Part 145 Repair Station Rating and Capability List vs. ISO 9001 certificate Scope

[Don Palmer]

Hi Cari,

Looks like you've received a lot of good input here.

For AS9100 our scope is going to be "OEM and aftermarket manufacture of ballscrews, ballnuts and assemblies."- or something to that effect - we are only making new screws, nuts and various components like flop over inserts and retaining tangs, etc. We don't supply assembled ballscrews to any of our current aerospace customers.

We are only going to be repairing ballscrews under our Repair Station certificate. So I think our rating should just say "Ballscrew Repair".

One question if I may ask it...Do you have SEPARATE facilities whereby you manufacture ballscrews exclusively in one facility, while repairing ballscrews in another?

 

[Cari Spears]

Hi Muleskinner -

Yes, I have received a lot of help here! In addition to the responses to my questions here at the cove, I have made friends with an FAA Inspector who has been most gracious in answering my endless emails!! It just occurred to me that I should probably have been sharing my questions and his responses with my friends here at the cove - I'll do that from now on.

In answer to your question (yes, you may certainly ask )- no. We have one building/facility. In addition to repairing or remanufacturing ballscrews (MRO), we are also an OEM supplier of various machine details that one might call "linear movement actuators" - ballscrew assemblies being one type - we also provide various machining, grinding and thread grinding that we like to call our "backdoor work".

 

[Don Palmer]

Ah, a gracious FAA Inspector...

I have made friends with an FAA Inspector who has been most gracious in answering my endless emails!! It just occurred to me that I should probably have been sharing my questions and his responses with my friends here at the cove - I'll do that from now on.

Yes, it's important to have a good rapport with your PMI, and anything you can share regarding your experiences is much appreciated.

 

[Blue Tuna]

AS9100 certs

About the first post here, there is a world of difference when you opt to list only as "repair of ball screws" vs. "manufacturing and repair", you will eliminate the enitre design section in 7.3. If at a later date you want to add the function of "manufacturing" in, this can be accomplished through one of the annual surveillance audits.

 

[Cari Spears]

For ISO our scope is "New and reconditioning of ballscrews, acme lead screws, spindles and related machine components."

For AS9100 our scope is going to be "OEM and aftermarket manufacture of ballscrews, ballnuts and assemblies."- or something to that effect - we are only making new screws, nuts and various components like flop over inserts and retaining tangs, etc.

We are only going to be repairing ballscrews under our Repair Station certificate. So I think our rating should just say "Ballscrew Repair".

Hi Blue Tuna - I'm not sure what you're saying in your post above. We manufacture new only for aerospace customers. We are getting our part 145 repair station certificate to cover repair and maintenance. We may at some point also apply for part 21 - but our customers are asking for AS9100.

 

[Don Palmer]

I'm not sure what you're saying in your post above. We manufacture new only for aerospace customers. We are getting our part 145 repair station certificate to cover repair and maintenance. We may at some point also apply for part 21 - but our customers are asking for AS9100.

As a manufacturer of NEW PARTS for aerospace customers, are you currently doing so as a subcontractor?

 

[Blue Tuna]

clarification

No doubt it is difficult to follow my rambling. AS9100 is a manufacturing standard, the AS9110 is a maintenance standard (which no one has the capability to certificate yet). However, many maintenance organizations (FAA Part 145 Repair Stations) opt for the AS9100 with the design function of 7.3 removed. If you are not going to manufacture under the AS9100 then your work in writing to the standard is much easier. For example the entire design section is moot as is First Article etc.....

With that said, if you are manufacturing parts for aerospace it may be to your advantage and include the manufacturing element.

If you opt for maintenance only, then there will probably be a time in the near future when you can "upgrade" to the AS9110 (when certification becomes available). The only problem here is the additional elements for 9110 over 9100.

 

[Cari Spears]

AS9100 is a manufacturing standard, the AS9110 is a maintenance standard (which no one has the capability to certificate yet).
With that said, if you are manufacturing parts for aerospace it may be to your advantage and include the manufacturing element.

If you opt for maintenance only, then there will probably be a time in the near future when you can "upgrade" to the AS9110 (when certification becomes available). The only problem here is the additional elements for 9110 over 9100.

WE MANUFACTURE NEW PRODUCTS FOR THE AEROSPACE INDUSTRY - SO WE ARE GOING TO BE AS9100 REGISTERED.

We also repair and manufacture new for at least a dozen different industries from machine tool to medical equipment to sporting goods.

We are also going to get Part 145 Repair Station certificated in order to repair and maintain ballscrews for commercial aircraft.

We are not opting for maintenance only; I'm not sure how you got that from what I'm saying.

 

[Cari Spears]

As a manufacturer of NEW PARTS for aerospace customers, are you currently doing so as a subcontractor?

Yes. Our customer has the contract for a landing gear assembly or a brake actuating system, for example, that has 2 or 3 ballscrews in it. We are subcontracted for the ballscrews.

It's the same tier(s) as our non-aerospace OEM work. One of the B3 contracts our customer to build a dozen of this machining center. Our customer subcontracts the ballscrews, spindles, etc. to us.

Sometimes we're tier 2, sometimes tier 3.

 

[Don Palmer]

FAR Part 21

WE MANUFACTURE NEW PRODUCTS FOR THE AEROSPACE INDUSTRY - SO WE ARE GOING TO BE AS9100 REGISTERED.

We also repair and manufacture new for at least a dozen different industries from machine tool to medical equipment to sporting goods.

We are also going to get Part 145 Repair Station certificated in order to repair and maintain ballscrews for commercial aircraft.

We are not opting for maintenance only; I'm not sure how you got that from what I'm saying.

Hi Cari,

Hope you are not getting frustrated with us. We are trying to understand your situation. I feel confident you are moving forward. Your posts do indicate that in a positive mode. We are here to learn from others as well as help when we can.

I am just so curious as to HOW your organization can, as you say, "MANUFACTURE NEW PRODUCTS FOR THE AEROSPACE INDUSTRY", without having Part 21 certification from the very beginning. Can you in fact manufacture aircraft parts as O.E.M., and sell these parts to your aerospace customers without FIRST having Part 21 certification. WHO determines Airworthiness?

Best regards!