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mike.morton's picture

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?

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bob.pasch's picture

Mike you're absolutely correct! There's nothing regulatory requiring a CRS to maintain a rating for which you're allowed to subcontract. With that interpretation, EVERY CRS would have to have EVERY rating available in order to perform ANY specified function and that's irrational.

Simple example, I'm a rated CRS who needs an NDI maintenance function for which I'm not rated. It's perfectly acceptable to subcontract to a non-certificated NDI lab provided you comply with §145.217 (2)(b)(1 thru 3).

There's nothing in §145.217 that sez YOU must be rated for a function that a non-certificated subcontractor can perform. If your PMI is unwilling to come off his/her interpretation, don't be afraid to go over his/her head... all the way to AFS-340 if necessary...

Or just have them call me :)

David (not verified)
Anonymous's picture

145.217(b)(3) is the key to this question – your repair station is providing the return to service for the article. Therefore the repair station must have a rating that covers the article being returned to service (145.201(a)). Remember that the contract vendor effectively becomes a part of your repair station when they perform that contract maintenance.

AC145-9, Para 4-7 also gives guidance along with Order 8900.1 Volume 6, Chapter 9, Section 20.

Our PMI has given guidance that provided we have a rating that covers the RTS of a higher level article that uses that process, then yes we can use non-certificated contract vendors without having a rating for the process itself.

If it is only the process that is being returned to service, then you will need a rating for the process.

mike.morton's picture

That is exactly the way I have interpreted the regs also. I just want to have all my ducks in a row when I address this my PMI, we have a good relationship and I want to keep that. I appreciate the way you have lined this out and will probably borrow your format when addressing him.

Thanks for your input.

mike.morton's picture

Appreciate the input, I was hoping I was on the right track, and it sound like I am.

Stand by the phone, I may need backup....Lol

mike.morton's picture

UPDATE---Thanks for the input, I was able to go to my PMI with this input and make a really strong argument. He in turn discussed it with some of the other PMI's in his office and has now sided with me on this issue. Thanks again.

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