Trace and certifications.
Both topics are confusing.
What do you need, with what type of material, and when?
Questions like these flood your brain. And you’re not alone. Many have the same misunderstandings of what is needed and when.
Whether you were born as a Quality Assurance inspector, trained, or were just thrown into purchasing to “figure it out.”
And it’s a huge concern for a few reasons.
One, the safety of your clients (i.e. passengers) is the most important thing. Without them, there’s no revenue. Without revenue, there’s no you. Two, you want to ensure you’re working with credible companies. Three, poor QA will result in longer material lead times and increase your processing cost and/or AOG occurrence. Four, it’s annoying, frustrating, and a waste of time to have to deal with bad paperwork.
And that’s how you can use this post. Share it with your team, discuss it, and create an internal system that works with your current QA standards (hopefully you have one).
Step 1: Define Regulated Source
A regulated source is a company who has oversight from an airworthiness body.
Skylink defines regulated sources as:
- Original Equipment Manufacturers (OEMs)
- All scheduled airlines and operators, including freight carriers (121, 129, 135, & foreign carrier).
- Major airframe and powerplant certified repair stations (FAA, JAA, EASA, TC or CAAC) whose capability allows them to perform C & D checks, repair or modify the aircraft structure or repair the major modules of an engine.
- Certified Component Repair Stations (FAA, JAA, EASA, TC or CAAC), provided the material they’re supplying is within the repair capabilities of their Air Agency Certificate.
Non-regulated sources are surplus parts suppliers, dealers, brokers, leasing companies, or repair stations who sell material outside of their repair capabilities.
Step 2: Determine Acceptable Trace & Certification For Aircraft Part Conditions
Factory New (FN) Part Manufactured By Regulated Sources
The original certification from the OEM. Appropriate documentation shall include one or a combination of the following: FAA Form 8130-3, EASA Form 1, JAA Form 1, SEG VOO 003, TC Form 1, Certificate of Conformance, Packing Slip, Transfer Ticket or Invoice.
- PC Holders: Invoice, packing list, or equivalent documentation (normal shipping documents), stating the part number(s) and corresponding quantities in each shipment.
- STC Holder: Normal shipping documents, documentation that identifies the part as an STC part and the production authority under which the part was produced.
- TSOA Holder: Normal shipping documents, documentation and/or markings that identify the part as a TSO part.
- PMA Holder: Normal shipping documentation and/or markings that identify the part as an FAA-PMA part. The part or packaging must be marked “FAA-PMA.”
- APIS Holder: Normal shipping documents, other documentation and/or data plates that identify the product as being produced under a TC only with an Approved Production Inspection System.
- Letter of Direct Ship Authority Authorization: Evidence that authority was given to the supplier from the PAH to ship parts directly to the customer, which may have a statement on the purchase order stating that the part/s “were produced under FAA approved manufacturing and quality control systems/methods as set forth in the FAA Production Certificate.”
New Parts From Non-FAA Certificated Sources
- A copy of shipping tickets, packing lists, invoices and/or other documents providing evidence that the origin of the part is from an FAA PAH or that the original acquisition was from an FAA-approved source.
- A copy of the written letter of direct shipment authorization that includes a statement that those parts were produced in accordance with the PAH quality system.
- A copy of the Certificate of Conformance (C of C) (i.e., standard parts). This certificate should identify the acceptable standard to which the part was produced.
- A copy of the return to service from FAA-approved foreign repair stations and/or FAA certificated sources.
- The return to service entry under part 43 maintenance record entry.
- A return to service record entry from an FAA-certificated air carrier operating under part 121 or 135.
New Surplus From Non-Regulated Source
You’ll want certification & traceability back to a regulated source stating that the material is new. Appropriate documentation may include one or a combination of the following: FAA Form 8130-3, EASA Form 1, JAA Form 1, SEG VOO 003, TC Form 1, Certificate of Conformance, Packing Slip, Transfer Ticket, and a material certification form that meets the requirements of ATA Spec 106 or other industry accepted certification.
Overhauled, Repaired, Inspected or Modified
- Certification & traceability back to the last operator and/or regulated source, including a non-incident/non-military statement.
- Original material certification form that meets the requirements of ATA Spec 106 or other industry accepted certification stating the part is in the same condition as listed on the Authorized Release Certificate
- The original FAA Form 8130-3, JAA Form 1, EASA Form 1, CAAC AAC-038, SEG VOO 003 or TC Form 1 (Dual FAA/EASA or JAA release) issued by a repair facility that is approved to perform the repair by the relevant airworthiness regulatory authority;
- Details of work performed or teardown report, including Service Bulletins (SB) number, Modification number or Airworthiness Directives (AD), with revision number and date;
- Name of the service manual and/or part number or ATA chapter reference used to perform the repair and the revision level and revision date of the manual; and,
Step 3: Communicate what you need with your trusted material suppliers
Once you’ve established what you can accept for various aircraft part conditions, notify your trusted material partners.
Hopefully, they were a part of the discussion before you made any changes.
Imagine if you made a change and didn’t tell them? They’d keep providing you with unacceptable paperwork.
Skylink has encountered this several times.
A shift was happening with EASA regulated operators. They were beginning to need OEM C of Cs for New Surplus (NS) material. We would ship our NS material with trace to a regulated source and find it being rejected months later. Why? Because it didn’t come with an OEM C of C.
Now, that would be a conversation to have with a trusted material partner, before the orders are placed.
Step 4: Be clear on you POs
Communication is important but with today’s technology, email, instant messaging, and social platforms, our communication often loses context.
Despite telling your supplier what trace and certification requirements you can accept, it’s best to put such requirements on your PO.
It’s redundant but it serves as a reminder. You can do the same with your RFQs. State what’s acceptable and what’s not.
You’ll save a lot of time and money by avoiding material being rejected once it get’s to you.
Be clear. Communicate well. Work closely with your trusted partner.
Step 5: Refine your systems
Things change. Changes develop. You find a better and faster way.
Update your systems. Don’t be stuck in a box.
Work with your trusted material partners to help you update your systems so you have external stakeholder buy-in. You need them and they need you. Be a partner. Communicate. And see the quality of your material increase and your rejection rate decrease.
But above all, always have fun while you’re doing it.
Never forget Your Wings.