AS9110 Alignment to FARs and OEM Requirements

Report
Registration Management Committee
AS9110 Alignment to Federal Aviation Regulations (FARs) and Original
Equipment Manufacturers(OEMs) Requirements
July16-17, 2014
Larry Henderson
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Company Confidential
Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• AGENDA
– AS9110 Revision B Application
– AS9110 Clauses vs FARs and OEM Requirements
– Auditing Approach
– Questions and Answers
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• AS9110 Revision B
– Implementation effective 1 January 2014
– Process based auditing approach.
– It is emphasized that the requirements specified in 9110 are complementary (not
alternative) to contractual and applicable statutory and regulatory requirements.
Should there be a conflict between the requirements of the standard and
applicable statutory or regulatory requirements, the latter shall take precedence.
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• AS9110 Standard Application
– Developed to benefit maintenance organizations that choose to adopt it, whether
or not holders of a National Aviation Authority (NAA) repair station certificate.
– Standard applies to organizations whose primary business is providing
maintenance services and for Original Equipment Manufacturers (OEMs) with
maintenance operations.
NOTE: An organization may be registered the 9110 standard and not hold an NAA
certificate.
– Maintenance Definition: Performance of tasks required to ensure the continuing
airworthiness of an article, including any one or combination of overhaul,
inspection, testing, replacement, defect rectification and the embodiment of
modification or repair.
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• 9110 Clause 4 Requirements
– Requires Control of QMS Documentation/Records.
» QMS documents must be released and controlled.
» Records identified with retention times identified.
» Maintenance data must be under control.
• FAR and OEM Requirements
– Identify documents/records required by NAA certificated organizations.
» Have latest revisions of documents for work being performed.
» Current revisions of procedures and technical data must be available.
» Control of Technical Data/Records
» Maintenance/ technical data must be under revision control and approved.
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• FAR and OEM Requirements (cont.)
– Technical data that may be required to conduct Maintenance, Repair and Overhaul
(MRO operations).
» Repair Station Manual (RSM)
» Component Maintenance Manual (CMM)
» Aircraft Maintenance Manual (AMM)
» Airworthiness Directives (ADs)
» Service Bulletins (SBs)
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• 9110 Clause 5 Requirements
– Quality objectives are established.
– Safety Management System (SMS) implemented.
»
Safety policy and objectives established.
»
Product Safety reviewed during management reviews.
»
SMS should be married to the quality management system (QMS).
• Objectives required for both systems.
• Risk management processes applies to both systems.
• FAR and OEM Requirements
– Customer and regulatory requirements reviewed.
»
Regulatory and customer complaints managed.
– Customer and regulatory audit results reviewed.
– Changes to authority requirements reviewed during management reviews.
»
New capabilities added.
– Customer and regulatory corrective actions reviewed.
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• 9110 Clause 6 Requirements
– Personnel must be qualified and certified to NAA and customer contract
requirements.
– Identify and verify certifying staff (authorized to sign the release certificate for an
article after maintenance.
– Surveillance and assessment of non-certified personnel process implemented.
– Infrastructure and work environment must be established.
• FAR/OEM Requirements
– FAR Part 65 certifications, i.e., Airframe/Power Plant and Repairman Ratings.
– Unique NAA regulatory and/or OEM training program implemented.
– Establishment of a training program; initial and recurring training requirements.
– Personnel remain current in maintenance tasks related to procedures, human
factors, technical knowledge.
– Housing and facilities requirements must be met. Ample identified to perform MRO
operations.
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• 9110 Clause 7 Requirements
– Project, Risk and Configuration Management Related to Product. (7.1.1, 7.1.2,
7.1.3)
– Review of customer contract and NAA requirements (7.2)
» Review requirements for subcontracting of work.
– Design of Repairs and Applications (7.3)
» Includes repair solutions and aircraft maintenance programs.
– Suppliers managed (7.4)
»
Monitor for counterfeit parts (bogus parts).
– Maintain a list of approved process capabilities/ratings (7.5.1)
» Assess changes to maintenance processes for articles.
• Capability List verified.
» Monitor special processes implemented.
» Listing of maintenance forms and records.
» Review scope of work for repair station, locations.
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• FAR and OEM Requirements:
– FAR 145 Maintenance Organization/Repair Station.
» MRO regulation to which organization is certified.
» Process for inspection and recording hidden damage noted during MRO
operations.
» Reference to a manufacturer’s inspection requirements for an article.
» Samples of inspection , maintenance forms, release/return of articles to
service, FAA 8130, EASA Form 1.
» Capability List.
• List must identify each article by make, model and name identified by the article’s
manufacturer.
• Identification and traceability requirements must be met.
» Program to prevent purchase of counterfeit/suspected unapproved parts (7.4)
» Work transfer-review of work performed at another location.
• Review repair station manual for procedures to accommodate this approval/process.
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• 9110 Clause 8 Requirements
– Monitoring and Measuring (8.1)
– Internal Audit Process (8.2)
– Monitoring and reporting of product nonconformances (8.3)
– Corrective and Preventive Actions (8.5)
» Human Factors
» The overall goal of aviation maintenance human factors research is to identify
and optimize the factors that affect human performance in maintenance and
inspection.
• FAR and OEM Requirements
– Performance of regulatory required audits.
– Monitoring of Airworthiness Directives (ADs) related to products.
– Human Factors requirements related to product safety.
– Reporting of Escapes related to OEM products.
–
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• Topic of FARs include:
– FAR Part 21-Certification of Products and Parts
– FAR Part 43-General Maintenance Rules (Maintenance, PM and Alterations)
– FAR Part 65-Certification-Mechanics and Repairmen
– FAR Part 145-Maintenance Organization/Repair Stations
– FAR Part 91-General Operating and Flight Rules
– FAR Part 119-Certification of Air Carriers and Commercial Operators.
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• Most NAA authority requirements are based on the FARs.
– Several NAA Authorities include:
» Federal Aviation Administration (FAA)
» European Aviation Safety Agency (EASA)
» Japanese Civil Aviation Bureau (JCAB)
» Civil Aviation Administration of China (CAAC)
» Transport Canada Civil Aviation (TCCA)
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• Auditing Approach:
– Review and understand OEM/Customer Requirements.
– Review and understand what the specific NAA requirements as they apply to
OEM/Customer contracts.
– Finally, evaluate how the 9110 AQMS requirements are built into and align with
the OEM/Customer quality management system and NAA requirements.
RMC Workshop Long Beach, CA 16 – 17 July 2014
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Registration Management Committee
AS9110 Alignment To FAR/OEM Requirements
• Questions and Answers:
RMC Workshop Long Beach, CA 16 – 17 July 2014
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