Sofema Aviation Services (SAS) www.sassofia.com considers the use of Alternate Tools in Part 145 Tooling Stores in relation to the use of “Task-Specific Tooling.”
Introduction
To be able to use “alternative tooling” requires a procedure to ensure a previous verification in the maintenance data of the product or component being maintained.
Considerations when the Maintenance data allows the use of alternative tooling
Only when this possibility is expressed in the maintenance data, the maintenance organisation is entitled to proceed with an equivalence assessment process in order to use alternative tooling.
Alternative tooling may be obtained by different means & there are 2 scenarios.
Alternate Tools when the Tooling Technical Data is Available
- Tooling technical data may be considered acceptable when:
o The maintenance data (AMM, CMM, etc…) already includes such data (i.e. manufacturing drawing, technical characteristics, manufacturing procedure, etc.), or;
o The maintenance organisation obtains additional data (i.e. manufacturing drawings, etc.) from the relevant manufacturer (may be the applicable TCH, STCH, OEM, or the tool manufacturer which is specified in the maintenance data of the product or component being maintained).
o In both cases the following minimum steps shall be considered and described in the MOE.
Process which should be followed to ensure Conformity
- Technical Specification: engineering document establishing:
o The technical characteristics of the tooling to be acquired/manufactured to demonstrate it is in conformity to the relevant technical data (i.e. dimensions, material, functions, accuracy, etc.), and;
o The applicable inspection/service/calibration need.
- Manufacture/acquisition: process in use to manufacture the tool and/or to acquire it from any internal or external source;
- Acceptance: incoming inspection process to verify the tooling meets the requirements established in the Technical Specification and is identified accordingly;
- Validation: practical demonstration (i.e. functional check, etc.) that the alternative tool is capable of correctly performing the relevant maintenance task.
Alternative tooling equivalence declaration: The satisfactory completion of the process mentioned above, is finalized by the formal approval by the maintenance organisation.
Alternate Tools when the Tooling Technical Data is Not Available
The maintenance organisation, may still intend in this situation to use alternative tooling, applying its engineering judgment through a reverse engineering approach.
- The main driver to evaluate the applicability of this option is a risk-based approach that shall be considered by the maintenance organisation on a case-by-case basis.
- This option is to be limited to the cases where the use of the alternative tooling does not affect the content of the maintenance task in terms of sequence and performance of the maintenance.
Process Which Should be Followed to Ensure Acceptability / Conformity
- Technical Specification: engineering document establishing:
o The technical characteristics of the tool to be acquired/manufactured based on a reverse engineering approach (i.e. dimensions, material, functions, accuracy, etc.) to demonstrate it is equivalent to the one specified in the maintenance data of the product or component being maintained, and;
o The applicable inspection/service/calibration need.
- Manufacture/acquisition: process in use to manufacture the tool and/or to acquire it from any internal or external source;
- Acceptance: incoming inspection process to verify the tooling meets the requirements established in the Technical Specification and is identified accordingly;
- Validation: practical demonstration (i.e. functional check, etc.) that the alternative tool is capable of correctly performing the relevant maintenance procedure.
Alternative tooling equivalence declaration: The satisfactory completion of the process mentioned above, is finalized by the formal approval by the maintenance organisation.
What options are available where the Maintenance data does not support the use of alternative tooling?
When the maintenance data does not allow or does not clearly states that alternative tooling may be used the following options are possible:
- Acquire the specific tooling P/N by the identified vendor (s), or;
- Request a revision of the maintenance data directly to the TCH or STCH or ETSO holder to include the alternative tooling proposed by the maintenance organisation before its use, or;
- Request approval for deviation to the maintenance data.
Note 1: Such deviation needs to be in the form of a new approved data (i.e. data issued by an appropriately approved EASA Part-21 DOA or under the conditions defined in bilateral agreements between the Community and the competent authority of a third country).
Note 2: Such request should be typically addressed to the TCH or STCH or ETSO holder or if this is not possible, to any other appropriately approved EASA Part-21 DOA.
The Need to Document Equivalence
Alternative tooling equivalence needs to be formally documented to meet the following minimum requirements:
- The assessment has to be recorded in a form (to be included in the MOE Part 5.1 list of forms), which allows recording for each tool;
- The reference to the maintenance data requiring the tooling;
- The identification of the tooling as given by the maintenance data;
- The identification of the alternative tooling to be used by the maintenance organisation.
Note 1: the form described above need to be kept on-file 3 years after the tool has been permanently withdrawn from service by the maintenance organisation.
Note 2: A system shall be in place for the maintenance staff so they can easily identify the alternative tooling to be used as a replacement of the one identified.
Next Steps
Sofema Aviation Services provides the following 1-day training course covering the essential areas of the Part 145 Tooling Store – Please see the following link or email team@sassofia.com:
Part 145 Stores Tooling Control, Inspection Procedures & Best Practice – 1 Day
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Alternate Tools, aviation, Aviation Maintenance Data, EASA Part 145, EASA Part 145 Stores, Part 145 Tooling Store, SAS blogs, Stores, Tooling Store, Tooling Technical Data
