Customer Audit - C.A.S.E. Standard 1-A vs. AS9110 - Aircraft Assemblies Maintenance

[RCW]

I'm looking for some feedback here....

I just recently went through a customer audit with regards to maintenance for aircraft assemblies. My company is not a certified FAA maintenance supplier and we are not certified to AS9110. I reviewed the purchase orders we received from the customer to provide maintenance and they reference the customer's maintenance spec. That spec calls out compliance to C.A.S.E. Standard 1-A. I received 7 corrective action requests (2 state the same nonconformity) and they all referenced against AS9110. Does that sound right? How can CARs be written up against a spec that is not flowed down to me?

I don't have the AS9110 spec, and I'm assuming the AS9110 and Standard 1-A requirements are similar, but if I'm held to the letter of the law, how come the auditor isn't?

It doesn't surprise me though. The whole audit was performed in a sloppy manner. While I have received the CARs, I haven't received an audit report. (Audit was 2 weeks ago.)

 

[Sidney Vianna]

Re: Customer Audit - CASE v.s. AS9110

How can CARs be written up against a spec that is not flowed down to me?

They can't, unless you accept it.
Since you are in the Aerospace Maintenance, Repair & Overhaul supply chain and you are not certificated by the FAA, typically your quality system should be considered an extension of your customer's (hopefully certificated) quality system. They might have imposed 9110 certification onto you and forgot notme to inform your organization accordingly.

As a member of the IAQG 9110 growth strategy relationship group, I can attest that some large aero customers are in the early stages of flowing down 9110 certification to non (FAA) certificated repair stations.

 

[BadgerMan]

Re: Customer Audit - CASE v.s. AS9110

I moved the thread as I think we'll get a better response in the AS9100 forum.

I'm assuming the AS9110 and Standard 1-A requirements are similar

Although they share some requirements, the two "standards" are different especially with regard to scope.

I sounds to me that there has been a breakdown in communication concerning contractual flowdown of QMS requirements.

 

[RCW]

Re: Customer Audit - CASE v.s. AS9110

They might have imposed 9110 certification onto you and forgot notme to inform your organization accordingly.

They have imposed AS9100 as a requirement but that is coming from the production side of their company, not the maintenance side. Possibly you could confirm this Sidney, AS9100 and AS9110 are not equivalent.

If AS9110 is a requirement here, then is should be stated and flowed down to me. I have no problem working to meet the spec as long as it's a legitimate requirement.

 

[Sidney Vianna]

Re: Customer Audit - CASE v.s. AS9110

Possibly you could confirm this Sidney, AS9100 and AS9110 are not equivalent.

9100 and 9110 share a very large percentage of requirements. There are 9100 certified organizations that extend their scope of certification to the service and repair.

 

[BadgerMan]

Re: Customer Audit - CASE v.s. AS9110

AS9100 and AS9110 are not equivalent.

No, they are not equivalent as Sidney indicated and there are plenty of certificated repair stations that are AS9100 certified as well as manufacturers that extend the scope of their AS9100 certs to their SRO operations. If your customer is flowing down AS9110 compliance, they need to inform you AND you need to agree, contractually.

 

[bornapilot]

Re: Customer Audit - CASE v.s. AS9110

As a former CASE Auditor for a Major Carrier for 15 years I am a little confused by some of your terminology. Were you audited by an air carrier or a 145 Repair Station? If it was an air carrier was the auditor a CASE Authorized Auditor. If you are not an FAA approved "Certificated" 145 Repair Station what type of work are you performing? As a side note and in agreement with the other postings the Standards are different. Also, there are a number of CASE Standards. Which one was used for your audit?

 

[RCW]

Re: Customer Audit - CASE v.s. AS9110

As a former CASE Auditor for a Major Carrier for 15 years I am a little confused by some of your terminology. Were you audited by an air carrier or a 145 Repair Station? If it was an air carrier was the auditor a CASE Authorized Auditor. If you are not an FAA approved "Certificated" 145 Repair Station what type of work are you performing? As a side note and in agreement with the other postings the Standards are different. Also, there are a number of CASE Standards. Which one was used for your audit?

I see your confusion and I raise you one. I guess my answer would be "a 145 Repair Station". I am the OEM and repair station for several aircraft products that I am subcontracted out to build/repair. The company I am supplying these to is a supplier to an aircraft manufacturer. Did that make sense?

I am not a FAA "Certificated" 145 Repair Station. The company that I supply these aircraft products to is the company that is auditing me for repair. I do believe they are certified to 145 repair station status. The only items I am repairing are the products my company has built. We are not repairing items built by other companies.

I have no idea if the person who did the audit was a CASE authorized auditor. My guess is that he wasn't.

As posted earlier, the flowed-down requirement was to C.A.S.E. Standard 1-A. That's the only spec information I have. The actual audit was performed against AS9110. I say that because that's what was referenced in the audit notice (email) I received, and that's what is referenced on the corrective actions requests I received. I have yet to receive an audit report.

 

[bornapilot]

Re: Customer Audit - C.A.S.E. Standard 1-A vs. AS9110 - Aircraft Assemblies Maintenan

Thank you for the clarification. I understand where you are coming from now and your frustration. So, as a manufacture (OEM) per the regulations you are entitled to "Rebuild" what you manufacture. You are not allowed to "Repair" under the regulation as that would require a Repair Station Certificate. I would be careful with those terms as the FAA gets a little bit concerned if you cross over the line into the repair arena. Also, we have all been through some audit nightmares and I have probably caused a few myself over the years so hang in there and let's all learn from our mistakes.

 

[RCW]

Re: Customer Audit - C.A.S.E. Standard 1-A vs. AS9110 - Aircraft Assemblies Maintenan

Thank you for the clarification. I understand where you are coming from now and your frustration. So, as a manufacture (OEM) per the regulations you are entitled to "Rebuild" what you manufacture. You are not allowed to "Repair" under the regulation as that would require a Repair Station Certificate. I would be careful with those terms as the FAA gets a little bit concerned if you cross over the line into the repair arena. Also, we have all been through some audit nightmares and I have probably caused a few myself over the years so hang in there and let's all learn from our mistakes.

YIKES!! Rebuild versus Repair?! More phraseology to keep straight. I'll remember this and use it the next time my customer wants to do an FAA Repair audit. (I'm sorry, we don't do repair, we rebuild.)