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Control of Non-Certificated Maintenance Contractors - Page 2


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Some Related Topic Tags (Not all threads are Tagged)
contract services, faa (federal aviation administration), maintenance, faa part 145 (certified repair station), faa repair stations
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  Post Number #9  
Old 25th June 2009, 12:37 PM
Polly Pure Bread

 
 
Total Posts: 490
Re: Control of Non-certificated maintenance contractors

Quote:
In Reply to Parent Post by big rob View Post

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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  Post Number #10  
Old 25th June 2009, 01:16 PM
BadgerMan's Avatar
BadgerMan

 
 
Total Posts: 699
Re: Control of Non-certificated maintenance contractors

Quote:
In Reply to Parent Post by dQApprentice View Post

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:

Quote:
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.

Last edited by BadgerMan; 25th June 2009 at 01:23 PM.
Thanks to BadgerMan for your informative Post and/or Attachment!
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  Post Number #11  
Old 25th June 2009, 01:18 PM
Randy's Avatar
Randy

 
 
Total Posts: 8,545
Re: Control of Non-certificated maintenance contractors

Here you go...What do you think?

14CFR 145.201 Privileges and limitations of certificate.
(a) A certificated repair station may—

(1) Perform maintenance, preventive maintenance, or alterations in accordance with part 43 on any article for which it is rated and within the limitations in its operations specifications.

(2) Arrange for another person to perform the maintenance, preventive maintenance, or alterations of any article for which the certificated repair station is rated. If that person is not certificated under part 145, the certificated repair station must ensure that the noncertificated person follows a quality control system equivalent to the system followed by the certificated repair station.

(3) Approve for return to service any article for which it is rated after it has performed maintenance, preventive maintenance, or an alteration in accordance with part 43.

(b) A certificated repair station may not maintain or alter any article for which it is not rated, and may not maintain or alter any article for which it is rated if it requires special technical data, equipment, or facilities that are not available to it.

(c) A certificated repair station may not approve for return to service'

(1) Any article unless the maintenance, preventive maintenance, or alteration was performed in accordance with the applicable approved technical data or data acceptable to the FAA.

(2) Any article after a major repair or major alteration unless the major repair or major alteration was performed in accordance with applicable approved technical data; and

(3) Any experimental aircraft after a major repair or major alteration performed under §43.1(b) unless the major repair or major alteration was performed in accordance with methods and applicable technical data acceptable to the FAA.


Part 43 link below........

http://ecfr.gpoaccess.gov/cgi/t/text...1.3.21&idno=14
  Post Number #12  
Old 25th June 2009, 01:23 PM
BradM's Avatar
BradM

 
 
Total Posts: 5,931
Re: Contracted Maintenance

Quote:
In Reply to Parent Post by BadgerMan View Post

I changed it again to add further clarification.

The question deals with (sub) contracted maintenance not "maintenance"......…LOL!
Yea, I kinda got in a hurry on that one.

Quote:
In Reply to Parent Post by BadgerMan View Post

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?
And the different QMS perspective was what I was trying to get at. I do know that calibration documentation was "prioritized" differently, depending on where the equipment was being handled. I was hoping that Rob could feel comfortable with supervising it all, then handling each area different procedurally.

Thanks for the explanation, Badger.
  Post Number #13  
Old 25th June 2009, 01:24 PM
BradM's Avatar
BradM

 
 
Total Posts: 5,931
Re: Control of Non-certificated maintenance contractors

Quote:
In Reply to Parent Post by dQApprentice View Post

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.
As a general notion, I might tend to agree with you. But not in this one. They are... different. If you ever see them, you would know. That is in addition to the evidence provided by Badger and Randy.
  Post Number #14  
Old 25th June 2009, 05:22 PM
Sidney Vianna's Avatar
Sidney Vianna

 
 
Total Posts: 8,753
Re: Control of Non-certificated maintenance contractors

Quote:
In Reply to Parent Post by dQApprentice View Post

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.
I don't think you understood the situation. We are talking about repair stations certificated by a National Aviation Authority, such as the FAA.

The IAQG is now interested in promoting 9110 for the maintenance, repair & overhaul sector. I am a member of the IAQG MRO Relationship Growth Strategy Team. In the next couple of months, I will have another article published as a sequel to my previous one. The OP should consider flowing down AS9110 implementation/certification to the non-certificated maintenance contractor as a way to mitigate the risks of doing business with them.
  Post Number #15  
Old 3rd April 2010, 10:00 PM
sarah0305's Avatar
sarah0305

 
 
Total Posts: 16
Re: Control of Non-certificated maintenance contractors

Rob,
As you responded to Badger about your inspecting and testing of each components after repair/overhaul i have a question.

Why not simply perform the work inhouse since you already test the component when it returns from your maintenance shop.

This way you would cut out any question on your audit about using non-certificated repair station.

Since you are set up for inspection and testing it seems redundant to send out the work. I am sure you have your reason but to me i just cant see doing twice the inspection and testing on the same component.

Kindest regards.
Sarah
  Post Number #16  
Old 7th April 2010, 05:45 PM
kiwisfly

 
 
Total Posts: 173
Re: Control of Non-Certificated Maintenance Contractors

Hi bigRob
The key is the extent and control you exercise over the contractor. When the contractor is an approved Repair Station they can attach the 8130 and you fit the repaired part to the aircraft on that basis.

When they are not an approved repair station, you need to control the contractor under YOUR system. That means, you need to demonstrate how the contractor was controlled under your system through second party audits, product audits and incoming test and inspection. After all, it is your 8130 going on the component, you need to ensure that the work is as good as if you had done the work yourself.

All this is covered by AS9110 at 7.4.1. There are some differences between EASA and FAA requirements, for example, you can't use a subcomponent 8130 attached by an approved repaired station if the higher assembly is issued with an EASA form 1 and vice versa. But that's another story......

Cheers,
Thanks to kiwisfly for your informative Post and/or Attachment!
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