Transcript 3A CASE TRAINING

7/18/2015
Compliance Requires Objective Evidence
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Welcome
C.A.S.E. Standard 3A
Quality Program Requirements
Distributors of New and Used Parts
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Course Outline
History of surplus parts
DOCUMENTARY - “the risk is onboard”,
the illegal trade in BOGUS AIRCRAFT
PARTS
C.A.S.E. Standard 3A
Review of AC 00-56
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Course Outline Cont’d
FAA unapproved parts video
Review
Test
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History of Surplus A/C Parts
After World War II
Military surplus
Start up of 707 & other commercial programs
Big business - much money
High demand = $$$
Illegal trade & bogus parts
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It’s Show Time
NORWEGIAN DOCUMENTARY
“The Risk is Onboard, the illegal trade in
BOGUS Aircraft Parts”
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After The Show
NORWEGIAN DOCUMENTARY
“The Risk is Onboard, the illegal trade in
BOGUS Aircraft Parts”
COMMENTS
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C.A.S.E. Standard 3A
Why the 3A Standard
Bogus / unapproved parts
Not to specs
Critical items with high $ value
A system to prevent fraud
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C.A.S.E. Standard 3A
Things to keep in mind
Auditing distributor
Review P. O. History
Review quality manual
Say what you do
Review quality system
Do what you say
Review self-audit system
Are they policing themselves
Part of management process
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C.A.S.E. Standard 3A
Thing to keep in mind (cont’d)
Training vs. Qualification
Purchases - Sales = Inventory
Accountability for stock
AIRLINES MUST COMPLY WITH FARs;
Therefore, suppliers must provide proper
documentation
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C.A.S.E. Standard 3A
Things to keep in mind (cont’d)
Traceability
Suppliers must have traceability not
only to the part source, but also to the
purchaser of the part
notify in case of an incident
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C.A.S.E. Standard 3A
Definitions (from AC 00-56)
Distributors - suppliers, brokers, dealers,
resellers, or other persons and agencies engaged
in the sale of parts for installation in typecertificated aircraft, aircraft engines, propellers
and in appliances
Distributor Accreditation - recognition of the
distributor’s quality system by an industry
group. (CASE, SAE, ANSI, ASA, DOT)
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C.A.S.E. Standard 3A
Definitions (cont’d)
Quality System - distributor’s total network of
administrative and detailed procedures, which
is implemented to ensure that the parts sold by
the distributor satisfy the customer’s
requirement and the documentation accurately
reflects the criteria identified in the purchase
order
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C.A.S.E. Standard 3A
Definitions (cont’d)
Quality System Standards - criteria developed
by various organizations that will provide
means to ensure that parts reflect the
appropriate quality
Self-Evaluation - a continuous program that the
distributor applies to evaluate its own
compliance with its quality system
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C.A.S.E. Standard 3A
Definitions (cont’d)
Traceability (chain of custody) - the ability via
documentation or electronic means to track
parts, processes, and materials by such means
as lot number, or serial number to the O.E.M.
or other acceptable source
Quality System Standards Organizations organizations that have developed quality
system standards to be utilized by others
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1) General
A. Describes minimum requirements for
quality programs
New aircraft parts / materials distributors
Surplus aircraft parts distributors
Designed to aid surveillance
Used to determine adequacy of
distributors’ quality program
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1) General (Cont’d)
B. Compliance with standard
Not an automatic entry into the C.A.S.E.
Register
C. Distributors subject to audit
any time during business hours
conducted by customer or another
CASE member
May be scheduled
May be unannounced
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1) General (Cont’d)
D. Acceptable Audit
Does not relieve distributors’ of responsibility
for
Maintaining consistently acceptable
quality system standards
FAA: any system that allows
exceptions is no system
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1) General (Cont’d)
E. Audit to C.A.S.E. Standard 3A
Not interchangeable or substitutable with
C.A.S.E. Standard 1A
Repair stations provide services
beyond scope of material control and
distribution
Exchange programs
Add parts of 3A std. and
Checklist to 1A to verify
traceability on parts associated
with exchange pool
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1) General (Cont’d)
F. Quality Parts and Materials
Necessary to Support Compliance to
Applicable FARs as defined in AC 20-62
21.303 (replacement and modification
parts)
121.215 (cabin interiors)
121.312 (materials for compartment
interiors)
121.363 (responsibility for airworthiness)
135.143 (general requirements)
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1) General (Cont’d)
F. Quality Parts and Materials
Suspected Unapproved Parts (SUPS)
segregated and secured
reported in accordance with AC 21-29
FAA Form 8120.11
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1) General (Cont’d)
F. Quality Parts and Materials
Related Reading Material
Advisory Circular AC00 - 56
Voluntary Distributor Accreditation
Advisory Circular AC20 - 36
index; articles certified under TSO
Advisory Circular AC20 - 62
Aeronautical Replacement Parts
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1) General (Cont’d)
F. Quality Parts and Materials Related
Reading Material (cont’d)
Advisory Circular AC21 - 2
Export Airworthiness Approval
Procedures
Advisory Circular AC21 - 20
Supplier Surveillance Procedures
Advisory Circular AC21 - 29
Reporting of Unapproved Parts
FAA Form 8120.11
(Malfunction and Defect Report)
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1) General (Cont’d)
F. Quality Parts and Materials
Related Reading Material (cont’d)
Advisory Circular AC21 - 38
disposition of unsalvageable aircraft
parts and materials
may send letter to owner and have him
sign it acknowledging the return of
scrap parts
may keep a file of scrap parts that are
returned, including serial numbers
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1) General (Cont’d)
F. Quality Parts and Materials
Related Reading Material (cont’d)
Advisory Circular AC21.303 - 2
announcement and availability:
PMA
Advisory Circular AC43 - 9
Maintenance Records
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1) General (Cont’d)
F. Quality Parts and Materials
Related Reading Material (cont’d)
Advisory Circular AC43 - 16
General Aviation Airworthiness
Alerts
FAA Order 8110.42
Parts Manufacturer Approval
Procedures
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1) General (Cont’d)
F. Quality Parts and Materials
Related Reading Material (cont’d)
FAA Order 8130.21C (or as revised)
procedures for completion and use of
FAA form 8130 - 3, airworthiness
approval tag
G. CACS - 30
Checklist Associated with 3A Standard
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2) Quality System and Quality
Manual
A. Distributor SHALL have established
Quality System
Assure Quality Product
that conforms to customer
specifications
Described in Detail (including procedures and
operations)
in Quality Manual or other appropriate
document
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2) Quality System and Quality
Manual Cont’d
A. Established Quality System (cont’d)
Minimum Elements Described in Manual
 1) Quality Organization
 2) Inspection Procedures
 3) Shipping Procedures
 4) Technical Data Control
 5) Record Keeping
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2) Quality System and Quality
Manual Cont’d
A. Established Quality System (cont’d)
Minimum Elements Described in Manual
 6) Training Requirements
 7) Shelf - Life Control
 8) Measuring and Test Equipment
Calibration (as applicable)
 9) Procurement
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2) Quality System and Quality
Manual Cont’d
A. Established Quality System (cont’d)
Minimum Elements Described in Manual
10)
11)
12)
13)
14)
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Material Control
Housing and Facilities
Internal Audit and Surveillance
Scrapped Parts Procedure
Certification Forms
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2) Quality System and Quality
Manual Cont’d
B. Quality Elements N/A to a Specific
Organization
Shall Be Included In The Distributor’s Quality
Manual
as “not applicable”
insures the quality element was not
overlooked
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3) Quality Organization
A. Organization Chart
Shall be depicted
showing relationship of quality
department to the rest of the
organization
validate, if possible the Quality
Department has real authority -- not
just satisfying the requirement
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3) Quality Organization Cont’d
B. Personnel (by title)
responsible for quality systems, including
inspection
tool and test equipment calibration
technical data control
shelf - life control
scrap
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3) Quality Organization Cont’d
C. Quality Manual (or Document)
Shall Be Kept Current
identifying standards to which it was
written
Shall Be Available
to employees
to customers’ auditor (or designee)
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3) Quality Organization Cont’d
D. Distributors Roster of Personnel
Shall Be Current
Individuals Authorized to Perform Specific
Inspection Functions
Inspections Each is Authorized to Perform
Training records must support this
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3) Quality Organization Cont’d
E. Distributors of New Aircraft Parts
Shall Maintain Current List of Manufacturers
that have officially authorized the
company as a distributor
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Questions
A. Is there an established Quality-Control
Program?
B. Does the quality manual describe the
Quality Department and its relationship to
the rest of the organization?
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Questions
C. Does a manual identify specific persons,
by title, responsible for various quality
functions and programs?
1) Quality Program
2) Inspection
3) Tool and Test Equipment Calibration
4)Technical Data Control
5)Shelf Life Program
6)Scrapped Parts
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Questions
D. Is the Quality Manual current and
available to all employees?
E. Is there a roster of:
(1) Persons that are authorized to perform
inspections ?
(2) A list of inspections they are authorized to
perform?
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Questions
F. Does the distributor maintain a current list
of manufacturers who officially authorize
them as a distributor?
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4) Inspection Procedures
(Responsibility by Title)
A. Inspectors
Verify Incoming Parts and Materials
free from defects
good state of preservation
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4) Inspection Procedures
(Cont’d)
B. New Parts Distributor
Maintain Inspection Program, including
periodic verification that standard parts
meet technical specifications applicable to
P/N
insure adequate specifications are available
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4) Inspection Procedures
(Cont’d)
B. New Parts Distributor (Cont’d)
to support inspection process
specifications are current
maintain records of inspections and tests
used to make verification
physical / chemical tests
check manufacturers’ test reports
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4) Inspection Procedures
(Cont’d)
C. Shall Have Receiving Inspection
Program
verify materials received
appropriate quality
lot / batch number
as indicated on accompanying
certifications and test reports
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4) Inspection Procedures
(Cont’d)
D. Receiving Inspection for Aircraft
Fasteners and Raw Stock
Visual Check
general workmanship
presence of certifications
presence of test reports
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4) Inspection Procedures
(Cont’d)
E. Inspection Stamps
Control System For Usage and Replacement
procedure must include...
1) facsimile of each stamp type
2) identify who stamps are issued to
3) policy for stamps that are lost or
stolen
4) requirement that no stamp be
reissued within a six month period
to two different employees
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Questions
A. Are all parts inspected for physical
damage and preservation?
B. Are standard parts verified as meeting
technical specifications?
C. Are there acceptable sampling procedures
used?
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Questions
D. Are fasteners and raw stock inspected
for condition, presence of certifications,
and test reports?
E. If inspection stamps are used, does the
policy require a stamp to be retired for
at least two years after an inspector
leaves?
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5) Shipping Procedures
A.
Shipping Requirements
ATA - 300 Specification Container
Equivalent
One Specified By Customer
packed in manner to preclude damage
by rough handling
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5) Shipping Procedures
(Cont’d)
B. Procedure in Place and Trained
Personnel
Visual Inspection of Items Shipped
1) obvious physical damage
2) ALL appropriate caps and plugs installed
WARNING...tape shall not be used to cover
electrical connections or fluid fittings /
openings. Adhesive residue can insulate
electrical connections and contaminate
hydraulic or fuel units
 ESDS caps
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5) Shipping Procedures
(Cont’d)
Visual Inspection of Items Shipped (cont’d)
 3) verifying part matches documentation and
the customer’s request / purchase order
quantity
part number
including dash numbers and letters
model number
serial number
etc.
batch number
lot number
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5) Shipping Procedures
(Cont’d)
Visual Inspection of Items Shipped
(cont'd)
4) verifying packing slip information
contains all information required by the
customer
5) shipping container and packing
appropriate for item being shipped
ATA 300 or equivalent...
...or as specified by customer
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5) Shipping Procedures
(Cont’d)
Visual Inspection of Items Shipped (cont’d)
6) verify required documentation
maintenance release (airworthiness approval)
“yellow tag”
FAA Form 8130-3
material certification
traceability (chain of custody)
etc. (export)
are at hand, properly completed
are signed
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5) Shipping Procedures
(Cont’d)
Visual Inspection of Items Shipped
(cont'd)
7) verify materials classified as
HAZMAT
inspected by trained and qualified
personnel
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Questions
A. Are all parts shipped in ATA 300
containers or equivalent?
B. Do appropriately trained personnel
conduct an inspection of items being
shipped, including but not limited to:
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Questions
1) Obvious physical damage?
2) Installation of plugs and caps?
3) Verification of quantity, part number, serial
number, model number, etc.?
4) Packing slip information as required by
customer?
5) Verification of airworthiness approval, material
certification, traceability documents, etc.?
6) HAZMAT materials properly inspected?
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6) Technical Data Control
(Responsibility by Title)
A. Technical Data Shall be Maintained
Applicable To Products On Hand
Current And Accessible
Stored In Manner To Protect It From Dirt
and Damage
No Hand Entries
No Hand Corrections
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6) Technical Data Control (Cont’d)
B. Airworthiness Directives
Verify Status On Date Of Sale
C. Microfilm, Microfiche, CD
Must Have Appropriate Viewing Device
maintained in good working order
protected from damage
available to personnel
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Questions
A. Is there a documented system for
obtaining technical data and maintaining it
up to date?
NOTE: Technical data includes any documents
used to determine that the part complies with
OEM requirements. Examples are, but are not
limited to drawings, manuals, parts catalogs,
and cross reference manuals.
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Questions
B. Is the appropriate, current technical data
readily available to personnel that need it?
C. Is AD status verification provided on date
of sale?
D. Is there a system to prohibit hand entries or
corrections to technical data?
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Questions
E. Is technical data stored in a manner that
will protect it from dirt and damage?
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7) Record Keeping
A. New Parts Distributor
System In Place Governing
storage
distribution
retrieval
of documents verifying
fasteners & raw stock phys / chem
properties conform to technical
specifications
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7) Record Keeping (Cont’d)
B. Records Confirming Aircraft Fastener
Integrity
Including Physical / Chemical Test Reports
retained for minimum of two years after date of
sale
C. Records Verifying Conformance to
Flammability Requirements
Retained For Minimum Of Seven Years After Date Of
Sale
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7) Record Keeping (Cont’d)
D. Traceability and Certification
Documents
Maintained From Date Of Sale
two years
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7) Record Keeping (Cont’d)
E. Distributor must have documented
traceability system-chain of custody
To Trace Parts To
source of production
FAA certificate holder
to end user (customer)
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7) Record Keeping (Cont’d)
Traceability System (cont’d)
Samples Of Traceability Documentation
Statement of Conformance
Material Certification
Return to Service Tags
Must be accompanied by the records of
last maintenance action-tear down report
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7) Record Keeping (Cont’d)
E. Traceability System (cont’d)
Approval Status Of Each Part I/A/W
FAR 21.303 (replacement & modification
parts)
(a) Except as provided in paragraph (b)
of this section, no person may produce a
modification or replacement part for sale
for installation on a type certificated
product unless it is produced pursuant to
a Parts Manufacturing Approval issued
under this subpart.
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7) Record Keeping (Cont’d)
E. Traceability System (cont’d)
Approval Status (cont’d)
FAR 21.303 (cont'd)
marking PMA parts I/A/W FAR 45.15
1) the letters “FAA - PMA”
2) name, trademark, symbol of PMA
holder
3) part number
4) eligibility listing (name and model
of each type certificated product)
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7) Record Keeping (Cont’d)
E. Traceability System (cont’d)
Approval Status (cont’d)
FAR 21.303 (cont'd)
exceptions to PMA
1) parts produced under PC or TC
2) owner / operator produced parts (for
maintaining or altering own product)
Note: not acceptable for distribution (SALE)
3) parts produced under TSO
4) standard parts conforming to established
U.S. or industrial standards (nuts & bolts)
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7) Record Keeping (Cont’d)
F. Life - Limited Parts
Records Confirming Life - Limited Status
records from previous operators as
applicable
G. Storage of Records
Protected Against
damage
alteration
deterioration
loss
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7) Record Keeping (Cont’d)
H. Serviceable Parts
Supplier Must Provide Airworthiness Approval
Document
from FAA certificated source
FAR 121 (air carriers & commercial
operators)
FAR 145 (repair stations)
* not applicable to new parts unless
work or test was performed
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7) Record Keeping (Cont’d)
H. Serviceable
Parts (cont’d)
Document Must Contain
certificate number
maintenance release for RTS
FAA Order 8130.21C (or as revised)
FAR 43 Appendix B
AC 145.3 Appendix 1
examples of airworthiness release
statements for air carrier work
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7) Record Keeping (Cont’d)
H. Serviceable Parts (cont’d)
Document Must Contain
(cont’d)
must be signed
inspection stamps, symbols, printed
names, and stamped names
NOT ACCEPTABLE
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7) Record Keeping (Cont’d)
H.
Serviceable Parts (cont’d)
Document (Airworthiness Approval /
Maintenance Release) Shall Be Physically
Attached To Unit
any format (usually tag or 8130-3)
as long as required information is
present, including part number &
serial number
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7) Record Keeping (Cont’d)
I. Distributor Shall Provide...
Copy Of Teardown Report
must contain
 condition at overhaul
list of significant parts replaced
tech data used (service bulletins, ADs)
functional test
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7) Record Keeping (Cont’d)
J. Incident Related Parts
Must Be Identified
from aircraft or engine subjected to extreme
stress or heat
major engine failure/sudden stoppage
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7) Record Keeping (Cont’d)
J.
Incident Related Parts (Cont’d)
accident
fire
submersion in saltwater
or parts themselves subjected to
extreme stress or heat, i.e. warehouse
fire….
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Questions
A. Does distributor request adequate test and
inspection records with each order of
parts?
B. Are records confirming fastener integrity
maintained for 2 years? (i.e.; chemical and
physical properties.)
C. Are certifications and test reports being
received and filed as required?
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Questions
D. Can each part or carton or package of
parts be linked to its certification and/or test
records by some unique identifier?
E. Does the vendor's purchase records/sales
orders chain of custody lead to a production
approval holder (PMA, TSO, PC, TC, STC
Holder) or manufacturer of standard parts ?
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Questions
F. Is serial number traceability maintained
when applicable?
G. Are export Certificates of Airworthiness
obtained for all foreign manufactured parts?
(Ref. FAR 21.502)
H. Are records protected against damage,
alteration, deterioration and loss?
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8) Training
A. Properly Trained and Competent
Personnel
Functions
inspection
parts handling
record keeping
documentation
traceability requirements
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8) Training (Cont’d)
A. Properly Trained and Competent
Personnel (cont’d)
Personnel Requiring Training
supervisors
inspectors
receiving personnel
shipping personnel
sales people
7/18/2015
Compliance Requires Objective Evidence
83
8) Training (Cont’d)
B. Inspection Personnel
Properly Trained and Authorized
in inspection techniques
in methods and equipment used to
determine part quality
this authorization criteria shall be identified
in quality manual
7/18/2015
Compliance Requires Objective Evidence
84
8) Training (Cont’d)
C. Shipping Personnel
 Trained and Competent In HAZMAT
recognition
packaging
identification
proper handling
7/18/2015
Compliance Requires Objective Evidence
85
8) Training (Cont’d)
D. Personnel Training
Shall Be Documented
 formal training (classroom)
on - the - job (OJT)
Must Be Retained
minimum of two years
after employee leaves company
7/18/2015
Compliance Requires Objective Evidence
86
8) Training (Cont’d)
E. Training Records
Shall Include
description of the training
date and number of hours of instruction
name of instructor and student and / or
signature of instructor and student
name of organization conducting the
training (if outside agency)
7/18/2015
Compliance Requires Objective Evidence
87
Questions
A. Are personal who perform inspection,
shipping and receiving functions properly
trained?
B. Are inspection personnel properly
authorized?
7/18/2015
Compliance Requires Objective Evidence
88
Questions
C. Are both formal classroom and on-the-job
training documented and maintained?
D. Is a roster of personnel authorized to
perform specific functions maintained?
7/18/2015
Compliance Requires Objective Evidence
89
9) Shelf Life Control
(Responsibility By Title)
A. Distributor Shall Document and
Maintain Program
Program Must Assure
identification of shelf-life items
proper handling of shelf-life items
no expired parts / materials will be
issued
7/18/2015
Compliance Requires Objective Evidence
90
9) Shelf Life Control Cont’d
B. Program Shall Include
Component Assemblies Containing Shelf-Life
Limited Items
7/18/2015
Compliance Requires Objective Evidence
91
Questions
A. Is there a documented shelf life
program?
B. Is there a list of shelf life limited
materials / parts and their limits?
7/18/2015
Compliance Requires Objective Evidence
92
10) Measuring and Test Equipment
(Responsibility by Title)
A. Equipment Used to Verify
Conformance
Shall Be Periodically Calibrated
N.I.S.T. (National Institute of Standards
and Technology)
other appropriate government standards
check bi-lateral agreements
must be traceable to standard used in
calibration
7/18/2015
Compliance Requires Objective Evidence
93
10) Measuring and Test Equipment
(Cont’d)
B. Past Due Tools /Equipment
Shall Have Procedure In Place To Prevent Use
C. Shall Maintain Documentation
Current Calibration Status
7/18/2015
Compliance Requires Objective Evidence
94
Questions
A. Does the supplier have the tools
required to assure conformity of the
inventory to specification?
B. Is there a documented program to
maintain serviceability and calibration
of those tools?
7/18/2015
Compliance Requires Objective Evidence
95
Questions
C. Are historical records containing repair
and calibration accuracy data for that
tooling maintained?
D. If personally owned measuring tools are
allowed on the premises are they
controlled by the program?
7/18/2015
Compliance Requires Objective Evidence
96
Questions
E. If in-house Calibration is performed are
the standards used traceable to N.I.S.T.?
F. Is there current certification for each inhouse standard use?
G. Are the precision tools stored in a
manner that will prevent damage and/or
adverse affects on the calibration of the
tool?
7/18/2015
Compliance Requires Objective Evidence
97
11) Procurement
A. Maintain System Such That...
Only Approved Quality Materials Purchased
Proprietary & Licensing Rights Observed
B. System Shall Assure...
Special Requirements Are Adequately
Communicated To Sources
test reports
physical / chemical analysis
7/18/2015
Compliance Requires Objective Evidence
98
11) Procurement (Cont’d)
C. Distributors of New Aircraft Parts
Purchase Materials Directly From Approved
Manufacturers...or
Purchase Materials From Distributors
Authorized By Manufacturer To Sell Product
deviations from this
must be disclosed to customer
must be approved by customer prior to
shipment
7/18/2015
Compliance Requires Objective Evidence
99
11) Procurement (Cont’d)
D. Distributors Shall ...
Maintain List Of Approved Suppliers
Maintain Quality History For Each Source
7/18/2015
Compliance Requires Objective Evidence
100
Questions
A. Does the system demonstrate the ability
to:
(1) Trace parts to the source of procurement
and to the source production or to an FAA
certificate holder and to end user.
 (2) Provide, upon request, information
pertaining to the production approval status of
each part in accordance with the applicable
FAR'S?
7/18/2015
Compliance Requires Objective Evidence
101
Questions
B. Does the system assure that special
requirements are adequately
communicated to the supplier's sources?
C. Does the surplus suppliers system
assure that:
(1) parts subjected to extreme heat or stress
are identified as such?
7/18/2015
Compliance Requires Objective Evidence
102
Questions
(2) all parts procured have traceability and/or
airworthiness certification as required by the
FAR'S?
(3) all Airworthiness Directives (A.D.s) which
have been accomplished are documented
appropriately?
(4) part numbers conform to the customers
purchase request?
7/18/2015
Compliance Requires Objective Evidence
103
Questions
(5) items identified as "overhauled" were in
fact overhauled and have appropriate
documentation to substantiate the condition of
the part?
7/18/2015
Compliance Requires Objective Evidence
104
12) Material Control
A. Handling of Material
Appropriate Manner
Protected From Damage & Deterioration
7/18/2015
Compliance Requires Objective Evidence
105
12) Material Control (Cont’d)
B. Packaging and Storage
Special Packaging Maintained As Necessary
electrostatic discharge sensitive (ESDS)
temperature / humidity control
magnetic control (radome)
Storage Area Periodically Checked
for overall effectiveness
storage
identification methods
7/18/2015
Compliance Requires Objective Evidence
106
12) Material Control (Cont’d)
C. Close Loop Corrective Action System
Implemented When Detecting...
substandard / non-conforming parts
these rejected parts
Identified, segregated, and secured
from useable stock
7/18/2015
Compliance Requires Objective Evidence
107
12) Material Control (Cont’d)
C. Close Loop Corrective Action System
(cont’d)
System Shall Include
notification of each purchaser within
24 hours of detection
method to recall or rectify problem
unapproved parts reported I/A/W AC
21-29
7/18/2015
Compliance Requires Objective Evidence
108
12) Material Control (Cont’d)
D. Segregation of........
Aircraft Parts
Non-Aircraft Parts
7/18/2015
Compliance Requires Objective Evidence
109
12) Material Control (Cont’d)
E. Distributors of Aircraft Fasteners
Shall
Maintain Batch / Lot Segregation
Maintain Batch / Lot Records
quantities sold from Each Batch/Lot
quantities sold to Each Customer
Note: Purchases less sales should equal
inventory
this must balance on batch / lot
numbered inventories
7/18/2015
Compliance Requires Objective Evidence
110
12) Material Control (Cont’d)
F. Distributors of Materials Requiring
Flammability Testing
Maintain Batch / Lot Segregation
Maintain Batch / Lot Records (flame certs)
and for other items for which this is
appropriate
7/18/2015
Compliance Requires Objective Evidence
111
12) Material Control (Cont’d)
G. Sorting and Delivery
In O.E.M. Packaging (when practical)
Packaging Shall Identify
manufacturer
distributor
part number
batch / lot (if applicable)
quantity
7/18/2015
Compliance Requires Objective Evidence
112
12) Material Control (Cont’d)
H. Flammable, Toxic, or Volatile Materials
Stored In Safe Manner
manufacturers’ recommendations
specified by local fire regulations
distributor shall identify and maintain
copy of applicable fire code
7/18/2015
Compliance Requires Objective Evidence
113
12) Material Control (Cont’d)
I. Electro - Static Discharge Sensitive
Materials (ESDS)
Use Necessary Precaution In Accordance With
Governing Requirements
packaging
handling
protection
7/18/2015
Compliance Requires Objective Evidence
114
12) Material Control (Cont’d)
J. Part Number Ambiquity
Assure None Exists
parts shall not be labeled with multiple part
numbers
if labeling may cause confusion
to part manufacturer
applicable specification
Note: mod level of unit may indicate A/C
applicability
7/18/2015
Compliance Requires Objective Evidence
115
12) Material Control (Cont’d)
K. Alteration or Replacement
Data Plate
Manufacturers’ Part Number
unacceptable
7/18/2015
Compliance Requires Objective Evidence
116
12) Material Control (Cont’d)
L. System To Segregate & Identify
Serviceable from Unserviceable Units
in a manner that will preclude issuing
an unserviceable part
7/18/2015
Compliance Requires Objective Evidence
117
Questions
A. Is material handled in such a fashion as
to preclude damage and deterioration?
B. Are storage areas periodically checked
for overall effectiveness?
C. Is batch segregation utilized for aircraft
fasteners and other material requiring
batch control?
7/18/2015
Compliance Requires Objective Evidence
118
Questions
D. Is the original packaging used as
practical?
E. Does packaging clearly identify
contents?
F. Does packaging conform to ATA
specification 300 when appropriate?
7/18/2015
Compliance Requires Objective Evidence
119
Questions
G. Is material susceptible to electrostatic
discharge damage handled in accordance
with proper requirements?
H. Are parts/components adequately
protected against the environment and
damage (including caps and plugs)?
I. Is a system in place to preclude part
number ambiguity?
7/18/2015
Compliance Requires Objective Evidence
120
Questions
J. Does the quality program provide a
closed-loop system for implementing
corrective action following the
identification of non-conforming parts
or material?
K. Is the non-conforming part/material
segregated from usable stock?
7/18/2015
Compliance Requires Objective Evidence
121
Questions
L. Is there a documented procedure in
place
for mutilating scrapped parts
which will
preclude their being returned
to service?
M. Are records maintained on all serialized
scrapped parts?
7/18/2015
Compliance Requires Objective Evidence
122
Questions
N. Is this requirement imposed on the
subcontractors and/or suppliers?
0. Is there a balance procedure for
quantities purchased less sales equals
inventory?
7/18/2015
Compliance Requires Objective Evidence
123
13) Housing And Facilities
A. Appropiate and Maintained
 Insure Storage Does Not Damage Inventory
B. Distributor Engaging in A/C or A/C
Component Maintenance
Storage Area Must Be Secured
prevent cannibalizing by maintenance
personnel
7/18/2015
Compliance Requires Objective Evidence
124
Questions
A. Is ventilation, lighting, temperature, and
humidity control adequate?
B. Are good housekeeping practices being
maintained?
7/18/2015
Compliance Requires Objective Evidence
125
14) Internal Audit And
Surveillance
A. Distributors Audit and Surveillance
Function
Periodically Self-audits Programs
verify procedures are in place to assure
compliance
with CASE 3A Standard
customer specifications
regulatory requirements
good industry practices
7/18/2015
Compliance Requires Objective Evidence
126
14) Internal Audit And
Surveillance
A. Distributors Audit and Surveillance
Function (cont’d)
Verify Operations Are Being Conducted In
Accordance With These Programs
7/18/2015
Compliance Requires Objective Evidence
127
14) Internal Audit And
Surveillance
B. Self Audits
Performed In Accordance With
Checklists Or Other Written Procedures
to determine the effectiveness of Quality
Program
Results Shall Be Documented
for Non-Compliance and Corrective Action
7/18/2015
Compliance Requires Objective Evidence
128
14) Internal Audit And
Surveillance
F. Self Audits (cont’d)
Corrective Action Shall:
be appropriate and prompt
correct reported discrepancies
locate and correct similar discrepancies
in areas not audited
correct the ROOT cause
implement follow-up
to eliminate recurrence
7/18/2015
Compliance Requires Objective Evidence
129
Questions
A. Is there a self audit program in place?
B. Are self audits documented including
non-compliance corrective actions?
7/18/2015
Compliance Requires Objective Evidence
130
15) Scrapped Parts Procedure
(Responsibility by Title)
A. Documented Procedures
Mutilation
drilling
grinding
cutting
other appropriate means
Extent Of Mutilation
preclude restoration and return to service
7/18/2015
Compliance Requires Objective Evidence
131
15) Scrapped Parts Procedure
(Cont’d)
B. Life - Limited Scrap Parts
Maintain Record
description of part
part number
serial number (if applicable)
date part was scrapped
retain record for at least two years
7/18/2015
Compliance Requires Objective Evidence
132
15) Scrapped Parts Procedure
(Cont’d)
C. Verification of Mutilation
Individual Responsible
must be identified in procedure by
position or title
D. Subcontractors/Repair Facilities of
Distributors
Imposed With Same Scrap Requirements
7/18/2015
Compliance Requires Objective Evidence
133
Questions
A. Does the supplier have a documented
procedure for the handling of scrapped
parts?
B. Does the supplier identify by title or
position the individual responsible for
verifying compliance with the
procedure?
7/18/2015
Compliance Requires Objective Evidence
134
Questions
C. Does the supplier impose the procedure
on subcontractors and repair facilities
with whom they do business?
7/18/2015
Compliance Requires Objective Evidence
135
16) Certification Forms
A. Quality Manual Requirement
Forms Used By Distributor
to certify parts
show traceability of parts
Shall contain samples
Shall contain instructions
B. Instructions
May Be Contained On The Forms
7/18/2015
Compliance Requires Objective Evidence
136
Review Of AC 00-56
History
Much Discussion On Having FAA Regulate
Surplus Dealers
aviation industry put a lot of pressure
on FAA
FAA Indicated That They Didn’t Have The
Manpower and Resources To Regulate
Established Guidance...AC 00-56
7/18/2015
Compliance Requires Objective Evidence
137
Review Of AC 00-56 (Cont’d)
History (cont’d)
AC 00-56 Lists Requirements
Distributor Found Lacking After Accreditation
many findings
accredited against ISO Std. & placed in
Airline Suppliers Association (ASA)
Register
manual did not address guidance offered in
AC
7/18/2015
Compliance Requires Objective Evidence
138
Review Of AC 00-56(Cont’d)
History (cont’d)
Brought To The Attention Of The FAA
At CASE Conference
CASE Updating 3A Standard
will be adopted by ASA as their own
7/18/2015
Compliance Requires Objective Evidence
139
Review Of AC 00-56 (Cont’d)
Literature Referenced in AC
AC 20-62 aeronautical replacement parts
AC 21-20 supplier surveillance
AC 21-29 suspected unapproved parts
AC 21-38 disposition of unsalvageable parts
and materials
Ac 21.303-2 announcement and availability:
PMA
7/18/2015
Compliance Requires Objective Evidence
140
Review Of AC 00-56 (Cont’d)
Literature (cont’d)
AC 43-9 Maintenance Records
Order 8110.42 PMA Approval Procedures
Order 8130.21C Completing 8130-3 Tag
AC 20-36 Index; Articles Under TSO
AC 21-2 Export Airworthiness Approvals
AC 43-16 General Aviation Airworthiness
Alerts
7/18/2015
Compliance Requires Objective Evidence
141
Review Of AC 00-56 (Cont’d)
AC 00-56 States:
“The purchasing organization who uses
accredited distributors and receives
noncompliant parts, and who voluntarily
reports such occurrences to the FAA, will have
such information considered as mitigating
circumstance per current FAA enforcement
policy. ...will allow the FAA to concentrate its
surveillance resources on parts purchased from
sources that may not be as reliable.”
7/18/2015
Compliance Requires Objective Evidence
142
Review Of AC 00-56 (Cont’d)
Quality Systems Minimums
Receiving Inspection
approved parts
PAH, TC, TSO, PMA
...from approved sources
121, 145, etc.
NOTE: Parts are not legal unless they are
manufactured under FAA approval.
7/18/2015
Compliance Requires Objective Evidence
143
Review Of AC 00-56 (Cont’d)
Quality Systems Minimums (cont’d)
Trained Personnel
in quality system
regulations
able to recognize approved parts
Measuring Equipment Calibration
Control Of Incoming Discrepant Material
Self Audit Program
7/18/2015
Compliance Requires Objective Evidence
144
Review Of AC 00-56 (Cont’d)
Quality Systems Minimums (cont’d)
PAH’s IPC
Inspection Stamp Control
Packaging Control
Recall System
within 24 hours
trace both ways
source
end user
provide method to correct problem
7/18/2015
Compliance Requires Objective Evidence
145
Review Of AC 00-56 (Cont’d)
Quality Systems Minimums (cont’d)
Quality Organization That Knows Regulations And
Requirements
Environmental Control
Procedure For Redistribution Of Lots
must keep original certification on file
procedure for accountability
System To Prevent Fraud
Parts Traceability
7/18/2015
Compliance Requires Objective Evidence
146
Review Of AC 00-56 (Cont’d)
Quality Systems Minimums (cont’d)
Notify Accreditation Organization
any changes in quality system must
be accepted before implementation
Provide Certifications
Customers Who Receive Discrepant Parts
must notify distributor
must notify local FAA (FSDO, CMO)
7/18/2015
Compliance Requires Objective Evidence
147
Review Of AC 00-56 (Cont’d)
Reaccreditation Every Two Years
Name Of Accreditation Organization
Date Of Accreditation
Date When Annual Check Is Due
to monitor the effectiveness of programs
Verify Required Documentation
“The following signature attests that the
documentation specified above and attached
is accurate with regard to the item(s)
described.”
7/18/2015
Compliance Requires Objective Evidence
148
Review Of AC 00-56 (Cont’d)
Final Thought
The FAA has recently sent a letter to CASE
stating that they will make the same allowance
(mitigating circumstances) if an airline has to
make a self-disclosure relative to a distributor
they use by virtue of being listed in the CASE
register.
7/18/2015
Compliance Requires Objective Evidence
149
It’s Show Time!
FAA Produced Video
Unapproved Parts...What You Can Do To
Prevent Their Use
7/18/2015
Compliance Requires Objective Evidence
150
Let’s Review The Video
Know Your Suppliers
Buyers 1st Line Of Defense
Unapproved Parts
PC - Supplier - Airline Relationship
Exceptions to PMA
PMA Marking
7/18/2015
Compliance Requires Objective Evidence
151
Case Standard 3A Course
Review








General
Quality System and Quality Manual
Quality Organization
Inspection Procedures
Shipping Procedures
Technical Data Control
Record Keeping
Training
7/18/2015
Compliance Requires Objective Evidence
152
Case Standard 3A Course
Review








Shelf Life Control
Measuring and Test Equipment
Procurement
Material Control
Housing and Facilities
Internal Audit and Surveillance
Scrapped Parts Procedure
Certification Forms
7/18/2015
Compliance Requires Objective Evidence
153
Test Time!
Let’s See What You’ve Learned
Minimum Passing Grade...70%
After The Test (If you are interested)
Bonus Video
Electro-Static Discharge
(ESDS)
Run Time...18:44
7/18/2015
Compliance Requires Objective Evidence
154