Is It Manufacturing or Is It Maintenance?

Is It Manufacturing Or Is It Maintenance? It’s all in the certification By Brian Whitehead February 2001 Manufacturing and maintenance have a lot in common. Many of the same tasks and procedures exist in both environments...

Fabricated parts
Where parts are fabricated, they must conform to the applicable data. This may be the original manufacturer’s specifications, or alternative data approved by STC or RDA. Locally-made parts must be clearly distinguishable from the original manufacturer’s parts. Typically, the same person will both fabricate and install the part, but single element items that are 100 percent inspectable may be made by one person and installed by another. The maintenance release for the installation also covers the making of the part, so the AME signing the release assumes responsibility for the entire job.
Where an AMO makes more complex items (let’s say a mod kit, made in accordance with an STC), it may be permissible for several individuals to take part in the fabrication, recording their actions on job cards. Each entry may constitute a partial maintenance release, with the final release being made by the AME responsible for the installation. The AME signing the final release is then responsible only for the actual installation, and can rely on the partial releases of the individual SCA holders for their portions of the work. It is important to understand that such a system is only acceptable when the part is both fabricated and installed by the same organization. It is suitable for organizations maintaining their own aircraft, and also for those providing "one stop shopping" for clients who bring aircraft in for repair or modification.

Repair parts provision has limits
What if an organization wants to make kits for installation by others? Well, that’s where we reach the limits of the "repair parts" provision. CAR 571.11 requires anyone signing a maintenance release to "personally observe the work," so they may only assume responsibility for parts made by others if the parts are 100 percent inspectable. Items like our mod kit example do not meet that criterion, so a separate certification is needed. A maintenance release won’t do, because the only actual maintenance being done is the installation, so the only thing left is a statement of conformity. And the only way to get the authority for that, is to obtain a CAR 561 manufacturing approval.
So, there we have it. Some things may only be done by manufacturers, some things only by maintainers, and some things by both. The main distinguishing feature is the certification used. If you have to make a part, and you do not hold a manufacturing approval, certifying the part itself is out of the question, so you must certify the entire job by issuing a maintenance release for the installation. To do that, you must be able to show compliance with all the applicable maintenance regulations, including those dealing with engineering data, record keeping, and product identification.

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