AMC1 CAO.A.020(c) Terms of approval

FABRICATION

(a) The agreement by the competent authority for the fabrication of parts by the maintenance organisation should be formalised through the approval of a detailed procedure in the CAE. This AMC contains principles and conditions to be taken into account for the preparation of an acceptable procedure.

(b) Fabrication, inspection, assembly and test should be clearly within the technical and procedural capability of the approved maintenance organisation.

(c) The approved data necessary to fabricate the part is that approved by either the Agency, the type certificate (TC) holder, the Part 21 design organisation approval holder, or the supplemental type certificate (STC) holder. Alternatively, the data can be declared by the declarant of a declaration of design compliance (in accordance with Part 21 Light Subpart C).

(d) Items fabricated by an approved maintenance organisation may only be used by that organisation in the course of overhaul, maintenance, modifications, or repair of aircraft or components undergoing work within its own facilities. The permission to fabricate does not constitute approval for manufacturing, or for supplying externally and the parts do not qualify for certification on EASA Form 1. This also applies to the bulk transfer or surplus inventory, in that locally fabricated parts are physically segregated and excluded from any delivery certification.

(e) Fabrication of parts, modification kits, etc. for onward supply and/or sale may not be conducted under a CAO approval.

(f) The data specified in point (c) may include repair procedures involving the fabrication of parts. Where the data on such parts is sufficient to facilitate fabrication, the parts may be fabricated by an approved maintenance organisation. Care should be taken to ensure that the data includes details on part numbering, dimensions, materials, processes, and any special manufacturing techniques, special raw material specification or/and incoming inspection requirement and that the approved organisation has the necessary capability. That capability should be defined within the CAE. Where special processes or inspection procedures are defined in the approved or declared (in accordance with Part 21 Light Subpart C) data, which are not available at the approved maintenance organisation, that organisation cannot fabricate the part unless the TC/STC holder or the declarant of a declaration of design compliance gives an approved alternative.

(g) Examples of fabrication under the scope of a CAO approval can include but are not limited to the following:

(1) fabrication of bushes, sleeves and shims;

(2) fabrication of secondary structural elements and skin panels;

(3) fabrication of control cables;

(4) fabrication of flexible and rigid pipes;

(5) fabrication of electrical cable looms and assemblies; and

(6) formed or machined sheet metal panels for repairs.

It is not acceptable to fabricate any item to pattern unless an engineering drawing of the item is produced which includes any necessary fabrication processes and which is accepted to the competent authority.

(h) Where a TC holder or declarant of a declaration of design compliance or an approved or declared (in accordance with Part 21 Light Subpart G) production organisation, or a production organisation using Part 21 Light Subpart R is prepared to make available complete data which is not referred to in aircraft manuals or service bulletins, but provides manufacturing drawings for items specified in parts lists, the fabrication of these items is not considered to be within the scope of a CAO approval unless agreed otherwise by the competent authority in accordance with a procedure specified in the CAE.

(i) Inspection and identification

Any locally fabricated part should be subject to an inspection stage before, separately, and preferably independently from, any inspection of its installation. The inspection should establish full compliance with the relevant manufacturing data, and the part should be unambiguously identified as fit for use by stating conformity to the approved or declared (in accordance with Part 21 Light Subpart C) data. Adequate records should be maintained of all such fabrication processes including heat treatment and the final inspections. All parts, except those with inadequate space, should carry a part number which clearly relates them to the manufacturing/inspection data. Additionally to the part number, the approved maintenance organisation’s identity should be marked on the part for traceability purposes.