Just like aircraft part trace, knowing what type of certifications you need is downright maddening.
Every operation is different, making QA standards difficult to apply to everyone, in every country, in every operation.
You spend hours sourcing and processing material orders to find out the certifications you received were wrong.
It’s frustrating. And a big contributor to your material processing costs.
To help combat this, let’s define what the various certifications are and some quick tips to use with your trusted material advisor.
What does it all mean? Airworthiness, C of C, & material certification defined
The term certification has a broad reach. On one hand, you’re talking about airworthiness, while on the other, you’re speaking in terms of quality and conformity.
Airworthiness is the “big brother.” He’s the one looking down, twisting your arm, saying try it. Install it without an airworthiness cert if you dare.
According to the FAA Part 21, an airworthiness certification is “…a document, issued by the FAA for an aircraft, aircraft engine, propeller, or article, which certifies that the aircraft, aircraft engine, propeller, or article conforms to its approved design and is in a condition for safe operation, unless otherwise specified.”
An airworthiness cert can come in many forms but the most common are FAA 8130 and an EASA Form 1. And yes, CAAC AAC-0038 has risen in popularity for Chinese operations, but, you get the point.
All overhauled, repaired, inspected or modified components must come with an airworthiness cert. But not all expendables are required to do so.
Certificate of Conformity / Compliance / Conformance
Let’s set the record straight. A Certificate of Conformance is not the same as a Material Cert.
Predominately OEMs provide C of Cs (so that will be in your trace packet) but suppliers, like Skylink, will provide a Material Cert.
Roy Resto has a great article about this in his post C of C’s, Beware of the Difference…
"When someone attests that an airplane, assembly, part, repair, or alteration conforms, they are generally stating that it conforms to one or a combination of the following:
- Approved Instructions
- Industry Standards or Approvals
- Aviation Regulations
- Company Standards
- Government Approvals
In the aircraft parts sales world, these are the characteristics of a Certificate of Conformity:
- They are issued by a manufacturer. (Note: some distributors, such as those with extensive fastener sales, are equipped to make determinations of conformity. But the vast amount of Certificates of Conformity are issued by the manufacturer.)
- They state that the part conforms to some of the subjects cited above
- They are signed
- The person signing is ‘authorized’ by the manufacturer to do so.
- They are indeed most valuable as the document to determine airworthiness.”
- Make sure you go back and read the rest of this post. It’s worth your time if this is a topic you struggle with.
A material certification states that a supplier, to the best of its knowledge certifies that the material being produced has not been submerged in water, been in a fire, been exposed to extreme conditions, and is not from a military source. There’s more to it, but it’s stating the material has not been compromised in any way to the best of the supplier's knowledge. Hence why trace is important.
As Roy Resto points out, “some suppliers such as Distributors, Brokers, or Stockists use the term Certificate of Conformity on their own documentation, but they have not, nor are equipped to make such determinations of Conformity.
In referring to their own documents, some distributors use the term C of C, when they should be using the term “Material Cert.” (Such as an ATA Spec 106 cert.).”
What do you need? Quick tips to avoid certification issues
Now that we’ve got the terminology straight, you still have to figure out what you actually need. I know, this sounds scary but it’s true.
We recently had a client who said they needed an 8130 for the expendable material we were providing for a C-check. The material came with an 8130 but it was a new unit with and OEM C of C and an airline serviceable 8130. Not an OEM 8130 but still an 8130. They rejected the material.
Both parties miscommunicated on what was actually needed. We’ll address this more in Step 2 below.
Step 1: Know your QA policies
Most organizations have policies around what they can and cannot accept. It’s important that you familiarize yourself with these policies. Read the boring manual. It’s worth the time.
And read the section “A Simple Guide to Ensure The Trace You’re Getting Is Sufficient” in this post
Step 2: Clearly articulate your needs to your trusted material partners
Knowing what you need is half the battle. Clearly communicating those needs is the other half.
Like the example above, if you state you need an 8130 then you may get various forms of an 8130.
Clearly specific, “We need an OEM 8130, we cannot accept foreign trace, any 8130 will suffice, etc.”
It’s also important your trusted material advisers communicate on their end. They should be asking clarifying questions to ensure you’re both aligned. We learned from the example above and now ask, “will any 8130 suffice (i.e. DAR or 145) or do you need a specific variant, like an OEM 8130?
Step 3: Your trusted material partner should be clear in what they’re providing you
To combat the various needs, Skylink sends out quarterly surveys both for new and existing clients and asks what is acceptable for their operation. We save this data in our ERP and client files so there’s no misinterpretation of what’s expected throughout our various teams.
It’s important that you and your material partners are closely aligned. If the information is unclear on their quotes or order confirmations, make sure they specify if it’s important to you. You want to catch any issues before the material arrives.
This goes with agreements as well. In our Vendor Managed Inventory program, we clearly state what material will be auto replenished, what trace and certifications will accompany the material, and where the trace files will be stored.
And that’s aircraft part certifications…defined.
Know what you need, communicate those needs, and avoid issues before they become an issue.
And remember, Never Forget Your Wings.