One of ASA's members wrote to me with a Spec 106 question. It is a question that I have heard before. At its root, the question is, "What does block 13C on the ATA Spec 106 form ("Last Certificated Agency") mean and whose name do we put into that block?"
In this case, a distributor was planning on purchasing aircraft parts from a non-US air carrier. The carrier in question is a foreign regional carrier (FRC) with no Part 129 certification from the FAA. The distributor was wondering whether the FRC could be "Last Certified Agency" of Block 13C of their ATA-106? The answer to that question depends on whether the FCC has performed a maintenance activity on the part.
The Spec 106 instructions for block 13C very simply say:
"Name the last certificated agency and its certificate number who last performed maintenance on the part."
Although this sentence likely anticipated FAA-certificated agencies (because it was written over 20 years ago by US air carrier representatives), that limitation is not specified in the instructions.
Something that is specified in the instructions is that suppliers of surplus parts that have been inspected shall include a document from a FAA 121, 135, 129 or 145 certificate holder indicating condition. This would be in addition to the Spec 106 form. This is not a regulatory requirement, but it is a requirement of the specification in section 3-7, and it shows us what was considered appropriate when the specification was developed.
Back to our fact pattern; the distributor indicated that the FRC employs certified inspectors. These inspectors perform inspection at the time of receipt (receiving inspection) and issue documentation stating that the part is considered airworthy. Inspection is typically considered a maintenance activity that must be reflected in an approval for return to service or other maintenance release. Typically receiving inspections are not considered to be maintenance activities in their own right, but are part of the maintenance organization's activities. But if receiving inspection is treated as a separate maintenance activity in this FRC, and receiving inspection is documented as such, then this activity could be a maintenance activity performed by a certificated agency.
So now we have to look at what kind of parts are being transacted in this case.
If the parts are new parts that are surplus to the FRC's needs, then the inspectors could inspect them to new condition, issue appropriate approval for return to service verifying that the parts have been inspected to new condition, and then the Spec 106 form could list the FRC as the last certified agency in block 13C. This may be subject to the same section 3-7 caveat mentioned above if the parts are received by a company with a Spec-106 compliance receiving inspection system. But the idea of issuing an air carrier approval for return to service is not a new one. Northwest Airlines used to issue 8130-3 tags for their surplus parts indicating that the parts had been inspected to verify the condition in which they were sold. For new surplus parts, this meant that their new, unused, status has been confirmed. An FRC could use whatever maintenance release form they typically use (such as the ANAC SEGVOO-003, CAAC AAC-038, EASA Form One, TCCA Form One, etc.) in order to document the inspection. They should be careful to describe what inspection was performed in the remarks block of the maintenance release form.
But what if we are talking about parts in 'as removed' condition? In such a case, the FRC could still be the last certificated agency if it performed an activity like an inspection. For example, a post-removal inspection that verifies that the part is unairworthy could be a maintenance activity. In this case the activity would be the inspection, and the unserviceable tag could be the record of the work performed (to meet this requirement, it typically needs to state what work was performed, e.g. the inspection)
Just because the part is not serviceable does not negate the fact that an inspection was performed and documented. But of course, the FRC must have appropriate maintenance capabilities to perform the inspection in question - if they do not (e.g. because all of their maintenance work is performed by contractors) then their 'inspection' might represent unauthorized maintenance - in such a case the maintenance contractor might the appropriate party to perform and document the inspection in question. In that situation, the maintenance contractor may be the last certificated party.
OPPORTUNITY FOR IMPROVEMENT
One of the issues with the Spec 106 form is that the instruction set is not very well suited to non-US operations (it was written for A4A in the 1990s). In today's industry, global operations and global sources of supply have become the norm.
ASA is currently working on proposed revisions to spec 106. We have formed a subcommittee from among our Quality Assurance Committee and that group has been working on proposed changes.
Our work plan, which we've coordinated with IATA and A4A, is that we will next share our proposals with IATA and then ASA and IATA intend to jointly present a set of proposed changes to A4A. Because the ATA specifications belong to A4A, A4A is the final arbiter of any changes to ATA Spec 106.
If you have any interest in participating in this process, then please let ASA know; we are currently working on this project, and plan to have our proposals ready quite soon. We will be briefing the Quality Assurance Committee on progress at the Annual Conference in July, so we would appreciate your input NOW to make sure it is included in the ASA proposal.