ED Decision 2022/021/R
VENDOR AND SUBCONTRACTOR ASSESSMENT, AUDIT, AND CONTROL — PRODUCTION ORGANISATION APPROVAL HOLDER THAT USES OTHER PARTIES SUPPLIER CERTIFICATION
(1) General
Other party (OP) supplier certification is a method whereby a supplier contracts an appropriately recognised or accredited OP for the purpose of obtaining a certification from that OP. Certification indicates that the supplier has satisfactorily demonstrated that it meets the applicable standard on a continuing basis. OP certification results in placing the supplier on the OP list of certified organisations, or in the supplier receiving a certificate identifying the requirements that have been met. Periodic follow-up evaluations are conducted by the OP to verify continued compliance with the requirements of the applicable standard.
The production organisation is required by point 21.A.139(d) to demonstrate that it has established and maintains a quality system that enables the organisation to ensure that each item produced conforms to the applicable design data and is in a condition for safe operation. To discharge this responsibility, the quality system should have, among other requirements, procedures to adequately carry out the assessment and surveillance of suppliers.
The assessment and surveillance of suppliers by an OP should be deemed to satisfy the requirements of point 21.A.139(b)(1)(ii) when the conditions of this AMC are satisfied. The assessment and surveillance of suppliers by OP as part of supplier certification does not exempt the production organisation approval (POA) holder from its obligations under point 21.A.165. The supplier assessment and surveillance, corrective action and follow-up activity conducted at any of its supplier’s facilities may be performed by OP.
The purpose of using an OP cannot be to replace the assessment, audit and control of the POA holder. It is to allow an element (i.e. the assessment of the quality system) to be delegated to another organisation under controlled conditions.
The use of suppliers that are certified by OP in accordance with this AMC should be part of a production organisation quality system.
(2) Reserved
(3) Conditions and criteria for using supplier certification for supplier assessment and surveillance
(a) The POA holder should include the use of supplier certification for the supplier assessment and surveillance in the POA holder’s quality system to demonstrate compliance with the applicable requirements of Part 21.
(b) The procedures that are required for use of supplier certification for the supplier assessment and surveillance should be consistent the with other procedures of the POA holders’ quality system.
(c) The procedures of the POA holder that uses supplier certification for the supplier assessment and surveillance should include the following:
(1) A listing of the OPs that have certified or will certify suppliers and will conduct supplier assessment and surveillance or the scheme under which the accreditation of the OP is controlled. This listing should be maintained by the POA holder and made available to the competent authority upon request.
(2) A listing of the certified suppliers that are under surveillance by the OP and that are used by the POA holder. This listing should be maintained by the POA holder and made available to the competent authority upon request.
(3) The method used by the POA holder to evaluate and monitor the certification process of any OP certification body or OP certification scheme used. This applies not only to new suppliers, but also to any decision by the POA holder to rely on OP certification of current suppliers. The method should include the following as a minimum:
(i) verification that certification standards and checklists are acceptable and applied to the applicable scope;
(ii) verification that the OP is appropriately qualified and has sufficient knowledge, experience and training to perform its allocated tasks;
(iii) verification that the frequency with which the OP carries out surveillance of the suppliers is commensurate with the complexity of the product and with the surveillance frequency established by the POA holder’s suppliers control programme;
(iv) verification that the surveillance of the suppliers is including on-site surveillance activities that are conducted by the OP;
(v) verification that the surveillance report will be made available to the competent authority upon request;
(vi) verification that the OP continues to be recognised or accredited; and
(vii) verification that the OP has access to the applicable proprietary data to the level of detail necessary to survey the suppliers’ functions.
Where the POA holder uses an OP accredited by a signatory to the European cooperation for Accreditation (EA) Multilateral Agreement and works in accordance with an aviation standard (e.g. ENÂ 9104 series of requirements) that describes the requirements for the OP certification, items (ii), (iv), and (v) should be deemed to be complied with.
(4) A definition that states to what extend the OP will conduct supplier surveillance on behalf of the POA holder. If the OP partly replaces surveillance by the POA holder, the POA holder should identify the functions that will continue to be surveyed by the POA holder.
(5) the procedures that ensure that the POA is aware of the loss of an existing certification.
(6) the procedures that ensure that the POA holder is aware of any non-conformity and has access to detailed information on any non-conformity.
(7) the procedures to evaluate the consequences of non-conformity and take appropriate actions.
(d) The POA should make arrangements that allow the competent authority to make investigations in accordance with point 21.A.9 to include OP activities.
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