Control of Non-certificated maintenance contractors

[big rob]

We are a part 145 repair station, and have been found to have discrepancies in our QCM on Contracted Maintenance,Non Certificated repair stations. How do I remain Directly in charge of the work being performed at the Non certificated shop?

Please help: (

[BadgerMan]

Do you specify quality system requirements for your non-certificated contractors?

Do you specify that your non-certificated contractors maintain a D&A program?

Do you then test and/or inspect the product repaired by non-certificated contractors prior to approving it for return to service?

[big rob]

1) Yes, we specify Quality System requirements
2) No, we do not specify they maintain a D/A program.
3) Yes, we test and inspect.

[BradM]

Originally Posted by big rob

We are a part 145 repair station, and have been found to have discrepancies in our QCM on Contracted Maintenance,Non Certificated repair stations. How do I remain Directly in charge of the work being performed at the Non certificated shop?

Please help: (

Hello big rob! Thank you for dropping by the Cove! We're sure glad to have you.

First, I am not that proficient in aviation, so discount it as such. I have worked in the environment before though. I have seen (typically medium size operations) that perform a number of different services on aerospace parts. Usually, they have a portion of their services certified due to it's nature, but the other portions are not. Does that sound like your situation?

Now to your question... I'm not sure I understand. if you are the supervisor; you are the supervisor. Why do you feel a need to distance yourself from the non-certified work? I would think you would be more concerned with creating separation in other ways than supervision.

Not sure my question makes sense. Let me know what you're thinking.

[BradM]

Sorry badgerman, I was putting together my post while you were helping out.

Add edit: I revised the title a bit, so that it might be a little more clear. Let me or any moderator know if it is not suitable.

[BadgerMan]

We do specify that non-certificated contractors maintain a D&A program.

The main difference I see is that we test the product and approve for return to service with non certificated sources whereas with certificated contractors, they can approve for return to service.

Was this an audit nonconformance? Can you ask the auditor for clarification?

[BadgerMan]

Originally Posted by BradM

Sorry badgerman, I was putting together my post while you were helping out.

Add edit: I revised the title a bit, so that it might be a little more clear. Let me or any moderator know if it is not suitable.

I changed it again to add further clarification.

The question deals with (sub) contracted maintenance not "maintenance"......…LOL!

When an FAA approved repair station sub-contracts/out sources repair of a product returned from the field because they don’t have the capability, they can use another approved repair station or a non-approved (certificated) source. The two options require different levels of control from a QMS perspective.

Clear as mud, eh?

[big rob]

Yes, this was an audit non conformance. The auditor is a fast talker and confuses me sometimes. He is helpful but seams to be one that likes verbage to be specific. We try to use certificated stations as much as possible but sometimes it just can't be done.

Thanks for your help.