Presentation Title Will Appear Here

AS9110 – Revision Status and Training

Reported by: Rick Downs Date of Report: 2011 July

Company Confidential

Team Members Team Leader/AAQG Leader: Jeff Wood (Boeing) APAQG Leader: Azmi Fuadi (Indonesian Aerospace) EAQG Leader: Jean-Francis Suquet (Eurocopter) Team Members: AAQG Representatives: Felipe Reyes (Aveos); Norm Dubay & Dave Hardin (Honeywell); Sidney Vianna (Det Norske Veritas); Bill Frazier (General Electric); Tom Susan (Rockwell Collins); Roger Ritterbeck (QMI – SAI Global);Tracy Parks & Jeff Fiscus (United Technologies); Peter Friedkin (Parker Aerospace); Max Mills (Gulfstream);Mahmoud Chamseddine (Bombardier); Dan Von Flue (Harter Aerospace) EAQG Representatives: David Hope (Rolls-Royce); Julian Temple (BSI); Daniel Albier (certified auditor);Bernhard Schneider (MTU Aero Engines); Stephane Richard (Zodiac Aerospace); Hans-Rainer Ziemer (EADS Defense & Security); Phillippe Poncelin-de-Raucourt (SAFRAN); Flavio Izzo (Alenia Aeronautica)

Company Confidential

Supporting Information • The 9110 certification numbers will most likely increase in a similar fashion (slow, steady increase), but unless there is greater industry recognition (e.g., regulatory authorities, airlines, IAQG member companies) to actively promote and/or mandate certification … no dramatic changes in certification numbers will be made –

We kicked off the MRO Relationship Growth Strategy Stream in October 2008; though there has been a 106% increase in the total number of certificates, it only amounts to an increase of 204 certificates [increase from 192 (Sept. 2008) to 396 (July 2011)]

–

To put this in perspective … in the same time frame 9100 certificates increased by 42%, but that increase amounted to 3903 certificates [increase from 9,159 (Sept. 2008) to 13,063 (July 2011)]

Revision to standard to address industry stakeholder feedback Company Confidential

Limited 9110 Standard Revision • Purpose of the revision –

Incorporate editorial corrections

–

Consider/address stakeholder needs

–

Enhance clarity of requirements to resolve interpretation issues

–

Ensure the standard is compatible for use by all stakeholders

AEROSPACE AEROSPACE STANDARD

9110 Issued Revised

2003-01 Proposed Draft 2010-11-30

Superseding 9110:2009

Quality Management Systems – Requirements for Aviation Maintenance Organizations

RATIONALE

• Proposed revisions – –

Stakeholder feedback/input provided for consideration Recommendations identified from gap/comparison analysis leaders for consideration

This standard has been revised to address stakeholder needs through the addition of definitions and clarification of existing requirements to resolve interpretation issues, and incorporate editorial corrections.

FOREWORD To assure customer satisfaction, aviation and defense organizations must produce, maintain, repair and continually improve, safe, reliable products that meet or exceed customer and applicable statutory and regulatory requirements. The globalization of the industry and the resulting diversity of regional and national requirements and expectations have complicated this objective. Organizations have the challenge of purchasing products from suppliers throughout the world and at all levels of the supply chain. Suppliers have the challenge of delivering products to multiple customers having varying quality requirements and expectations. Industry has established the International Aerospace Quality Group (IAQG), with representatives from companies in the Americas, Asia/Pacific and Europe, to implement initiatives that make significant improvements in quality and reductions in cost throughout the value stream. This standard has been prepared by the IAQG. This document standardizes quality management system requirements to the greatest extent possible and can be used at all levels of the supply chain by organizations around the world. Its use should result in improved quality, schedule and cost performance by the reduction or elimination of organization-unique requirements and wider application of good practice. While primarily developed for the aviation and defense industry, organizations providing maintenance, repair and overhaul services, this standard can also be used in other industry sectors where a quality management system with additional requirements over an ISO 9001 system is needed.

• Initiated revision – April 2010

• Estimated publication date – Oct. 2011

IAQG sector re-ballot of standard to close September 28th, 2011 Company Confidential

Stakeholders Comments on 9110

IAQG 9110 Writing Team 9110 Standard Comments Review Matrix - Stakeholder Feedback Line Number

Stakeholder

9110 Clause No.

Comments / Feedback

1

EASA Regina Hamelijnk

1.1

An important note has been added in as to point out that should there be a conflict between the requirements of this standard and applicable statutory and regulatory requirements, the latter shall take precedence. Therefore, the standard does not need to incorporate all of the rules that are defined in the commonly applicable regulations in the field of aviation maintenance, it is rather meant to complement them.

2

EASA Regina Hamelijnk

1.2

Last §: National Airworthiness Authority (NAA) should read National Aviation Authority.

Proposed Change

Revise the text to: … National Aviation Authority (NAA) …

Justification (e.g., clarification, improve quality, reduce cost, other)

Am end / No action / Forw ard

Comment with no impact; no action required.

No action

26 Nov 09: During the meeting with EASA, we both agreed on the principle that the 9110 describes the detailed requirements of basic QMS supporting Authorities approvals.

Amend

26 Nov 09: Thought process consistent with existing definition for term [National Aviation Authority (NAA)] in IAQG dictionary.

Correction

Notes

Action Complete

X

19 Oct 09: Agreed to remove the exclusion from future revisions. Coordinate with IAQG Dictionary; 9110 text is currently consistent with the IAQG Dictionary - forward revised wording.

3

EASA Regina Hamelijnk

3.1

EAQG MRO team proposes: Article does not include standard or commercial Any component installed or to be installed on aircraft, engine, parts. Why have these been excluded from the etc. which is listed by the responsible design approval holder Clarification definition? as eligible for installation (e.g., complete engine/APU, propeller, operational/emergency equipment, appliance, part).

4

MTU Comment

3.2

Slight adjust of text to present a more accurate representation.

Correction

Amend

5

EASA Regina Hamelijnk

3.4

EAQG MRO team proposes to add the following: Critical items seems to be a new concept, it … Examples of critical items include safety critical items, may need to be explained more in detail (critical fracture critical items, mission critical items, key tasks, critical parts). characteristics, critical maintenance tasks, etc.

Enhancement

Amend

6

EASA Karl Specht

3.4

Definition of critical items is not sufficient in terms of FMEA.

Clarification

7

EASA Regina Hamelijnk

8

EASA Karl Specht

EAQG MRO team proposes to revise the following: The aviation authority having jurisdiction over the manufacturer, aircraft owner/operator and or maintenance organization; the Authority could be civil or military.

16 Nov 10: Amend Agreed. Moreover "product" is removed in the first part of teh Forward sentence (refer to line 9.a). The IAQG MRO team proposes the following: Article Material, part, product, component, assembly, or appliance which is listed by the design organization as eligible for installation in product or included in the design data approved by the Authority.

14 June 10: Agreed.

19 Oct 09: We propose to provide EASA with further explanations based on SCMH, 9101, 9100 FAQ, and 9100 revision summary content.

• Compilation of the stakeholders comments; majority of feedback/comments originated from EASA

26 Nov 09: Further to the discussion with EASA, we recommend adding "critical maintenance tasks" in the listing of examples. 9 Nov 10: The IAQG MRO team proposes to change this wording into "maintenance tasks critical for safety" which is self explanatory and does not need examples: ...Examples of critical items include safety and fracture critical items, key characteristics, maintenance tasks critical for safety .

19 Oct 09: No action This is a general definition of critical items; it is not meant to be connected to FMEA. This has been agreed by EASA.

X

19 Oct 09: Both terms are correct. "Suspect unapproved parts" is commonly used within the industry. We will nevertheless coordinate with the other IAQG standards teams to evaluate the proposed change. Revise the text to: Suspect ed Unapproved Part

3.12

Term should read: Suspected unapproved parts.

3.13

When talking about technical data the term approved technical data should be used (or defined additionally), because this is the main difference to a general technical publication.

NOTE: This revision will drive changes throughout the standard, wherever the term is utilized.

Consistency

26 Nov 09: Amend EASA accepts both terms; both terms are also used by Forward FAA. Nevertheless, the EAQG MRO team recommends the term "Suspected", which is consistent with the terminology used in the 9120 standard; revised from initial publication. 18 Oct 10: IAQG MRO team agrees. Forward revised term/definition to IAQG Dictionary.

EAQG MRO team proposes adding the following: Adding the following sentence to the end of the existing definition: ... Technical data is approved by or on behalf of the Authority.

26 Nov 09: The EAQG MRO team proposes to split sentence and separately explain the way technical data is approved. Enhancement

Amend

9 Nov 10: Agreed. The IAQG MRO team proposes the following: Technical data shall be acceptable to the Authority or approved by the Authority, if applicable . 19 Oct 09: The term "Component" is covered by the definition of "article". No change is necessary.

9.a

EASA Regina Hamelijnk

3. Terms and definitions (General)

The following should be added to the definitions: * Component

Clarification

Amend

9.b

EASA Regina Hamelijnk

3. Terms and definitions (General)

* Certifying staff

The EAQG MRO team proposes adding the following definitions: Certifying Staff Personnel responsible for the release of an aircraft or an article after maintenance.

Clarification

Amend

9.c

EASA Regina Hamelijnk

3. Terms and definitions (General)

* Certified personnel

The EAQG MRO team proposes the following definitions: Certified Personnel Personnel qualified by an external/internal competent body and authorized in accordance with a company process to carry out special tasks (e.g., non-destructive testing certified personnel, licensed maintenance personnel).

Clarification

Amend

9.d

EASA Regina Hamelijnk

3. Terms and definitions (General)

* Risk management

16 Nov 10: The definition of article is amended as follows: article material, part, product, component, assembly, or appliance which is listed by the design organization as eligible for installation in product or included in the design data approved by the Authority. 19 Oct 09: Need to develop definition for this term. 18 Oct 10: Agreed. The IAQG MRO team proposes the following: Certifying Staff Personnel authorized by the maintenance organization to sign the release certificate for an aircraft or article after maintenance. 19 Oct 09: Need to develop definition for this term.

Clarification

18 Oct 10: Agreed. The IAQG MRO team proposes the following: Certified Personnel Personnel qualified by an external/internal competent body to carry out special tasks (e.g., non-destructive testing certified personnel, licensed maintenance personnel).

19 Oct 09: Agreed. Forward We will coordinate with other IAQG teams to develop definition of Risk Management; forward definition to IAQG Dictionary.

19 Oct 09: We will develop definition for "Return to service / certification for return to service" on the basis of Part 145.A.50(a): (a) A certificate of release to service shall be issued by appropriately authorised certifying staff on behalf of the organisation when it has been verified that all maintenance ordered Clarification has been properly carried out by the organisation in accordance with the procedures specified in 145.A.70, taking into account the availability and use of the maintenance data specified in 145.A.45 and that there are no non-compliances which are known that hazard seriously the flight safety.

Amend

Clarification

Amend

The EAQG MRO team first proposed the following definitions: Continuing Airworthiness All of the processes ensuring that, at any time in its operating Clarification life, the aircraft complies with the airworthiness requirements in force and is in a condition for safe operation.

Amend

18 Oct 10: Agreed. The IAQG MRO team proposes to complement the definition of the Release Certificate. 3.8 release certificate document attesting that a product is released for use (return to service) and/or certifying that the activities performed, and the results achieved, conform to established organization, authority and contract requirements.

9.e

EASA Regina Hamelijnk

3. Terms and definitions (General)

* Return to service/certification for return to service

9.f

EASA Regina Hamelijnk

3. Terms and definitions (General)

* Serviceability (term used in clause 3.13)

9.g

EASA Regina Hamelijnk

3. Terms and definitions (General)

* Airworthy [used in 7.1.(f)]

9.h

EASA Regina Hamelijnk

3. Terms and definitions (General)

* Data approval holder [used in 7.5.1(h)]

Clarification

Amend

9.i

EASA Regina Hamelijnk

3. Terms and definitions (General)

* Approved design organisation [used in 7.5.1(h)]

Clarification

No action

10

EASA Regina Hamelijnk

4.2.1

Clarification

18 Oct 10: The IAQG MRO team agreed it is premature to add the No action NOTE at this time. Consideration to be given during a future revision … quality policy and safety policy should be aligned, not conflicting, complementary, etc.

19 Oct 09: Need to develop definition for this term.

• Final review/disposition of comments done at recent IAQG meeting in York, UK by the IAQG MRO Relationship Growth Strategy Stream • Disposition of (62) stakeholder comments:

7 May 10: Proposed definition developed by EAQG MRO Team.

(38) items are “amending” the 9110 standard (limited’ revision), among which (3) comments are also “forward” to other IAQG teams (i.e., IAQG Dictionary, 9100 team)

18 Oct 10: Refer to the line 9.f above. The IAQG MRO team considers that Continuing Airworthiness is already (implicitly) defined in regulations. 25 Nov 10: The IAQG MRO team finally agrees on adding the proposed definition of "airworthy": 3.x Airworthy Assurance that the aircraft or article conforms to the type design and is in a condition for safe operation. 18 Oct 10: The IAQG MRO team proposes to modify the clause 7.5.1.h as follows: h) evidence that all maintenance and inspection/verification operations have been completed as planned in accordance with technical data that has been approved, as applicable, by the design data approval holder, an approved design organization or that is acceptable to the Authority; 16 Nov 10: The definition to the term "Data approval holder" is not required as the term is no longer used further to above revision the text associated to clause 7.5.1.h.

Link between quality policy and safety policy should be explained more in detail.

12 Feb 10: EAQG MRO team agreed on adding a NOTE to clarify. NOTE: The safety policy is associated to the quality policy.

18 Oct 10: Refer to the above line.

X

X

15 Dec 09: EAQG MRO team believes that an MRO specific item associated to technical data be added to the listing.

11

EASA Regina Hamelijnk

4.2.3 7.2.2

Should be more specific in relation to technical data.

Propose the following revisions: Add NOTE after clause 4.2.3 first paragraph ("Documents required by the quality management system …".). NOTE Documents include technical data used to carry out maintenance. Clarification

Amend

Add supporting text to the clause 7.2.2, possibly after item e. The organization must use technical data at the contractually specified revision or at the latest revision, if not specified.

12

EASA Regina Hamelijnk

5.3

13

EASA Regina Hamelijnk

5.5.2(d)

14

EASA Karl Specht

5.6.1

15

EASA Regina Hamelijnk

5.6.2

16

EASA Regina Hamelijnk

5.7 (e)

17

EASA Karl Specht

18

EASA Regina Hamelijnk

Link between quality policy and safety policy should be explained more in detail. How to avoid conflicts between both aspects? They should not be seen as disconnected elements of the management system. As written, it seems as if Refer to line 10. safety policy and objectives are adding another layer, without taking into account the need for a common approach to manage quality and safety.

Clarification

Add: … to resolve safety issues.

EAQG MRO team proposes to add the following: the organizational freedom and unrestricted access to top management to resolve quality management and safety issues.

Enhancement

Is double (content).

Eliminate redundant content.

Clarification

18 Oct 10: Agreed. The IAQG MRO team proposes the following revisions to clauses 4.2.3 and 7.2.2: - Add a NOTE after clause 4.2.3 first paragraph ("Documents required by the quality management system …".). NOTE Documents include technical data used to carry out maintenance. - Add supporting text to the clause 7.2.2. The organization must use technical data at the contractually specified revision or at the latest revision, if not specified.

18 Oct 10: Refer to line 10. The IAQG MRO team agreed it is premature to add further No action clarification at this time. Consideration to be given during a future revision … quality policy and safety policy should be aligned, not conflicting, complementary, etc.

Amend

X

19 Oct 09: We agree on the concept but we have to determine if this is the responsibility of the Management Representative or the Accountable Manager or the Safety Manager. 14 Jun 10: Agreed to add for the management representative “to resolve safety issues"

Add risk assessment as an input to the management review.

EAQG MRO team proposes to add the following item to the listing: Enhancement x) results of risk assessments

Change "continuing" to "continued".

Revise the wording as follows: e) is reviewed for continued suitability.

No action

19 Oct 09: The second sentence deals with the safety policy/safety objectives instead of quality policy/quality objectives. The 9110 standard is based on the ISO 9001 format and additions are introduced as separate sentences/requirements.

X

18 Oct 10: The IAQG MRO team agrees with the general principle. As this revision (as proposed) is not MRO specific, we propose to add the following item in clause 5.6.2: h) product safety The addition of "product safety" as a review input would be appropriate and more maintenance specific (link to safety Amend policy/objectives) and would indirectly include associated Forward risk assessments. Note 1: This item is placed after existing ISO 9001 content g) - existing bold italic text will directly follow this item … i), j), and k) respectfully. Note 2: Forward this item (results of risks assessments as an input to the management review) for future consideration to the 9100 team.

6.1

6.2.1

Is missing facilities and materials.

Personnel required to be certificated: should be explained or covered by a definition. In 6.2.2.(f), the term used is “certified”: standardise terminology (certificated versus certified).

Preference

EAQG MRO team proposes to add the following: The organization shall have a system to continually assess the availability of tools, technical data , facilities, materials and Enhancement necessary qualified personnel to ensure the safe completion of the maintenance, repair and overhaul activities. EAQG MRO team proposes to revise the following: The organization shall ensure personnel required to be certified meet and maintain the applicable eligibility Authority requirements. A process shall exist for the qualification and surveillance of non-certified personnel who Enhancement perform maintenance, repair and overhaul services.

No action

19 Oct 09: We used the same wording (context) for the review of the Safety Policy to be consistent with the ISO text for the review of the Quality Policy (see clause 5.3.e) ... ISO mentions that the Quality Policy "is reviewed for continuing suitability".

Amend

19 Oct 09: Agreed.

Amend

10 Oct 10: Agreed. Refer to line 9.c (added definition of certified personnel).

X

NOTE Non-certified personnel shall be assessed on their ability to satisfactorily carry out maintenance, repair and overhaul operations prior to performing the work.

6.2.1 (see clause Personnel requirements certificated/non3.0 - terms and certificated should be defined more clearly. definitions above)

19

EASA Karl Specht

20

EASA Regina Hamelijnk

21

EASA Regina Hamelijnk

22

EASA Karl Specht

23

EASA Regina Hamelijnk

7.1

24

EASA Regina Hamelijnk

7.1.2

25

EASA Karl Specht

7.1.2

EAQG MRO team proposed to add the following definitions: Certified Personnel Personnel qualified by an external/internal competent body and authorized in accordance with a company process to carry out special tasks (e.g., non-destructive testing certified personnel, licensed maintenance personnel).

10 Oct 10: Agreed. Refer to line 9.c (added definition of certified personnel). Clarification

Amend

Certifying Staff Personnel responsible for the release of an aircraft or a component after maintenance.

6.2.2 (f)

Add: "qualified and certified in accordance with design approval holder requirements, as applicable".

EAQG MRO team proposes to add the following: ensure that personnel performing maintenance, repair and overhaul services and release of articles are qualified and certified in accordance with applicable organization, design approval holder, Authority, and customer contract requirements.

Enhancement

6.4

Add something on the need to consider human factors.

EAQG MRO team proposes to add the following: The work environment shall take into account human factors and human performance to ensure good maintenance practices and enhance the effectiveness of personnel.

Enhancement

In general replace “and/or authority” by “and authority” .

Replace all references to "and/or authority" to "and authority".

Preference

The terms ”maintainability” § “producibility” are not clear. Producibility does not seem to be relevant in the case of maintenance.

EAQG MRO team proposes to revise the following: producibility ability to effectively conduct the prescribed maintenance tasks and inspectability,

Clarification

7. (In General)

The EAQG MRO team proposes to add the following: A link with the management review process - in § 5.6.2 should be made, as to ensure that the efficiency h) results of risk assessments, and effectiveness of the risk management - in § 8.5.3 process is assessed as part of the management g) evaluating the need for action based on the results of risk review. assessments .

Amend

X

9 Nov 10: Agreed. The IAQG MRO team proposes to add the following: The work environment shall give consideration to human factors and human performance and must ensure that the effectiveness of personnel is not unduly impaired.

19 Oct 09: No action The intent is the same. The text "and/or" is to address non-certified maintenance organizations.

X

12 Feb 10: Agreed to provide clarification of "maintainability" and to replace "producibility" by "ability to carry out the prescribed maintenance tasks". Amend

18 Oct 10: Agreed. The IAQG MRO team proposes to add the following: producibility ability to effectively conduct the prescribed maintenance tasks and inspectability,

19 Oct 09: Agree on the concept. We will provide further clarification. Need to coordinate within IAQG. Enhancement / Clarification

A link to “preventive actions” (§ 8.5.3) should be added, i.e. the difference (if any) between risk mitigation actions and preventive actions should be made clear.

The term risk management sounds out of place when talking about maintenance, because no risks should be taken when working on aircraft.

NOTE: Revisit/revise the usage of the term 'certificated/non-certificated' to 'certified/non-certified' throughout; will require a change to the following paragraphs - § 1.2, § 6.2.1 (including associated NOTE), and § 7.4.1.

18 Oct 10: No action The IAQG MRO team considers that the design data holder requirements are implicitly covered in the contract.

The scope of risk management should not be limited with regards to the achievement of applicable requirements. It should also consider the quality and safety objectives of the organisation (conformity is not enough).

–

18 Oct 10: Agreed. The IAQG MRO team proposes to remove the term "serviceability" from the definition of Technical Data: 3.13 technical data data that is necessary to ensure that the aircraft or aircraft component article can be maintained in a condition such that serviceability and continuing airworthiness of the aircraft and related operational and emergency equipment is assured.

Clarification

Forward 18 Oct 10: The IAQG MRO team agrees with the general principle, but this revision is not MRO specific. We will forward the proposed addition to the 9100 team for consideration in a future revision.

No action

19 Oct 09: We disagree. Risk management is an integral part of a Safety Management System (SMS) to evaluate potential occurrences of unsafe conditions. This text will be extremely useful as organizations implement a SMS; currently this text is an independent process ... an additional element/principle of SMS introduced in this version of the standard.

X

X

26 Nov 09: EASA agreed on the risk management set up in the scope of SMS. 15 Dec 09: Configuration control in maintenance means that articles must meet the applicable technical data, including any SB and AD.

Configuration status accounting not clear: does it refer to record keeping or accountability?

EAQG MRO team proposes to add the following: NOTE Configuration control in maintenance is focused on ensuring that articles comply with applicable technical data, including any associated service bulletins or airworthiness directives.

Control of work transfers has to be done in compliance with applicable authority requirements (missing).

EAQG MRO team proposes to add the following: The organization shall establish, implement and maintain a process to plan and control the temporary or permanent transfer of work (e.g., from one organization facility to another, from the organization to a supplier, from one Enhancement supplier to another supplier) and to verify the conformity of the work to requirements. The organization shall only transfer work to suppliers that hold the required approvals and certificates.

26

EASA Regina Hamelijnk

27

EASA Karl Specht

28

EASA Regina Hamelijnk

7.3

There is too much emphasis on design and development activities, which are normally not the core activity of a maintenance organisation. The standard should be further customised to address the specifics of maintenance more in detail. There is an imbalance between the portions dealing with design and development and those dealing with process control, where specific aspects related to aviation maintenance could be addressed more in detail.

Clarification

No action

29

EASA Karl Specht

7.3

Is not applicable to MRO because this is connected to a Part 21 design approval and should be clearly separated.

Clarification

19 Oct 09: We recognize that activities dealing with design data approval and continuing airworthiness management are No action addressed by other EASA regulations, but we still want to cover in the 9110 standard applicable to maintenance organizations the approval of repairs, design alterations and STC as well as maintenance programmes.

X

30

EASA Regina Hamelijnk

7.3.1

Add: verification that the required authorisation/certification for the design activity has been obtained from the Authority.

Clarification

19 Oct 09: We believe that this is already addressed in the following bold italic text within 7.3.1: No action The different design and development tasks to be carried out shall be based on the safety and functional objectives of the product in accordance with customer, statutory and regulatory requirements.

X

31

EASA Regina Hamelijnk

7.3.3

More emphasis on technical data.

7.1.3 (d)

7.1.4

Clarification

Amend

Amend

18 Oct10: Agreed. The IAQG MRO team proposes to add the following after the NOTE: Configuration management provides identification and traceability, the status of achievement of its physical and functional requirements, and access to accurate information during all phases of the life cycle. 18 Oct 10: Agreed. The IAQG MRO team proposes to add the following sentence: The organization shall establish, implement and maintain a process to plan and control the temporary or permanent transfer of work (e.g., from one organization facility to another, from the organization to a supplier, from one supplier to another supplier) and to verify the conformity of the work to requirements. The organization shall only transfer work in a manner acceptable to the applicable Authorities. 19 Oct 09: Refer to comments above (§ 1.2) of 9110 allowing exclusions as long as they are limited to clause 7. "Where exclusions are made, claims of conformity to this International Standard are not acceptable unless these exclusions are limited to requirements within Clause 7, and such exclusions do not affect the organization's ability, or responsibility, to provide product that meets customer and applicable statutory and regulatory requirements." Nevertheless, we agree to add a clarification that the depth of the design project is to be adapted to the complexity/criticality of the task.

X

15 Dec 09: The IAQG has approved the request to provide visibility within the Supply Chain Management Handbook (SCMH) on the applicability of this clause (Design and Development) as it applies to MRO organizations.

EAQG MRO team proposes to add the following: The organization shall define the data required to allow the product to be identified, manufactured, inspected, used and maintained; including for example - the drawings, part lists and specifications necessary to define the configuration and the design features of the Enhancement product, - the material, process, manufacturing and assembly data needed to ensure conformity of the product, and - the technical data (e.g., technical publications, maintenance program) to ensure continuing airworthiness.

32

EASA Regina Hamelijnk

7.4.1

4th paragraph: “select suppliers…. In accordance with the organisation’s requirements”: add “and with regulatory and statutory requirements, as applicable”.

33

EASA Regina Hamelijnk

7.4.1

A distinction should be made for suppliers being certified/authorised and suppliers performing EAQG MRO team proposes to add the following: work under the quality system of the When using non-certified suppliers, the maintenance Enhancement organisation. The supplier selection and organization shall contractually specify the applicable quality monitoring procedures have to be adapted to system requirements. reflect those two cases.

34

EASA Regina Hamelijnk

7.4.2 (k)

35

EASA Regina Hamelijnk

7.4.3

Clarification

Organisation’s release documentation package: EAQG MRO team proposes to revise the following: should it read” supplier’s release documentation format and content of the supplier’s release documentation package? package, and 5th paragraph: Where the organisation delegates verification activities to the supplier, the requirements for delegation shall be defined and a register of delegations maintained. Here again, a distinction should be made for suppliers being certified/authorised and suppliers performing work under the quality system of the organisation.

Correction

Enhancement

Forward

19 Oct 09: Agreed on the concept, but we propose to potentially add further definition regarding technical data requirements/expectations in the § 7.3.3 dealing with the design outputs.

X

18 Oct 10: The IAQG MRO team considers that this is not maintenance specific. We will forward the proposed amendment to the 9100 team. 19 Oct 09: This is ISO text that we cannot change. We have already the concept in the following 9110 added text: The organization shall ensure that suppliers hold the No action required approvals and certificates. Additionally, the organization’s purchasing process shall satisfy applicable Authority requirements pertaining to the use of non-certificated suppliers.

X

18 Oct 10: The IAQG MRO team considers that the concern is addressed in the following existing text: No action Additionally, the organization’s purchasing process shall satisfy applicable Authority requirements pertaining to the use of non-certified non-certificated suppliers.

X

Amend

No action

19 Oct 09: Agreed to change.

26 Nov 09: Delegation is one option when working with non-certificated suppliers; develop proposed text.

X

2 Feb 10: We finally concluded that the revision is not necessary.

It should be made clear that any delegation of such requirements must conform to statutory and regulatory requirements.

36

EASA Karl Specht

7.5.1 (g)

Something is missing.

37

EASA Regina Hamelijnk

7.5.1 (o)

Replace “manufacturer” by “approved design organisation”.

38

EASA Regina Hamelijnk

7.5.1.1

39

EASA Regina Hamelijnk

40

MTU Comment

41

EASA Regina Hamelijnk

7.5.4

42

EASA Regina Hamelijnk

7.6

Something should be added with regards to the need to consider applicable data and instructions defined by the approved design organisation.

43

EASA Regina Hamelijnk

7.6 (a)

“….; where no such standards exist, the basis used for calibration or verification shall be recorded..;” add: “and approved by the Authority prior to its use.”

44

EASA Karl Specht

Correction

Amend

Clarification

Amend

It is not clear what is meant with “new maintenance processes”. Does this address tasks which have not been previously performed EAQG MRO team proposes to revise the following: by the organisation and for which it first needs to First application of maintenance processes by the qualify or does it refer to new processes Clarification organisation shall be documented, qualified and approved by developed by the organisation? In the latter the customer and/or Authority , if applicable . case, it should be explained how these new processes will need to be approved as applicable by the approved design organisation.

Amend

Something should be added with regards to the need to consider applicable data and instructions defined by the approved design organisation.

Clarification

Amend

Correction

Amend

Published version of EN9110 was missing part of the standard text; ASD-STAN has already addressed this item.

X

19 Oct 09: Agreed.

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(3) items are “forward” to other 9100 IAQG teams for future consideration

EAQG MRO team proposes to revise the following: the equipment, tools and materials shall be those recommended by the approved design organization of the article or must be at least equivalent to those recommended by the approved design organization and acceptable to the customer and/or Authority.

15 Oct 10: Replace “approved design organization ” by “design approval holder ” . 18 Oct 10: The IAQG MRO team agrees on the following text: the equipment, tools and materials shall be those recommended by the design approval holder of the article or must be at least equivalent to those recommended by the design approval holder and acceptable to the customer and/or Authority. 19 Oct 09: Agreed. The sentence covers both cases. Proposed added text: 26 Nov 09: The EAQG MRO team proposes to replace "New maintenance processes" to "First application of maintenance processes by the organisation." 18 Oct 10: Agreed. The IAQG MRO team proposes the following data: First application of new maintenance processes by the organisation shall be documented, qualified , and approved by the customer and/or Authority, if applicable . 19 Oct 09: Agreed. A clarifying statement should possibly be added.

7.5.2

7.5.3 NOTE

EAQG MRO team proposes to add the following: Special processes shall comply with the requirements of the applicable technical data.

Remove the following text - "maintenance, Remove the following text: repair, modification, inspection/verification" … … a product, a sequential record of its maintenance these items are already addressed by the (maintenance, repair, modification, inspection/verification) definition of the term "Maintenance" (see clause to be retrievable. 3.7).

18 Oct 10: Agreed. The IAQG MRO team proposes the following text after the NOTE: Special processes shall comply with the requirements of the applicable technical data issued by the design approval holder.

4 June 10: Agreed.

15 Oct 09: IAQG Request for Further Clarification: Agreed. Since the 9110 standard is based on ISO text that we cannot reword, we could only add a note. The note could be "Customer property would include articles going through maintenance", but we think that this note would bring no benefit. Please provide further clarification.

EAQG MRO team proposes to add the following NOTE: Customer property: This paragraph should be reworded, as to reflect that in the case of NOTE: Customer property includes articles being maintained, maintenance, the product itself is customer repaired, and/or overhauled, in addition to any other Clarification property. This is different from the manufacturing articles provided by the customer in support of these environment, where the product remains the activities (e.g., replacement hardware, tooling, property of the organisation until it is sold. containers, protective devices).

Amend

EAQG MRO team proposes to revise the following: The organization shall maintain a register of the monitoring and measuring equipment and define the process employed for their calibration/verification including details of Clarification equipment type, unique identification, location, frequency of checks, check method and acceptance criteria, in accordance with applicable technical data.

Amend

16 Oct 09: EASA Reply: We understand that no changes to the elements based on ISO text can be made, so the note to be added may explain that customer property usually includes articles going through maintenance, in addition to any other articles provided by the customer in conjunction with and for the duration of such maintenance (such as containers, protective devices, etc.). As this type of property is generally not addressed in maintenance regulations, the ISO requirements would bring additional “value”. 19 Oct 09: Agreed. 18 Oct 10: The IAQG MRO team proposes to add the following NOTE: NOTE Customer property can include aircraft and articles being maintained, in addition to any other items provided by the customer in support of these activities (e.g., replacement hardware, tooling, containers, protective devices).

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(21) items need “no action”: e.g., clarification, comment on ISO text, topic already addressed in another clause, …

19 Oct 09: Agreed.

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EASA Regina Hamelijnk

15 Oct 09: IAQG Request for Further Clarification: We don't see that this being relevant for maintenance organisations which are working according to the technical data issued by the approved design organisation. Please provide further clarification. We cannot reword ISO text, so, if necessary, provide the additional statement.

Clarification

No action

19 Oct 09: This is mentioned/addressed through 2 clauses: - § 5.5.2.b specifies that the management representative reports "to top management on the performance of the QMS". - § 5.6.2.a specifies that "the input to management review shall include information on results of audits".

X

Clarification

No action

19 Oct 09: Disagree. - The 9110 standard does cover design activities, reference § 7.3. - Provisions related to risk management are addressed in § 7.1.2 which includes requirements about risk identification and assessments.

X

16 Oct 09: EASA Reply: We accept your reply and withdraw our comment. The requirement for authority approval is specific to Part 145. As 9110 will be complementary to that for Part 145 approved organisations, we can consider that this will be covered.

The text added after the NOTE seems to be more appropriate for design organisations than in the case of maintenance. This may be the right place to provide further guidance on risk assessment techniques (hazard identification, risk probability and severity) and/or on reliability monitoring as related to maintenance.

19 Oct 09: Agreed.

46

EASA Regina Hamelijnk

8.2.1

Plans for customer satisfaction improvement: add that these must also take into account the safety objectives, i.e. “actions decided to improve customer satisfaction shall not be detrimental to the safety objectives.”

Add something on reliability monitoring as related to maintenance.

EAQG MRO team proposes to add the following NOTE: NOTE: Actions decided to improve customer satisfaction shall be consistent with the safety policy and the safety objectives.

12 Feb 10: We decided to address the issue with a supporting NOTE. Enhancement

Amend 18 Oct 10: The IAQG MRO team agrees on the following requirement at the end of the paragraph: These plans shall be consistent with the organization's safety policy and safety objectives.

EAQG MRO team proposes to revise the following: evaluate whether the process nonconformity has resulted in a Enhancement product nonconformity or potential reliability issue ,

47

EASA Regina Hamelijnk

8.2.3

48

EASA Regina Hamelijnk

8.2.4 (b)

49

EASA Regina Hamelijnk

8.2.4

50

EASA Karl Specht

51

EASA Regina Hamelijnk

8.3

§ after (e): the term used: is “organisation responsible for design”. In § 7.5.1(h) the term used is “Approved design organisation”: Ensure consistency.

EAQG MRO team proposes to revise the following: Dispositions of use-as-is or repair shall only be used after approval by an authorized representative of the approved design organisation .

Clarification

Amend

52

EASA Regina Hamelijnk

8.3

“Product dispositioned for scrap….”: add: “if specifically authorised by the customer”. The use of “disposition” as a verb does not seem to be correct English.

EAQG MRO team proposes to revise the following: “Product dispositioned for scrap shall be conspicuously and permanently marked, or positively controlled, until physically Clarification rendered unusable. The maintenance organization shall not scrap customer property unless specifically authorized by the customer. ”

Amend

53

EASA Karl Specht

To my knowledge such authority is not delegated to maintenance staff.

Refer to Line 51

Clarification

Amend

54

EASA Regina Hamelijnk

Continual improvement: The link with § 7.1.2 “Risk Management” and with § 5.7 “Safety Policy” should be explained.

EAQG MRO team proposes to revise the following: NOTE Continual improvement opportunities can result from lessons learned, problem resolutions, risk mitigation, and the benchmarking of best practices.

Enhancement

Amend

Amend

19 Oct 09: Agreed. Both texts are consistent. Please clarify your concern.

Page 32: item (b) under the first paragraph on this page does not match the text of this first paragraph.

Clarification

No action 19 Oct 09: The first paragraph is ISO text. The other lines [b)] under the second paragraph is aerospace supplemental text.

Company Confidential

X

19 Oct 09: Agree.

8.2.4 (e)

Page 32: second paragraph after list (a-e): it should be added that sampling inspection shall EAQG MRO team proposes to add the following: only be used if compatible with the When the organization uses sampling inspection as a means data/instructions provided by the design approval of product acceptance, the sampling plan shall be justified on holder. the basis of recognized statistical principles and appropriate Clarification for use (i.e., matching the sampling plan to the criticality of If “product” used in this § refers to the aircraft or the product and to the process capability). Sampling component maintained, the cases where such inspection shall only be used if compatible with the technical sampling would be acceptable seem to be very data/instructions provided by the design approval holder. limited.

There should be no sampling in maintenance except as foreseen in TC holder manuals.

Clarification

Amend

20 Oct 10: The IAQG MRO team proposes to delete the paragraph dealing with sampling. Sampling inspection shall only be used if compatible with the technical data/instructions provided by the design approval holder. When used the organization uses sampling inspection as a means of product acceptance, the sampling plan shall be justified on the basis of recognized statistical principles and appropriate for use (i.e., matching the sampling plan to the criticality of the product and to the process capability).

19 Oct 09: We agree that the maintenance organisation shall comply No action with the TC holders manuals, but there are situations where the manuals do not specify the inspection requirements (e.g., riveting inspection for airframe maintenance). 19 Oct 09: Agree.

This input drove the revision of the standard

X

No action

Quality monitoring. I am missing the regular

8. reporting of audit findings to the accountable (In General) manager.

8.1

18 Oct 10: The IAQG MRO team proposes to add the following text: The organization shall determine the monitoring and measurement to be undertaken and the monitoring and measuring equipment needed to provide evidence of conformity of product to determined requirements. The selection of monitoring and measuring equipment and the method of calibration/verification shall comply with applicable technical data or be demonstrated as equivalent.

Enhancement

8.3 NOTE 3

8.5.1

9 Nov 10: The IAQG MRO team proposes the following: Dispositions of use-as-is or repair shall only be used after approval by an authorized representative of the organization responsible for design approved design organisation . 19 Oct 09: First comment - agreed. Second comment - disagree. "Disposition" is a widely used term to indicate the decision to process non-compliant items (e.g., rework to bring to conformity, repair, use-as-is, scrap). 18 Oct 10: The IAQG MRO team proposes the following: The organisation shall not scrap customer property unless specifically authorized by the customer. Product dispositioned for scrap shall be conspicuously and permanently marked, or positively controlled, until physically rendered unusable.

Refer to Line 51.

19 Oct 09: Agreed, proposed text to add the link with Risk Management. The continual improvement as it relates to the safety policy is already addressed in § 5.7.b and c. 18 Oct10: The IAQG MRO agrees on the proposed text. NOTE Continual improvement opportunities can result from lessons learned, problem resolutions, risk mitigation, and the benchmarking of best practices.

X

Supporting Information • 9110 Standard Revision Report – Ballot Results  AAQG/AAQSC ballot closed (02/08/11) 

19 - Approved (37 comments provided)



0 - Disapproved



1 - Waived

 APAQG ballot closed (04/09/11) 

Approved (7 comments provided)

 EAQG ballot closed (05/08/11) 

9 - Approved (56 comments provided)



1 - Disapproved (77 comments provided)



2 - Waived

These results and associated resolution required re-ballot of the standard Company Confidential

Expected Training Update • Based on the revisions made we anticipate that a self

study guide will be distributed to those already completing the 9110 AATT course. In addition, the AATT course will be updated going forward.

• This is tentative, a final decision will be made once the

standard is published.

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Questions?

Company Confidential

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