New EASA Guidance on Supplier Evaluation: Who is a “Supplier?”

May 1, 2019 by 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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Europe Formally Recognizes AC 00-56 and ASA-100

April 30, 2019 by 1 Comment

The European Union has formally recognized FAA AC 00-56 and ASA-100 as acceptable methods for supplier evaluation.

Some of you will remember that ASA was working with the European Aviation Safety Agency (EASA) to establish protocols for aircraft parts suppliers.  EASA examined various proposals for regulating distributors, and ultimately concluded that the FAA’s Voluntary Industry Distributor Accreditation Program was an appropriate model upon which to rely.  EASA sought comments on the proposal and ultimately issued a recommendation to the European Commission.

The first part of that recommendation was acted upon in August when the European Commission issued a new rule that required repair stations (EASA 145 organization) to

“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”  EASA 145.A.42(b)(i).

The second part of that recommendation has been implemented in ED Decision 2019/009/R.  This Decision provided guidance on what it means to establish the above procedures.  First, the guidance clarifies that “[f]or the acceptance of components, standard parts and materials from suppliers, the [] procedures should include supplier evaluation procedures.” AMC1 145.A.42(b)(i) Components, section (b).   At first glance, this appears to impose a huge new obligation on repair stations to evaluate suppliers.  But EASA has offered an easy way to meet this evaluation obligation, by relying on the existing infrastructure for supplier evaluation.

GM3 145.A.42(b)(i) Components explains how to evaluate suppliers.  It explains that a suppliers’ quality system should have certain elements.  It also permits reliance on suppliers known (through external auditing) to meet four standards that are considered acceptable: AC 00-56, ASA-100, AS/EN9120 and EASO 2012.  This means that a 145 organization can rely on a supplier that was audited to such a standard, and does not have to perform its own evaluation.  The basis for endorsing each of these standards was an analysis of each standard by EASA that found that each was in compliance with the list of elements published in this GM.

I was part of the EASA rulemaking team that performed the evaluations, so I know that EASA put a lot of effort into validating that the Voluntary Industry Distributor Accreditation Program was acceptable for use in Europe.  The entire industry of accredited distributors should be proud of this recognition, because it is the result of 25 years of commitment to safety and quality.

This is great news for the community of accredited distributors.  This verifies that aircraft parts installers who rely on AC 00-56 as an element of their supplier selection process are doing the right thing.  It also confirms that the global norms for supplier evaluation are working to enhance safety.

 

Look for tomorrow’s article on how broad is the European definition of “supplier.”

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