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.
–
(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).
–
(21) items need “no action”: e.g., clarification,
comment on ISO text, topic already addressed in
another clause, …
19 Oct 09:
Agreed.
45
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.
Company Confidential
Questions?
Company Confidential
8