Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabrication

#1
Can a repair station approved for "repair" works go for AS9100 certification with scope for " manufacture/fabrication"?

The repair station gets work order from customer for "repair" and declares "repair" for return to service activity in FAA Form 8130-3 Airworthiness approval tag/Authorised release certificate.

Will it not violate Part-145.1 Applicability, if AS certificate is issued to same organization for manufacture/fabrication of parts?
 
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BadgerMan

#2
Re: Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabricati

Yes, but the scope should specify service, repair, overhaul, or whatever is pertinent.

We have a certificated repair station in the same facility as a PAH and they maintained a common AS9100 cert for several years. The scope read something like "designs, manufactures, and services".

However, last year the repair station "upgraded" to an AS9110 cert.
 

Sidney Vianna

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#3
Re: Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabricati

There are repair stations that manufacture replacement parts under their own PMA (Parts Manufacturer Approval). So, in principle, it is possible, but they should only be certified to AS9100 with the proposed scope of certification, IF they are indeed doing it. As I said in a previous post, some repair stations are going for AS9100 certification, rather than AS9110, simply because their CB is not accredited for AS9110.
 
#4
Re: Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabricati

Hi Sidney,

Your point is correct.So,if the repair station have parts manufacturer's approval,it can definitely go for a certification with scope stating " manufacturing/fabrication of--".

However can a CB grants certificate to a repair station (which is only approved for repair activity) with scope manufacture/fabrication.Will it not violate PART-145 approval?

Yes I agree, a repair station approved for certain scope under FAR-145 can go for AS9100 with same certification scope as it is for repair station approval.Reasons- as you have mentioned- many CBs don't have AS9110.
 
B

BadgerMan

#5
Re: Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabricati

So,if the repair station have parts manufacturer's approval,it can definitely go for a certification with scope stating " manufacturing/fabrication of--".
The repair station gets work order from customer for "repair" and declares "repair" for return to service activity in FAA Form 8130-3 Airworthiness approval tag/Authorised release certificate.
I'm confused. There appears to be a conflict here.

So if these are new articles manufactured under a PMA, how will the repair station satisfy a requirement for an FAA form 8130-3?
 
#6
Re: Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabricati

§ 145.5 Certificate and operations specifications requirements.


(a) No person may operate as a certificated repair station without, or in violation of, a repair station certificate, ratings, or operations specifications issued under this part.
 
K

kiwisfly

#7
Re: Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabricati

Not too sure what you're asking Joy but there does not have to be a direct relationship between what the 145 repair station scope is and what the 9100 scope is. I agree that perhaps there should be but officially, the two do not have to be the same.

The regulator is only interested in what the organisation repairs, not what it might make and sell to a customer because it will not go out under the MRO's release certificate. The CB might be interested in all the activities included in the scope of AQMS certification, but manufactured parts might go out under a CofC only, repaired items will be sent out on a 8130, Form 1 etc...

A company does not need a PAH (PMA) to make parts and sell them to a customer. The customer may have required them to have 9100 to be an approved supplier. This organisation may be a 145 repair station (maintenance organisation) but the fact their regulatory scope and AQMS scope are different is not an issue. The MRO scope will probably be part of the wider AQMS scope.

Personally, I would like to see IAQG make 9110 mandatory for MROs but reading the 9110B Application statement, to me it appears more likely that more MROs will do 9100, not less.

Cheers,:bigwave:
 
#8
Re: Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabricati

.

The regulator is only interested in what the organisation repairs, not what it might make and sell to a customer because it will not go out under the MRO's release certificate.



C:
Here, we have reached to an interesting point.So what happen if the repair station release the part under the MRO's release certificate and stating " repair" in FAA 8130-3? Though the part is fabricated and not repaired.

Also note that customers issues repair order and not for fabrication.As the AMM and SRMs describes the fabrication process,the repair station fabricates those as per those manual.

Original parts are very costly as those are sold by aircraft manufacturers and customer wants cheap replacement through this channel.
 
K

kiwisfly

#9
Re: Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabricati

Hi Joy
Regardless of who makes a part, a MRO can only fit an 'approved' part to the articles it repairs. The 8130/Form 1 signatory confirms that all the work was completed following the appropriate technical data, all the right equipment was used, and only approved parts were used.

A MRO is allowed to fabricate some new parts but these are normally only replacement parts (such as bushings etc..) that they get made and use themselves. [See EASA 145.A.42.(c)] The parts are only for the MRO's use, they are not allowed to sell them nor attach a release certificate to these manufactured parts, just use them to replace worn parts on the article they're repairing/maintaining. (note the use of the terms article and part - see 9110B definitions)

There's a name for some of those cheap replacement parts you refer to, they're called 'bogus' (see 9110B) or SUP. If anyone wants to make a part for sale (i.e. make it 'approved' in the eyes of the regulator), they can be an OEM, type certificate holder, production organisation or have a PMA.

You will note that the 9100 approval has not been mentioned here, that's because there is no relationship between what a 9100 approval might cover and what a MRO is allowed to do, in the eyes of the regulator. If a MRO thinks 9100 alone will allow them to make parts, attach a release certificate then sell them into the aerospace supply chain, or anyone is selling 9100 stating that this might be a prospect, then I hope you put them right on this point. Very scary if this is happening!!

Cheers,
 
#10
Re: Part-145 Repair Station AS9100 Certification with Scope for Manufacture/Fabricati

Thanks friend,you got my point.
 
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