This Question crosses many discussion topics but I would like some input from the regulation side of things. We use a couple of non-certificated vendors for processes we are currently rated for, but because of cost we choose to use the non-certificated vendor, the vendors are managed by our Quality dept, and they have been audited and accepted on our repair station vendor listing. We are now considering dropping one of these capabilities as the outside vendor is much more effecient. It costs quite a bit to keep the capability in an opertaional readiness therefore it is not cost effective to keep. My FSDO is telling me in order to use a non-certificated vendor, I must keep my rating otherwise I must use a certificated vendor for the process. They are siting 14CFR 145.201 as a backup for this statement, but I dont see the realtionship from the reg to what they are saying, also there is nothing in 14CFR 145.217 that requires this either (that I can interpret). I see no reason to stop using the non-certificated vendor if they contiue to be audited, and our inspectors stay trained on the process. I have no problem with using certificated vendors but there are none in my area, this will cause a turn time and pricing issue due to shipping. Are other repair stations being held to this requirement?
Mon, 10/28/2013 - 09:57#1
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