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.