Showing posts with label Regulatory Compliance. Show all posts
Showing posts with label Regulatory Compliance. Show all posts

Apr 28, 2009

How to Become a Certificated 14 CFR Part 145 Repair Station

Following the links in this article to FAA website gives a good idea of the Part 145 certification requirements (sourced by Kuttan as a reference for domain specialists):


The 14 CFR Part 145 certification process provides for interaction between the applicant and the FAA from initial inquiry to certificate issuance or denial. It ensures that programs, systems, and intended methods of compliance are thoroughly reviewed, evaluated, and tested. Any questions about this process should be directed to the nearest Flight Standards District Office (FSDO).

The certification process consists of five phases:

* Preapplication Phase
* Formal Application Phase
* Document Compliance Phase
* Demonstration and Inspection Phase
* Certification Phase

A. Preapplication Phase

(1) Preapplication Statement of Intent (PASI), FAA Form 8400-6

(a) The PASI will be used by the Manager, Flight Standards Division or designee to evaluate the complexity of the proposed operation. This allows the establishment of the certification team to be based on the complexity of the certification. A Certification Project Manager (CPM) will be designated as the principal spokesperson for the FAA during certification.

(b) An applicant should conduct a thorough review of the appropriate regulations and advisory material to provide guidance for personnel, facility, equipment, and documentation requirements. As a result of this review, the applicant must address, in FAA Form 8400-6, Preapplication Statement of Intent (PASI), how these requirements will be met.

NOTE: Submittal of the PASI by the applicant shows intent to initiate the certification process.

(2) Preapplication Meeting. The preapplication meeting should be held in the district office. This will allow the applicant to become familiar with the assigned FAA personnel.

(3) Application for Repair Station Certificate and/or Rating, FAA Form 8310-3. During the preapplication meeting the applicant should be instructed on how to complete the application.

(4) Formal Application Attachments. During the preapplication meeting requirements for the application attachments should be discussed. This discussion should include the following:

(a) Manual. The applicant should be encouraged to use Advisory Circular 145-9, which provides information and guidance material for all repair station certificate holders or applicants under Title 14 of the Code of Federal Regulations (14 CFR) part 145 to develop and evaluate a repair station manual (RSM) and quality control manual (QCM). The material presented in this AC describes an acceptable means, but not the only means, to develop a manual and comply with the referenced regulations. The manual should allow the user to understand its content without further explanation and must not contradict any regulatory requirements.

NOTE: It is the applicant's responsibility to develop manuals and procedures that ensure safe operating practices and compliance with the rules. The team can offer suggestions for improvement but must not "write" the material.

(b) Letter of Compliance. The letter of compliance will ensure that all applicable regulatory requirements are addressed during the certification process. Listing each applicable FAR section, in sequence with the FARs, does this. After each listed regulation, there must be a brief narrative or specific reference to a manual/document that describes how the applicant will comply with that regulation. The letter of compliance must be reviewed to ensure that the applicant has a clear understanding of the regulation and that the proposed method of compliance meets the intent of the regulation.

(c) Letter stating compliance with 14 CFR 145.53(c) or (d).

B. Formal Application Phase. To begin the Formal Application Phase the team will receive the application, and attachments. As a rule, the team will meet with the applicant after receiving the formal application package. All questions about the proposed operation, the formal application, and attachments should be resolved at this time. The meeting should consist of the certification team members and all key management personnel from the applicant's organization.

Corporation Papers: If a corporation makes the application, the FAA must have a copy of the Certificate of Incorporation by the State and any accompanying documentation to evaluate the eligibility of the applicant.

Drug and Alcohol Program: All applicants wishing to perform maintenance functions on Air Carrier / Commuter aircraft or components must provide a drug and alcohol program to be approved by the FAA. The Drug Abatement Home page is located at the following address: http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/aam/drug_alcohol/

C. Document Compliance Phase. In this phase, the application is thoroughly reviewed for approval or disapproval, and the manual and related attachments are reviewed for acceptance or rejection. This review ensures both conformity to the applicable regulations and safe operating practices. This phase is done in the district office by the certification team.

D. Demonstration and Inspection Phase. In this phase the certification team ensures that the applicant's proposed procedures are effective and that facilities and equipment meet regulatory requirements. The Certification Project Manager must decide if demonstrations will be required.

E. Certification Phase. Once the applicant meets the regulatory requirements of CFR Part 145, the certification team will issue the repair station certificate and operations specifications with the appropriate ratings.

Forms
* FAA Form 8000-4, Air Agency Certificate
* FAA Form 8000-4-1, Repair Station Operations Specifications
* FAA Form 8060-4, Temporary Airman Certificate
* FAA Form 8310-3, Application for Repair Station Certificate and/or Rating
* FAA Form 8400-6, Preapplication Statement of Intent
* FAA Form 8610-2, Airman Certificate and/or Rating Application, if applicable
* FAA Form 337 , Major Repair and Alteration. Instructions are in AC43.9-1E.
* FAA Form 8130-3 , Airworthiness Approval Tag. Instructions are in Order 8130-21D.

References
* 14 CFR Parts 43, 45, 65, 121, 125, 135, and 145
* Advisory Circular 145-9, Guide for Developing and Evaluating Repair Station Manual and Quality Control Manual.
* Advisory Circular 145-5, Repair Station Internal Evaluation Programs.
*SFAR 36
* Order 8300.10, Airworthiness Inspector's Handbook, Vol. 2, Chapters 161, 162, 164, and 165 .

* 145 Certification Job Aid.
* 145 Repair Station Manual & Quality Manual Job Aid.

The following information is used by FAA Inspectors as guidance information during the certification process. This information would be very valuable to the applicant to review.

Airworthiness Inspector’s Handbook: Order 8300.10

8300.10 Vol 1 CHAPTER 4 The generic process for certificating organizations.

8300.10 Vol 2 CHAPTER 161 Introduction to CFR Part 145.

8300.10 Vol 2 CHAPTER 162 Certificate CFR Part 145 Domestic/Satellite Repair Station.

8300.10 Vol 2 CHAPTER 164 Evaluate CFR Part 145 Manual Revisions.

8300.10 Vol 2 CHAPTER 165 Evaluate CFR Part 145 Repair Stations facilities and equipment.

8300.10 Vol 2 CHAPTER 24 Certificate Repairman/Added Privileges.

AC 65-24 Advisory Circular for Certification of a repairman.

AC 65-31A Training, qualification, and certification of Nondestructive Inspection (NDI) personnel.

AC 120-78 Advisory Circular for Acceptance and use of electronic signatures, electronic recordkeeping systems, and electronic manuals.

AC 145-9 Guide for Developing and Evaluating Repair Station and Quality Control Manuals

AC 145-10 Repair Station Training Program

Suspected Unapproved Parts (SUP) Office Home Page.

Nondestructive Testing (NDT) CHECKLIST for use with Visual, Penetrant, Magnaflux, Eddy Current, Ultrasound, and X-ray.

Jan 29, 2009

RFID & Embedded chips for Aviation parts management...

Author: Jim Clark

Several years ago, the FAA estimated that unapproved parts played a role in 174 U.S. aircraft crashes or less serious accidents between May 1973 and April 1996, causing 17 deaths and 39 injuries, although none involved a major airline. Every year, with the help of the industry, FAA finds "suspected unapproved parts" in the supply chain. While the number of unapproved parts flagged by FAA’s unapproved parts program is fairly small, how many counterfeit parts escape notice? How much damage do they cause? Because crashes frequently destroy the parts that fail, it’s hard to know.

We haven’t heard much about the counterfeit parts problem since 1995, when then-FAA Inspector General Mary Schiavo sounded the alarm and triggered Congressional hearings. Speculating about the threat of bogus parts isn’t a favorite talking point for manufacturers, airlines or the FAA.

We do know that counterfeit parts makers are getting more sophisticated. For instance, in 2007, FAA issued an "unapproved parts notification" regarding counterfeit tail rotor hanger bearings electro-etched with fake Bell Helicopter part numbers.

So what more can the industry do about it? Benjamin Jun, VP for technology at Cryptography Research, is suggesting a high-tech solution the company first developed to prevent counterfeiting of consumer products: embedding tiny, 1-millimeter square, tamper-resistant silicone chips that signal their authenticity into key parts, particularly in the avionics systems in aircraft. The San Francisco-based firm designs the core of these "CryptoFirewall" chips to withstand sophisticated attacks by professional counterfeiters.

Here’s how the system would work: Mechanics would be given hand-held verifiers that could communicate with the embedded chip, which would respond, confirming who manufactured it and that it was FAA certified. The verifier would communicate an unpredictable challenge to the chip and verify the authenticity of the chip’s response. In some ways, the system resembles complex systems to defeat hackers.

The chip might also signal other information, like when it was manufactured, when it was installed or how many times it has been used, so that it could flag when it needed to be replaced, the way cars remind drivers when they need service.

Cryptography Research has already marketed its CryptoFirewall embedded-chip technology to protect several consumer products from counterfeiting. For instance, a chip in satellite TV systems verifies that the customer is authorized to use the signal. Chips in lithium batteries verify that they are appropriate for the cell phone they power. Another chip prevents counterfeiters from cloning the cell phones themselves. And chips in smart cards verify the identity of parties making large financial transactions.

What would such a system cost for aircraft parts? The cost depends on part volume. For high volume parts, like the ones used in consumer products, the added cost can be as low as 20 cents per part, according to Jun. For aircraft parts, which are manufactured in lower volumes, he projects that the cost would probably be more like a dollar or two per part. For components that already contain application-specific integrated circuits (ASICS), manufacturers could add CryptoFirewall logic to those circuits, which would be cheaper than installing stand-alone chips.

Since the technology has proven worthwhile to protect against counterfeit consumer products, where potential counterfeiting damages may be only a few hundred dollars per unit, Jun expects it would be cost-effective to authenticate aircraft parts whose failure can cause crashes and lead to fatalities.

Some aircraft manufacturers already incorporate radio frequency identification devices (RFIDs) in aircraft parts. Although RFIDs can contain the same kind of information that could be included in CryptoFirewall chips, Jun says that counterfeiters have been able to copy RFIDs, as well as bar codes, holograms, and other passive security mechanisms. However, for non-security applications, Jun expects these technologies to remain popular since they can cost only a few cents per part.

Cryptography Research is just starting to explore the potential of the avionics market. Jun says that his firm hasn’t talked to the FAA yet. The company has not announced any deals with aircraft manufacturers, but then, it doesn’t usually disclose its customer base, giving an extra level of protection against potential counterfeiters.

According to Jun, it would probably take two to three years for a manufacturer to implement this embedded chip anti-counterfeiting technology.

Aircraft manufacturers could develop their own anti-counterfeiting computer chip systems without using Cryptography Research’s services and technology. But Jun cites several advantages of contracting out this specialized function, including Cryptography Research’s track record of security, bundled licenses for semiconductor security key patents, and faster time-to-market.

[Sourced by Kuttan from Aviation Today]

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