AS9100C 7.4.3 Delegation of Verification (to a supplier for a specific circumstance)

A

AirdrieQPA

#1
I work for a prime defence contractor (Canadian) and we are having an internal debate on whether or not we are delegating verfication to our supplier for a specific circumstance, repair activities of customer avionics.

There are several pieces of military avionics that we cannot repair or certify as serviceable in house. For these activities the parts are returned to the OEM or OEM approved repair facilities for repair. This is done via a PO by PO arrangment or a sub-contract, with the OEM and or OEM approved repair facility. These vendors (that's what we call them) are all on our approved vendors list, and are recognized by the Military as repair facilities and have had Government Quality Assurance determinations made.

What we get in return following the repair activity is the Avionic asset in a serviceable condition, a CofC stating conformance to the specification (which I would assume is the design specification for this part) and the repair report.

What our activity in house is follows, we review the test/repair report and the CofC and we fill out the customers technical records database as part of the Airworthiness functions we perform with respect to what was replaced or repaired, close out the PO's in our Accounting system and provide the parts to our Shipping department for return to the customer.

Our question(s) is this, does this activity describe delegation to the supplier or in this case the repair facility? What is it we are doing here in house during our review of the paperwork and technical records update? If so, how and if not, why? This has started a good healthy debate and we are looking for others opinions on the matter. Thanks in advance for your time and consideration to this question.
 
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#2
Re: AS9100C 7.4.3 Delegation of Verification

Our question(s) is this, does this activity describe delegation to the supplier or in this case the repair facility? What is it we are doing here in house during our review of the paperwork and technical records update? If so, how and if not, why? This has started a good healthy debate and we are looking for others opinions on the matter. Thanks in advance for your time and consideration to this question.
Hi David, I don't think what you described raises to a level of delegation of responsibility.

You have outsourced the repair work and you rely on paperwork provided by the supplier to confirm the airworthiness of the hardware. AS9110 Rev. B 7.4.3 clarifies that verification activities can include review of documentation from the supplier (what seems to be what you are doing).

Delegation of Product Release to suppliers has to be (typically) much more extensively controlled, including the designation of individuals who work for the supplier who would be authorized to accept the product on behalf of the customer.

Please note that the IAQG just approved a new project for the development of a (non-certifiable) Delegate Product Release Inspection (DPRI) Standard.
 

Big Jim

Trusted Information Resource
#3
Re: AS9100C 7.4.3 Delegation of Verification (to a supplier for a specific circumstan

I suspect that this scenario does fit into the part of AS9100C 7.4.3 that you are asking about.

"Where the organization delegates verification activities to the supplier, the requirements for delegations shall be defined and a register of delegations maintained."

It sounds like you are delegating verification activities in the purchase orders or other purchasing documents. What may be missing is the keeping of a register (list) of the delegations.

I'm curious about how others maintain that list. Is there an easy way for you to do so? I'm thinking you could add a column to your approved supplier list (register of approved suppliers) that shows that you require certification of conformance from those suppliers.

Other comments are welcome.
 

DannyK

Trusted Information Resource
#4
Re: AS9100C 7.4.3 Delegation of Verification (to a supplier for a specific circumstan

I work for a prime defence contractor (Canadian) and we are having an internal debate on whether or not we are delegating verfication to our supplier for a specific circumstance, repair activities of customer avionics.

There are several pieces of military avionics that we cannot repair or certify as serviceable in house. For these activities the parts are returned to the OEM or OEM approved repair facilities for repair. This is done via a PO by PO arrangment or a sub-contract, with the OEM and or OEM approved repair facility. These vendors (that's what we call them) are all on our approved vendors list, and are recognized by the Military as repair facilities and have had Government Quality Assurance determinations made.

What we get in return following the repair activity is the Avionic asset in a serviceable condition, a CofC stating conformance to the specification (which I would assume is the design specification for this part) and the repair report.

What our activity in house is follows, we review the test/repair report and the CofC and we fill out the customers technical records database as part of the Airworthiness functions we perform with respect to what was replaced or repaired, close out the PO's in our Accounting system and provide the parts to our Shipping department for return to the customer.

Our question(s) is this, does this activity describe delegation to the supplier or in this case the repair facility? What is it we are doing here in house during our review of the paperwork and technical records update? If so, how and if not, why? This has started a good healthy debate and we are looking for others opinions on the matter. Thanks in advance for your time and consideration to this question.
What you are describing is outsourcing the repair of avionics. The OEM or OEM approved repair facility is repairing and certifying the units based on your PO. The OEM would be responsible for ensuring that the OEM approved source is performing the repair to their specifications.
Delegation would be if you provided a stamp to your supplier and the repair would not pass through your own inspection system ( review of C of C) and go straight to production or assembly.
 
K

kiwisfly

#5
Re: AS9100C 7.4.3 Delegation of Verification (to a supplier for a specific circumstan

Hi AirdrieQPA,
What you describe here is very normal MRO activity. Your scope of repair does not include the Avionics equipment you send to the OEM for repair. Their scope of repair would include the equipment you require to be fixed for your customer. If this was for a commercial airline, the OEM would provide the Form 1 /8130 and you would pass that on with the equipment to the customer to allow them to fit the repaired equipment to their aircraft. Note that you should not replace the release documents with your own, unless you have fitted it to the a higher assembly that is within your scope of maintenance approval.

Because this is military, there is no Form 1 or 8130, the CofC replaces this and confirms that the equipment has been maintained in accordance with the approved technical data. You have not delegated anything to the vendor, you have actually outsourced the repair to an approved facility as your scope of approval did not extend to this equipment. You obviously have the joy of completing the customer's paperwork for them and update their database with your suppliers information regarding the repair, I trust you are reimbursed for this along with the repair which I guess you pay the vendor for.

What you are doing for the customer is managing the asset on their behalf, and updating the technical records with your vendor's information. The customer wants you to do this for them otherwise they would have to deal with a greater number of vendors. It is much easier for them to just deal with you and have you maintain the vendor support network. This is becoming more common with military logistics units as well as the big OEM's, selecting a few main suppliers and putting all of the work through them, saving them the overhead of maintaining a large vendor network.

I hope this helps,

Cheers,
 
A

AirdrieQPA

#6
Re: AS9100C 7.4.3 Delegation of Verification

Thank you for taking the time to reply, it is most appreciated.
 
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