Perform Oversight of the Aerospace Supply Chain
Repair stations vary tremendously in size and scope of activities. Some large repair stations provide the daily work necessary to keep an airline’s fleet operating. Others perform substantial maintenance, which might include more thorough inspection and repairs on airframes and overhauls of highly complex pieces of hardware, such as aircraft engines. Some repair stations offer very specialized services for their customers such as welding, heat treating, and coating on a variety of aircraft parts. However, the vast majority of repair stations perform maintenance on components, normally remote from airports and hangars.
RequirementsFAA and other National Aviation Authorities (NAAs) oversight of certificated repair stations require a tremendous amount of resources, centered around personnel with a high degree of specialized knowledge about manufacturing and repair processes, material technology, regulations, quality control techniques and much more. It is a well know fact that, like many other federal agencies, the FAA’s budget is limited and the agency is always under public and congressional scrutiny, especially during the aftermaths of aviation accidents. In a couple of reports published in 2003 and 2005, the Department of Transportation through the Office of the Inspector General (DOT IG) expressed concerns about the FAA’s oversight of the contract maintenance industry and stated that the agency’s oversight is currently insufficient for the amount of work independent repair stations perform for airlines.
The FAA has responded to these findings by, amongst other things, introducing a risk-based inspection program that identifies those repair stations doing the most work for airlines and monitoring their operations more closely. At present, it is estimated that the FAA has certified close to 4,600 domestic and 650 foreign repair stations. However, in addition to the FAA certificated repair stations, a growing number of non-certificated repair stations are performing safety critical work, according to a recent report issued by the same Office of Inspector General from the US Department of Transportation. By definition, the work performed by these non-certificated repair stations is not overseen by the FAA inspectors. Even though the work performed in such non-certificated stations must be performed by FAA certified mechanics and inspected by FAA certified inspectors, there is a dramatic difference between the regulatory requirements for certified and non-certified stations.
Additional Layer of ControlDue to economic pressures, many airlines are outsourcing a growing percentage of their maintenance, repair and overhaul activities. It is estimated that over the past decade, network air carriers have increased contract maintenance from 37% of their total maintenance expenses to 53%. Furthermore, some of the outsourced maintenance, repair and overhaul work is being contracted to emerging MR&O suppliers, based in countries without a strong history in the aerospace and aviation sectors. So naturally many interested stakeholders are concerned with the FAA and other NAA’s, as well as the airlines’ ability in performing adequate oversight of repair stations far and away, where their inspectors will have to assess the suppliers technical and technological abilities in addition to their quality management practices, but under the heightened challenge of the language and cultural barriers and differences.The number of non-certificated vendors approved by Air Transportation Oversight System (ATOS) air carriers to perform aircraft maintenance ranges from 4% to 39% of the total number of maintenance vendors.
With all these growing concerns about the contract maintenance sector being able to maintain and improve flight safety under this continually changing backdrop, a potential additional layer of control that all stakeholders might consider to provide supplementary confidence of both certified and non-certified repair stations might be derived from the Industry Controlled Other-Party (ICOP) certification Scheme to the AS9110 Standard. AS9110 includes all of ISO 9001:2000 quality management system requirements and specifies additional requirements for a quality management system meant to be deployed by aerospace maintenance organizations. It should be noted at this point that AS9110 is an American standard, developed and maintained by Society of Aeronautical Engineers (SAE).
In Europe, the technically equivalent standard is EN 9110 and in Asia, the JISQ 9110 document. All three documents contain the same requirements, so MR&O organizations operating in any part of the world will be subjected to the same level of expectations. AS9110 is very similar to the AS9100 Standard, a document that has been developed by the major aerospace OEMs (through SAE) and is being deployed throughout the aerospace supply chain. According to the Online Aerospace Supplier Information System (OASIS) database, there are over 4,500 organizations certified to the AS9100 Standard. A basic and critical aspect for any MR&O organization is compliance with the applicable aviation authorities’ regulatory requirements, as well as customer requirements. As mentioned above, accredited certification of an MR&O supplier to AS9110 is intended to provide an additional layer of control, not as a replacement of regulatory oversight, nor customer monitoring. The ICOP certification scheme has additional controls, when compared to the traditional third party certification process. Some of the additional controls include witnessed audits by OEMs and allowance for Regulatory NAA representatives to also perform audits of the Accreditation and Certification Bodies, in addition to be present during the assessments of the suppliers themselves.
The ICOP Scheme also strengthens the requirements imposed for the qualification and competence of registrar auditors and time on-site, during the audits. At this time, airline involvement in the AS9110 Standard and ICOP scheme has been minimal. It is expected that some airlines, realizing the potential implications and benefits of invoking AS9110 to their supplier base, might become more involved through the Sectorial Groups: The Americas Aerospace Quality Group – AAQG, the European Aerospace Quality Group – EAQG and the Asia Pacific Aerospace Quality Group – APAQG.
ImplementationSo, let’s explore why implementation and possibly accredited “other-party” certification of an MRO organization to AS9110 could be beneficial to stakeholders such as the suppliers themselves, the airlines, aerospace OEMs and the regulatory agencies. From a supplier standpoint, implementing AS9110 may lead to a well structured quality management system, departing from the failed “do-inspect-fix-blame” cycle to the much better and successful “plan-do-check-act” approach. The intent of a properly implemented quality management system is to prevent avoidable rework and repair, thus improving profitability, as well as improving timeliness of work execution. Establishing a process for monitoring customer satisfaction is also a requirement from AS9110, so the supplier will have to be proactive and seek feedback on how their customers perceive them. As an example, if customers overwhelmingly complain about late deliveries or completion of major overhauls, the supplier should not only identify the issue, but through the management review and corrective action processes establish ways to rectify the “chronic tardiness” problems.
Many large, legacy airlines are presently going through financial difficulties. And, supplier oversight is an increasingly expensive activity. If airlines could collectively rely on AS9110 certificates as a COMPONENT of their supplier oversight process and tailor the remainder of their oversight activities, based on the results of the AS9110 audits performed by the registrars and/or other customers, they could allocate their oversight resources more wisely. In the OEM world, such a process is becoming a generally accepted practice. Many Aerospace OEMs are relying on “ICOP” controlled AS9100 certificates as evidence of supplier’s Quality Management System, and focusing on product specific assessments. By shifting their attention from QMS assessment to product related issues, OEMs are able to utilize their supplier Q.E.s/representative’s time to assess the supplier performance on issues that are near and dear to them, as customers. It is a much more focused assessment.
Aerospace OEMs themselves perform R&O activities and also outsource some of the work. For R&O work done, either in-house or outside repair stations, compliance to AS9110 could assist in boosting confidence on the quality of the work.
For Regulatory Agencies, also struggling with the oversight resources issue, this layer of oversight could be a welcomed activity. The suppliers themselves are responsible for the costs of the registrar audits. The Regulatory Agencies, upon gaining confidence of the AS9110 certification process, could even use, like the airlines, the results of the 9110 audits as an input to tailor their own oversight audits. For non-certificated repair stations, presently outside of the Regulatory oversight process, certification to 9110 could give the NAAs some confidence about the supplier’s ability to conduct repair work that satisfies minimum recognized standards.
In order for the AS9110 ICOP certification process to be a RELIABLE COMPONENT of an Industry wide oversight process, it is critical that all players, from the Regulatory Agencies, to the airlines, to the repair stations, to the Accreditation Bodies, to the Certification Bodies and the suppliers are ALL aligned in keeping flight safety as the utmost goal, not a meaningless fancy certificate on the wall to be displayed in trade shows and hung in the lobby. In the 9100 ICOP certification world, there have been cases of a Registrar and a “related body” caught in a conflict of interest situation, which led to the registrar temporary suspension and later reinstatement, after a lawsuit against the Accreditation Body. The case was settled out of court (reference QSU article). Also, the three Sectorial Groups: AAQG, EAQG and APAQG need to make sure that the accreditation requirements for registrars to be authorized to issue 9110 certificates is truly harmonized. As of early January 2006, there are apparent different approaches between some of the European Accreditation Bodies and the US Accreditation Body, ANSI-ASQ National Accreditation Board, ANAB. For the process to have, as intended, Worldwide acceptance, it is critical for a truly harmonized process to exist.
Sidney Vianna is the director of Aviation, Space & Defense Certification Services for DNV Certification. He is a non-voting member of the Registration Management Committee with the Americas Aerospace Quality Group. He is also the District Manager in the U.S. and Canada West Coast. For more information, visit www.dnvcert.com.