New EASA Guidance on Supplier Evaluation: Who is a “Supplier?”
May 1, 2019 5 Comments
EASA has published new guidance directing Part 145 organizations to have procedures for accepting components, standard parts and materials (EASA 145.A.42(b)(i)), and to ensure that those procedures include supplier evaluation (EASA AMC1 145.A.42(b)(i)). Full details on the new supplier evaluation requirement are in yesterday’s blog post.
Who needs to be evaluated? It is not just the traditional distributors. The definition of supplier connected to this guidance is a very broad one:
“A supplier could be any source that provides components, standard parts or materials to be used for maintenance. Possible sources could be: Part-145 organisations, Part 21 Subpart G organisations, operators, stockist, distributors, brokers, aircraft owners/lessees, etc.” EASA GM2 145.A.42(b)(i).
This means that manufacturers, repair stations, operators, and aircraft owners are all suppliers, for purposes of the new guidance and rules. And they all need to be evaluated by Part 145 organizations when they are being used as suppliers of components, standard parts and materials. Evaluation should be based on the 16 elements of the supplier’s quality system, that were published by EASA. EASA GM3 145.A.42(b)(i).
Luckily, EASA established a reasonable mechanism for supplier evaluation. While it is possible for a repair station to perform its own evaluations to the standards set in the EASA guidance material, EASA has also permitted reliance on accredited distributors. This allows Part 145 organizations to purchase components, standard parts and materials from accredited distributors and to rely on the accreditation to meet the supplier evaluation requirements.
Note that relying on accreditation does not relieve the Part 145 organization of its other obligations to ensure that the component, standard part or material is acceptable for installation.
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Most of the Lessors (engine Lessors) don’t have any of the required standards below
(1) EN/AS9120 and listed in the OASIS database;
(2) ASA-100;
(3) EASO 2012;
(4) FAA AC 00-56
How should airline accept such lessor’s as supplier ? under which criteria ?
Excellent question, tdake. The requirement is that EASA 145 organizations must evaluate their suppliers. The listed standards are shortcuts that permit easy evaluation, but they are not the only ways to evaluate.
Normally, lessors either do not sell parts (they tend to disposition entire assets, like airframes and engines) but those that do sell items at the part-level tend to have separate parts distribution businesses. For example GECAS owns GECAS Asset Management Services, and GECAS Asset Management Services is accredited under AC 00-56B.
It is nice to see that these old posts are still getting some notice!
Thank You Jaosn for the reply. Yes old post but it’s good and exact information posted by you what was searching.
I still need clarification e.g. many engine lessor lease/loan the engine to Airlines and in such cases as they don’t have any of the listed standards compliant. How should Airlines accept them as whole engine supplier? Your additional input will for surely help.
Tushar
Tushar,
For starters, let’s remember the regulatory language:
“The organisation shall establish procedures for the acceptance of components, standard
parts and materials for installation to ensure that components, standard parts and
materials are in satisfactory condition and meet the applicable requirements of point (a).”
EASA guidance has suggested oversight of suppliers, and reliance on EASA-trusted third party oversight organizations, as a systems-based means of mitigating the risk of receiving parts in unsatisfactory condition. E.g. EASA AMC1 145.A.42(b)(i) Components. But the EASA guidance provides fairly broad discretion in tailoring supplier evaluation to the specific situation. EASA GM3 145.A.42(b)(i) Components.
I have worked with airlines on acceptance and return of leased assets. In my experience, the organizations typically have a robust mechanism for ensuring the condition of the engine upon acceptance. But if a 145 organization did not have its own standards that met the requirements of the regulations, then the EASA guidance material has provided a mechanism for oversight of suppliers at EASA GM3 145.A.42(b)(i) Components in section (a).
If you need help developing a system for receiving engines and ensuring supplier control, then my firm would be happy to provide support for your efforts. Please feel free to contact me directly.