AS9120B - Exclusions

[FliuGer]

Dear forum community, I would like to ask several questions regarding possible exclusion from AS9120B standard and N/A.

My company is Purchasing and Sales organization. We bought 'as it' (or 'repaired', 'surplus', 'new' etc.) aircraft parts and components, send them to contracted EASA Part-145 or Part-21J/G (if we need a mod) approved organization for repair/mod/recertification, and sell them in the market. All materials for repair purchased by EASA Part-145/21G organizations themselves, or we arrange direct purchasing from the manufacturer to them. We rent our office and we rent (contract) two different warehouse service (in the same city, but in a different location) for our parts/components (the warehouse companies has other customers as well and provides warehousing to us as a service). Several of our sales staff work as self-employes (provide service to us) using our office and several employed (including quality, logistic and HR staff). We use Quantum, Bitrix24 and MS excel software to manage our purchase orders, parts/components' lists etc. We plan to standardize our processes in accordance with EN9120:2018 (AS9120B) standard requirements.

So my question are:

1. Can my organization be considered as a Warehouse Management organization?
2. What type of structure are we iaw AS9120B if we rent warehouses as a service?
3. How many locations do we have iaw AS9120B if we rent warehouses as a service?
4. Should we include self-employed staff in "Total number of Employees"?
5. Can we exclude '7.1.5 Monitoring and measuring resources' if we don't have any measurement equipment and don't perform measurement?
6. Can we exclude '8.3 Design and Development of Products and Services' if all work performed by contracted EASA Part-21J/G/145 approved organisations?
7. Can we exclude '8.5.1 Control of Production and Service Provision' as we do not carry any production?
8. Can we exclude '8.5.3 Property Belonging to Customers or External Providers' as we don't hold any customer property? How to be with already bought items, when our contract EASA Part-21J/G/145 dispatch them? Is it customer property already? And how to be, if the customer paid for STC, our contracted Part-21J prepare it, send it to us and we send it to the customer? Is it customer property (data) already?
9. What else can be excluded iaw our profile?

Thanks in advance. AS9120B for me is a quite 'new' standard. My all experience is in Part-21J/G/145/66/M/CAMO/AirOps.

 

[Marc]

Hopefully someone will help, but be aware - Asking so many questions in the same post will offput some people.

 

[Big Jim]

Dear forum community, I would like to ask several questions regarding possible exclusion from AS9120B standard and N/A.

My company is Purchasing and Sales organization. We bought 'as it' (or 'repaired', 'surplus', 'new' etc.) aircraft parts and components, send them to contracted EASA Part-145 or Part-21J/G (if we need a mod) approved organization for repair/mod/recertification, and sell them in the market. All materials for repair purchased by EASA Part-145/21G organizations themselves, or we arrange direct purchasing from the manufacturer to them. We rent our office and we rent (contract) two different warehouse service (in the same city, but in a different location) for our parts/components (the warehouse companies has other customers as well and provides warehousing to us as a service). Several of our sales staff work as self-employes (provide service to us) using our office and several employed (including quality, logistic and HR staff). We use Quantum, Bitrix24 and MS excel software to manage our purchase orders, parts/components' lists etc. We plan to standardize our processes in accordance with EN9120:2018 (AS9120B) standard requirements.

So my question are:

1. Can my organization be considered as a Warehouse Management organization?
2. What type of structure are we iaw AS9120B if we rent warehouses as a service?
3. How many locations do we have iaw AS9120B if we rent warehouses as a service?
4. Should we include self-employed staff in "Total number of Employees"?
5. Can we exclude '7.1.5 Monitoring and measuring resources' if we don't have any measurement equipment and don't perform measurement?
6. Can we exclude '8.3 Design and Development of Products and Services' if all work performed by contracted EASA Part-21J/G/145 approved organisations?
7. Can we exclude '8.5.1 Control of Production and Service Provision' as we do not carry any production?
8. Can we exclude '8.5.3 Property Belonging to Customers or External Providers' as we don't hold any customer property? How to be with already bought items, when our contract EASA Part-21J/G/145 dispatch them? Is it customer property already? And how to be, if the customer paid for STC, our contracted Part-21J prepare it, send it to us and we send it to the customer? Is it customer property (data) already?
9. What else can be excluded iaw our profile?

Thanks in advance. AS9120B for me is a quite 'new' standard. My all experience is in Part-21J/G/145/66/M/CAMO/AirOps.

5. Yes, if there is no need for calibrated measuring tools.

6. Yes. Take a look at 8.3 in the standard itself including the other topics mentioned there. If you are a distributor only and do not want to apply design to any activities that are ISO 9001:2015 but not part of your AS9120B program.

8. Yes. Keep in mind that generally title to property transfers when received by the customer. You don't need to worry about applying 8.5.3 to orders that are being prepared for shipping or orders that have been shipped. It is still your property.

 

[FliuGer]

Big Jim, thanks for your answer.