Sofema Aviation Services www.sassofia.com looks at the challenges of maintaining an effective supply change compliant with EASA, Best Practice & Due Diligence.
What is it all about
Amongst other proposed changes EASA looked at enhancing the supplier evaluation procedure to provide clarity together with a strong and robust process
So what happened
Unfortunately, as is currently happening in many regulatory related areas EASA steps back and several years pass. (This story is not a positive reflection on the role of EASA – however it is unlikely that this will change or improve in the near term!)
So what should I do?
The important thing to realise is that EASA regulations are minimum compliance. For an organisation to implement positive behaviours which are reflected in an EASA NPA for example.
In this context best practice would be to review the following information and to consider the advantage and opportunity to incorporate within the organisation procedures
GM 145.A.42 (a) Supplier evaluation and control (Proposed)
1) The following elements may be checked for the evaluation and control of a supplier’s quality system, as appropriate, to ensure that the component and/or material is supplied in satisfactory condition:
a. Availability of appropriate up to date regulations, specifications such as component manufacturer’s data and standards;
b. Standards and procedures for training of personnel and competency assessment;
c. Procedures for shelf-life control;
d. Procedures for handling of electrostatic sensitive devices;
e. Procedure for identifying the source from which components and material were received;
f. Purchasing procedures identifying documentation to accompany components and material for subsequent use by approved Part-145 maintenance organisations;
g. Procedures for incoming inspection of components and materials;
h. Procedures for control of measuring equipment that provide for appropriate storage, usage, and for calibration when such equipment is required;
i. Procedures to ensure appropriate storage conditions for components and materials that are adequate to protect the components and materials from damage and/or deterioration. Such procedures should comply with manufacturers’ recommendations and relevant standards;
j. Procedures for adequate packing and shipping of components and materials to protect them from damage and deterioration, including procedures for proper shipping of dangerous goods. (e.g. ICAO and ATA specifications);
k, Procedure for detecting and reporting of suspected unapproved components;
l. Procedure for handling unsalvageable components in accordance with applicable regulations and standards;
m. Procedures for batch splitting or redistribution of lots and handling of the related documents;
n. Procedure notifying purchasers of any components that have been shipped and have later been identified as not conforming to the applicable technical data or standard;
o. Procedure for recall control to ensure that components and materials shipped can be traced and recalled if necessary;
p. Procedure for monitoring the effectiveness of the Procedure for detecting and reporting of suspected unapproved components;
2) Suppliers certified to officially recognised standards that have a quality system that includes the elements specified in 1) may be acceptable; such standards include:
a. EN/AS9120 and listed in the OASIS database;
b. ASA-100;
c. EASO 2012;
d. FAA AC00-56.
The use of such suppliers does not exempt the organisation from its obligations under 145.A.42 to ensure that supplied components and material are in satisfactory condition and meet the applicable criteria of 145.A.42(e).
Sofema Aviation Services www.sassofia.com and SofemaOnline www.sofemaonline.com provide EASA compliant classroom and online regulatory and vocational training – for details please email office@sassofia.com or online@sassofia.com
