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Control of Non-Certificated Maintenance Contractors
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Control of Non-Certificated Maintenance Contractors
Control of Non-Certificated Maintenance Contractors
Control of Non-Certificated Maintenance Contractors
Control of Non-Certificated Maintenance Contractors
Control of Non-Certificated Maintenance Contractors
Control of Non-Certificated Maintenance Contractors
Control of Non-Certificated Maintenance Contractors
Control of Non-Certificated Maintenance Contractors
Control of Non-Certificated Maintenance Contractors
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Some Related Topic Tags
contract services, faa (federal aviation administration), maintenance, faa part 145 (certified repair station), faa repair stations
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  Post Number #17  
Old 10th August 2013, 11:23 PM
Lpitt56

 
 
Total Posts: 18
Re: Contracted Maintenance

I have a similar question related to using a non-certificated contractor to do repairs. We are an FAA Repair Station but with a Limited scope to just perform an inflation test on a component. We have a new FAA agent and during his first inspection he ask if we do any actual repairs. He was told no, only testing but if we receive one with a tear or damaged fitting we send it out for repairs. He said we were in violation because we did not list them or control them as a noncertificated contractor. Hear is the kicker.. we return it to the OEM for repairs. The same OEM who wrote our CMM that we go by for the test we perform and did our training. He was saying if we send them components to repair we must control them like a supplier, perform audits of their facility, etc. I thought an OEM was authorized to do repairs without being a Repair Station under another article. Does this sound right that we need to treat them like a supplier?

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  Post Number #18  
Old 14th August 2013, 06:02 PM
errhine's Avatar
errhine

 
 
Total Posts: 101
Re: Contracted Maintenance

It depends on the circumstances. Who is providing an 8130-3 for the repair, you or the OEM? Is the OEM the Production Approval Holder (PAH) of the design, or are they the supplier to the PAH? Are they a 145 repair station as well?

A PAH is authorized to rebuild articles under the authority of their certificate, but not to repair. Rebuilt means that the article must be to new part production quality.

Regardless of these answers, I believe they should be part of your approved suppliers list as they are providing repair work for you.
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  Post Number #19  
Old 14th August 2013, 08:03 PM
Lpitt56

 
 
Total Posts: 18
Re: Contracted Maintenance

Thanks for the reply. Yes they are the PAH and do repairs that are approved in their CMM which is FAA approved. They send us a CofC when returned and we issue the 8130-3. I felt we would have to list them as an approved sources but do we have to perform periodic audit of their facility? The FAA agent said he yes but I'm not sure he understood they are the owners of the CMM and send us a CofC. Would an audit of their facility be necessary under 145, even when they send us a CofC?
  Post Number #20  
Old 15th August 2013, 10:58 AM
errhine's Avatar
errhine

 
 
Total Posts: 101
Re: Contracted Maintenance

Do you list the repair on your 8130-3? If so you may be exceeding the limitations on your 145 (test only). Does your RSM address this situation? Are there other suppliers that perform work to make a component airworthy that you do not audit as part of an ASL? You don't need to answer, but these are what I would look into.

I would request that the OEM provide an 8130-3 to cover the repair as this would show your ASI that the work is performed by an approved facility.

Depending on the nature of your relationship with the FSDO, it may be worth it to delve into these topics with them, on the up side, if you are out of the box it would count towards a self-disclosure and prevent an LOI. And if you are withing the regulations, you will know as well. Just make sure to document either way.
  Post Number #21  
Old 23rd August 2013, 03:17 PM
neal0o

 
 
Total Posts: 2
Re: Contracted Maintenance

The guidance for rebuilt products are very specific regarding the 8130-3

A PAH may issue an FAA Form 8130-3 for approval for return to service after
rebuilding, altering, or inspecting its product in accordance with ?? 43.3(j) and 43.7(d). The useof FAA Form 8130-3 for this purpose is optional, but the FAA recommends its use. This will help aviation authorities and the industry to ensure complete traceabilit
y and ease the movement of products and articles through the aviation system. (Refer to
paragraph 3-2a(2) and figure 3-1of this order.)

NOTE:

Rebuilt products and articles accomplished by a manufacturer may not be found acceptable by some European countries, because “rebuilt” is not included within the definition of “maintenance” as defined in 14 CFR part 1 or because the European system does not have a similar system that recognizes “rebuilt.” Therefore, when completing FAA Form 8130-3 for the purpose of “rebuilt,” refer to paragraphs 3-2a(3), 3-5m(3), and 4-5l.

reference:

FAA Order 8130-21G - Just google it.
  Post Number #22  
Old 27th August 2013, 06:21 PM
errhine's Avatar
errhine

 
 
Total Posts: 101
Re: Contracted Maintenance

Google is a dangerous way to get the FAA Orders. I recommend going to the Regulatory Guidance page and search current orders by Number.

http://www.airweb.faa.gov/Regulatory...meset?OpenPage

Word of caution, Order 8130.21G expires Jan 31, 2014 and Form 8130-3 will change as well.
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