Authorized release certificate for new parts

[qa guy]

Can a company create their own release tag for a part? ie: radio.
I used to know an avionics guy who said he can do that within the company. (no manufacturing cert.)
I have spent exhausting hrs. reading the CARS and do not see how this is
possible without a manufacturing certificate. It is quite clear to me in the regs that approval documentation of some type is required. Why would anyone else pay so much for the the
release tag if you could?
Also, could you simply greentag it as a serviceable used part? I know its common with
parts when they sit in quarentine?
Any positive feedback is greatly appreciated.

[azimuthaviation]

If theyre an AMO why can't they?

[GreenGrass]

Follow up to my previous question: would the documentation be similar for the US and Canada?

[qa guy]

Installation of New Parts

571.07 (1) No person shall install a new part on an aeronautical product unless the part meets the standards of airworthiness applicable to the installation of new parts and, subject to subsections (2) and (3), has been certified under Subpart 61.
(amended 2007/12/01; previous version)

571.07 (1) No person shall install a new part on an aeronautical product unless the part meets the standards of airworthiness applicable to the installation of new parts and, subject to subsections (2) and (3), has been certified under Subpart 61.
(amended 2007/12/01; previous version)

(2) No certification referred to in subsection (1) is required where

(a) a new part is a foreign-manufactured part that is certified pursuant to an agreement with Canada, which agreement provides for the acceptance of export airworthiness certification;

(b) a new part is a foreign-manufactured part that is obtained from a manufacturer holding a type design recognized in Canada and the part is certified in accordance with the laws of the state of manufacture;

(c) a new part, whose accompanying documentation has been verified, has been inspected in accordance with the requirements of Chapter 571 of the Airworthiness Manual;

(d) a new part is installed on an aircraft that is operated under a special certificate of airworthiness in the owner-maintenance or amateur-built classification; or
(amended 2002/03/01; previous version)

(e) a part is made in accordance with subsection 571.06(4).

One thing to keep in mind is that the AMO in question here is not approved to certify work carried out to the part (radio) just to install it,.

[Guy Incognito]

- qa guy

I assume that by "release tag" are you talking about a Form 1. Check out Standards 571.10(2)(d) and the associated Appendix J.

An AMO can make an Authorized Release Certificate (Form 1) for a part, but be mindful of Block 11. Only one of 4 terms can be entered in block 11: Overhauled, Repaired, Inspected/Tested, or Modified.

If your AMO isnt authorized to overhaul, repair or modify your hypothetical radio, then you had better say Inspected/Tested.

[azimuthaviation]

If the AMO cant perform maintenance on the radio they cant certify it as inspected/tested either. And the Form One does not constitute installation certification as explicity states on the Form One, so its of no use to issue one in order to install it

[CID]

You have to keep "traceability" in mind. If a properly authorized AMO signs an airworthiness release for a component like a radio, they are assuming responsibility only for the overhaul, repair or modifications done to the unit. That means he better have reasonable traceability such as where it came from.

If a shop receives a radio with no tag on it and issues an airworthiness release, they may be tasked with providing traceability if they are audited or if there is a court case.

For an example of how this can go wrong, consider something a little simpler than a radio. Let's consider a bolt. If an AMO signs a release tag stating that some random found bolt is an AN-3 bolt and that bolt fails on the airplane and causes an accident, the guy who signed the release may be asked to prove it's an AN-3 bolt. Unless he has proof that it was ordered and batched from an authorizted distributor or manufacturer or the company itself manufactured it under a manufacturing authority, he/she is in a load of trouble for selling providing bogus parts.

The simple answer is "no" an AMO can not sign an airworthiness release for a new radio that arrived without a manufacturer's airworthiness release or for a tire, or tube, or propellor or bolt for that matter.

[azimuthaviation]

What about this from CAR's 573? In addition there was an exemption to reieve AMO's from the requirements of this standard which was due to expire midnight new years day, whether or not it has been renewed Im not too sure.

(11) An AMO with ratings in the Aircraft, Avionics, Engine, Propeller, Structure, or Component categories may evaluate undocumented parts of the kinds listed on the pertinent ratings, provided that:
(amended 2002/03/01; previous version)

(a) the AMO establishes applicable procedures, in its MPM, to perform the process outlined in Standard 571, Appendix H;

(b) the AMO obtains approval for the procedures required in paragraph (a) in accordance with section 573.01 of the CARs, and

(c) the performance of such service is authorized in the limitations set out in the AMO certificate.

[CID]

There are a lot of caveats to that standard in 573. See appendix H of the 573 standard. You wouldn't be able to apply it to a radio, at least not one that forms part of a required system. Furthermore the there is still a process of establishing traceability even if it means packing slips and receipts.

Again the "simple" answer is no.

[Heliian]

Some undocumented parts may be sent to an approved facility for re-certification. For your radio example, the radio shop could recert it if their policies permit, but the process to recert is usually a complete overhaul/inspection which would cost more than buying a new one. You can remove a part serviceable but you still have to maintain traceability with say, a green tag maint release and it should state on it that it was removed serviceable and will require post installation function checks. A commercial operator with an AMO will also have it's own procedures and forms for use on parts removed serviceable and there are also some CAR's relating to the installation of parts from other a/c and the documentation required. A form 1 is nice but not necessarily required if there is sufficient traceability.

[Cyclenut]

Sounds like "Overtagging" to me. Suggest you +/or your AMO review this and then decide:

The Authorized Release Certificate Goes Under the Microscope

http://www.tc.gc.ca/eng/civilaviation/p ... ce-755.htm

What about over-tagging?
There have been numerous questions and concerns submitted from industry regarding over-tagging a certificate-what is it and why is it unacceptable? Over-tagging occurs when someone receives a repaired part with a completed certificate and proceeds to write a new certificate under their company name. There are various justifications given for this activity, including internal process and document flow, as well as hesitance to reveal one’s sources. Regardless of the reason for the activity, it does not conform to the regulations. The organization responsible for performing the maintenance activity needs to be the one responsible and accountable for the certification of the work. How can an organization be responsible if they had no control over the process and quality control involved with the activity? If a second organization takes responsibility for the work, they break the traceability between the installer and the repairer of the part.

Read the entire article for more information. Food for thought.

[qa guy]

thanks to all for the great feedback! I think the best thing to do would ammend the company MCM to include
this process in our parts receiving section. If its approved then we're o.k.
Seems kind of ridiculous that the exact same part (radio in this case) is $200 more if you want paper work with it.

[CID]

qa guy, I think you're missing the point. You can't determine if its the "exact same part" or a bogus part or a manufacturing reject or a part past its shelf life with no traceability.

If you pull an airworthiness tag out of nowhere you are assuming liability for the part. Think of this scenario. You have a Goodyear tire that you got from somewhere with no tag. You make your own tag and install it and it blows causing an accident.

An investigation finds a manufacturing defect and they look through the paperwork only to find you're the only one who ever gave it an airworthiness release based on....nothing. Except that you figured it looked right.

Goodyear isn't liable. You are.

[ALF]

Call your PMI. That is what he is there for.

[twotter]

Can a company create their own release tag for a part? ie: radio.
I used to know an avionics guy who said he can do that within the company. (no manufacturing cert.)
I have spent exhausting hrs. reading the CARS and do not see how this is
possible without a manufacturing certificate. It is quite clear to me in the regs that approval documentation of some type is required. Why would anyone else pay so much for the the
release tag if you could?
Also, could you simply greentag it as a serviceable used part? I know its common with
parts when they sit in quarentine?
Any positive feedback is greatly appreciated.

Is this for a removed serviceable part? If it is, can you show where it was installed and certified with suitable documentation? If so then go for it.. In most cases, if it's already in an airplane and was documented properly, it shouldn't be a problem.

[twotter]

qa guy, I think you're missing the point. You can't determine if its the "exact same part" or a bogus part or a manufacturing reject or a part past its shelf life with no traceability.

If you pull an airworthiness tag out of nowhere you are assuming liability for the part. Think of this scenario. You have a Goodyear tire that you got from somewhere with no tag. You make your own tag and install it and it blows causing an accident.

An investigation finds a manufacturing defect and they look through the paperwork only to find you're the only one who ever gave it an airworthiness release based on....nothing. Except that you figured it looked right.

Goodyear isn't liable. You are.

Now this sounds like a guy who was almost good enough to be a TC employee.. The bafflegab isn't quite good enough though as I can point out a lot of holes in it. More practice and training will be required before a TC position will be offered.

[robertw]

To sign an "Authorized Release Certificate" for an in service part, your AMO needs to be rated in the appropriate category. In this case, if your TCCA approval certificate doesnt have "Avionics" on it with specifics to radio systems, you can't sign a release for it. If you do have this on your certificate, you have to be authorized under your AMO to sign a release document for that product. To be able to sign that release, you have to carry out some sort of maintenance action in accordance with the manufacturers ICA's (maintenance manual, CMM etc...) to compare the radio with to verify it conforms to it's type design. Signing a relase tag willy nilly without the above is foolish and... In contravention of the CAR's.

For new parts, you can't sign the "Statement of Conformity" (block 13A on the Form One) unless you hold manufacturing approval for that product.

An AMO "Green Tag" or "Serviceable" tag just doesn't cut it for new parts.

Read the regulations with regards to reqirements for the installation of parts. 571.07, 571.08.

Also read AN B0073. http://www.tc.gc.ca/eng/civilaviation/s ... 3-2642.htm

[qa guy]

If you pull an airworthiness tag out of nowhere you are assuming liability for the part. Think of this scenario. You have a Goodyear tire that you got from somewhere with no tag. You make your own tag and install it and it blows causing an accident.

If I create a green tag, it has a section on it with previous certification, which will always be available because it will be on the red tag that was on the u/s part....at least there should be a red tag...

[qa guy]

Thanks robert, that is how I understand it as well.
Now, I received some new tubes from a new vendor. It came wih a statement that it was manufactured according to all manufacturing requirements. However there is no mention of any aviation standards or that its aircraft approved, and it is not printed on a form one, conformity cert. or authourized release tag. Does this meet the requirements of 571.08 on new parts?
Thanks for the AN reference!

[robertw]

Tires and tubes are a bit tricky. At first, a person might be tempted to call them commercial parts. If you read Std 571.07 however, you will see that part of the definition of a commercial part includes "whose failure does not adversely affect the continued safe flight and take-off and landing of the aircraft". I'd say tires and tubes definitely affect the safety of a take off or landing and are thus not commercial parts. In this case, only the brands and p/n' s of tires and tubes that the manufacturer of the aircraft specifies in their IPC should be used. Your tubes don't seem to have adequate certification for installation and I would consider them not eligible for installation.