I recently hosted a webinar on the topic of AS9110B Quality Management Systems – Requirements for Aviation Maintenance Organizations. I received some great questions from attendees, so I’d like to share the Q&A session with you.
Q: What would be some typical product safety objectives?
A: In terms of safety, it’s important to look at it in through two lenses. One is obviously flight safety, so as it relates to the construction of any kind of repair process. Are you taking into account the possible risk, as it relates to flight safety concerns, which could be very product specific? How are you managing those within your repair process? There are product specific or procedure specific type of safety items that any MRO activity should consider appropriately. Then also, the employee safety of employees involved in the MRO activity. There are a number of things; they almost take on a Health & Safety type of feel to them as far as possible injuries, near misses, as it relates to the repair activity. It’s probably worth noting, we do want to make sure safety, as it relates to preforming repair activities, is appropriately being measured and anything that could be considered a safety risk is being measured as part of the process.
Q: Can you elaborate on technical data?
A: Absolutely. Technical data can include things like airworthiness directives; certainly anyone that’s operating an MRO has come into contact with these. It could be a service bulletin, documents themselves that detail any kind of service requirement , repair modifications, things like maintenance manuals, drawings, EO’s, and technical orders. It can include anything that relates to the repair activity itself. One of the useful approaches that I saw an auditor take is to start to look at the repair activity itself and then from that, look out in terms of documentation. What’s necessary in order to support the repair activity in terms of documentation itself?
Q: Our company is certified to AS9110 for the first time, are there simple safety policies and safety objectives we can view to obtain some insight?
A: Every organization is going to be a little different. So I’m apprehensive to say this set works for everyone, tried and true, but a great vehicle for looking at potential best practices, is through the IAQG website. If you go to the IAQG website, there are supporting materials, FAQs, but there’s also a set of documents including the Supply Chain handbook manual, which talks about different sections of the standards, and specifically with 9110, can offer insight into safety objective and policy type items.
Q: How is the repair station manual incorporated into the AS9110 quality manual?
A: There’s no prescriptive answer, some organizations will have a requirement by their respective authority, that they maintain a repair manual and a quality manual. Some authorities or local representatives of those authorities will allow the MRO to combine them; I don’t see that too often, but it does happen. So it’s really important to make sure, especially in 9110 since we’re talking about repair where the interface with the air safety authority is so much stronger, to really make sure that you understand that requirement. How do you manage manuals, what’s required, can you operate an MRO with an integrated repair/quality manual? Often times the authority will simply want to see your repair manual, so it’s really important to understand your ability to manage that documentation accordingly.
Q: Could you please provide some risk assessment formats as related to different MRO environments?
A: I’ve seen a number of different MRO companies take an approach called failure mode analysis, where they look at, in terms of risk management, the possible failures that could happen within the different levels of processes and different activities. Using a FEMA like approach, building scoring systems; red, yellow, green type systems – high, medium and low risk, where they assess that. They look at it in terms of what can potentially go wrong, in terms of all potential risks, and identify correspondingly with that potential ways to mitigate, whether they be controls, additional verification, audits or changes to work instructions. They took that whole thing and found a way to tailor it to manage risk associated with the repair process. I thought it was a really good approach.
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Posted in: Aerospace |