish to do so (yes, also the regulatory authority has the authority to witness/perform audits with your subcontractors(? Or can the DOA request to conduct audits on our Suppliers with our organisation being present? (again depends on what you agreed with them)