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  1. Compliance Requires Objective Evidence

  2. Welcome C.A.S.E. Standard 3A Quality Program Requirements Distributors of New and Used Parts Compliance Requires Objective Evidence

  3. 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 Compliance Requires Objective Evidence

  4. Course Outline Cont’d • FAA unapproved parts video • Review • Test Compliance Requires Objective Evidence

  5. 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 Compliance Requires Objective Evidence

  6. It’s Show Time • NORWEGIAN DOCUMENTARY • “The Risk is Onboard, the illegal trade in BOGUS Aircraft Parts” Compliance Requires Objective Evidence

  7. After The Show • NORWEGIAN DOCUMENTARY • “The Risk is Onboard, the illegal trade in BOGUS Aircraft Parts” • COMMENTS Compliance Requires Objective Evidence

  8. 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 Compliance Requires Objective Evidence

  9. 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 Compliance Requires Objective Evidence

  10. 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 Compliance Requires Objective Evidence

  11. 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 Compliance Requires Objective Evidence

  12. 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 type-certificated 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) Compliance Requires Objective Evidence

  13. 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 Compliance Requires Objective Evidence

  14. 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 Compliance Requires Objective Evidence

  15. 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 acceptablesource • Quality System Standards Organizations - organizations that have developed quality system standards to be utilized by others Compliance Requires Objective Evidence

  16. 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 Compliance Requires Objective Evidence

  17. 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 Compliance Requires Objective Evidence

  18. 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 Compliance Requires Objective Evidence

  19. 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 Compliance Requires Objective Evidence

  20. 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) Compliance Requires Objective Evidence

  21. 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 Compliance Requires Objective Evidence

  22. 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 Compliance Requires Objective Evidence

  23. 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) Compliance Requires Objective Evidence

  24. 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 Compliance Requires Objective Evidence

  25. 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 Compliance Requires Objective Evidence

  26. 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 Compliance Requires Objective Evidence

  27. 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 Compliance Requires Objective Evidence

  28. 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 Compliance Requires Objective Evidence

  29. 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 Compliance Requires Objective Evidence

  30. 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 Compliance Requires Objective Evidence

  31. 2) Quality System and Quality Manual Cont’d • A. Established Quality System (cont’d) Minimum Elements Described in Manual • 10) Material Control • 11) Housing and Facilities • 12) Internal Audit and Surveillance • 13) Scrapped Parts Procedure • 14) Certification Forms Compliance Requires Objective Evidence

  32. 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 Compliance Requires Objective Evidence

  33. 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 Compliance Requires Objective Evidence

  34. 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 Compliance Requires Objective Evidence

  35. 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) Compliance Requires Objective Evidence

  36. 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 Compliance Requires Objective Evidence

  37. 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 Compliance Requires Objective Evidence

  38. 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? Compliance Requires Objective Evidence

  39. 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 Compliance Requires Objective Evidence

  40. 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? Compliance Requires Objective Evidence

  41. Questions F. Does the distributor maintain a current list of manufacturers who officially authorize them as a distributor? Compliance Requires Objective Evidence

  42. 4) Inspection Procedures (Responsibility by Title) • A.Inspectors • Verify Incoming Parts and Materials • free from defects • good state of preservation Compliance Requires Objective Evidence

  43. 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 Compliance Requires Objective Evidence

  44. 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 Compliance Requires Objective Evidence

  45. 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 Compliance Requires Objective Evidence

  46. 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 Compliance Requires Objective Evidence

  47. 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 Compliance Requires Objective Evidence

  48. 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? Compliance Requires Objective Evidence

  49. 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? Compliance Requires Objective Evidence

  50. 5) Shipping Procedures • A.Shipping Requirements • ATA - 300 Specification Container • Equivalent • One Specified By Customer • packed in manner to preclude damage by rough handling Compliance Requires Objective Evidence