Control of Non-Certificated Maintenance Contractors

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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: :)(
 
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BadgerMan

Re: Contracted Maintenance

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?
 
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big rob

Re: Contracted Maintenance

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

Leader
Admin
Re: Contracted Maintenance

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.:bigwave:

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

Leader
Admin
Re: Contracted Maintenance

Sorry badgerman, I was putting together my post while you were helping out.:agree1:

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.
 
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BadgerMan

Re: Contracted Maintenance

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?
 
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BadgerMan

Re: Contracted Maintenance

Sorry badgerman, I was putting together my post while you were helping out.:agree1:

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?
 
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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. :thanks:
 
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Polly Pure Bread

We try to use certificated stations as much as possible but sometimes it just can't be done.

a non certified contractor has no difference from a certified one, except a piece of paper saying it is so, but the control over the contractor should always be in your hands.
 
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BadgerMan

a non certified contractor has no difference from a certified one, except a piece of paper saying it is so, but the control over the contractor should always be in your hands.

The term is certificated, not certified.

Here is the pertinent regulation:

Sec. 145.217

Contract maintenance.

[(a) A certificated repair station may contract a maintenance function pertaining to an article to an outside source provided--
(1) The FAA approves the maintenance function to be contracted to the outside source; and
(2) The repair station maintains and makes available to its certificate holding district office, in a format acceptable to the FAA, the following information:
(i) The maintenance functions contracted to each outside facility; and
(ii) The name of each outside facility to whom the repair station contracts maintenance functions and the type of certificate and ratings, if any, held by each facility.
(b) A certificated repair station may contract a maintenance function pertaining to an article to a noncertificated person provided--
(1) The noncertificated person follows a quality control system equivalent to the system followed by the certificated repair station;
(2) The certificated repair station remains directly in charge of the work performed by the noncertificated person; and
(3) The certificated repair station verifies, by test and/or inspection, that the work has been performed satisfactorily by the noncertificated person and that the article is airworthy before approving it for return to service.
(c) A certificated repair station may not provide only approval for return to service of a complete type-certificated product following contract maintenance, preventive maintenance, or alterations.
 
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