21L.A.273 Production control system

MEANS OF CHECKING OF THE PRODUCTION PROCESSES The production control system should include appropriate means of checking that production processes, whether performed by the natural or legal person that produce under Subpart R or by subcontractors under its control, are performed in accordance with the applicable production data and ensure:

(a)there is a system for the control and authorised amendment of data provided for the production, inspections and tests to ensure that data is complete and up to date at the point of use;

(b)the availability of personnel with suitable qualifications, experience, and training for each required production, inspection, and test task (special attention should be paid to tasks that require specialised knowledge and skills, e.g. NDT/NDI, welding, etc.);

(c)a working area is provided where the working conditions and environment are controlled as appropriate in respect of cleanliness, temperature, humidity, ventilation, lighting, space/access, protection against noise and pollution; and

(d)the equipment and tools are sufficient to enable all specified tasks to be accomplished in a safe and repeatable manner without any detrimental effects on the items under production; it should be demonstrated that the calibration control of the equipment and tools used complies with, and is traceable to, national or international standards.

CONFORMITY OF SUPPLIED ITEMS

(a)The natural or legal person that produces under Subpart R is responsible for determining and applying acceptance standards for physical condition, configuration status and conformity of raw materials, subcontracted works, and supplied products or parts, whether to be used in production or delivered to customers as spare parts. This responsibility also includes items of buyer-furnished equipment (BFE).

(b)The following techniques are examples for the production control: first-article inspection of supplied parts, including destruction, if necessary, to verify that the article conforms to the applicable data for the new production line or the new supplier; incoming inspections and tests of supplied parts, materials or equipment that can be satisfactorily inspected on receipt; review of incoming documentation and data relevant to the showing of conformity to be included in the certification documents; any additional work, tests or inspections that may be needed for parts that are to be delivered as spare parts and that are not subject to the checks normally performed during subsequent production or inspection stages.

(c)The natural or legal person that produces under Subpart R may rely upon an EASA Form 1 issued in accordance with Part 21 or Part 21 Light if provided as evidence of conformity with the applicable design data.

(d)For suppliers that do not hold an approval under Part 21 Subpart G (POA) or that have not declared their production capability under Subpart G of this Annex, the inspection system of the natural or legal person that produces under Subpart R should include a system for the control of incoming parts which would allow that natural or legal person to inspect and test such items at the supplier’s facility, if the item cannot or will not be completely inspected upon receipt.

IDENTIFICATION OF INCOMING MATERIALS AND PARTS The natural or legal person that produces under Subpart R should inspect all parts and materials supplied from external parties to ascertain that: they are identified; they have not been damaged during transport or unpacking; the incoming parts and materials have the appropriate and correct accompanying documentation; and the configuration and condition of the parts and materials are as laid down in the applicable design data. Only upon completion of these checks and of any incoming further verifications laid down in the procurement specification, the natural or legal person that produces under Subpart R may accept the parts or materials for warehousing and used in production. This acceptance should be certified by an inspection statement. A suitable recording system should allow reconstruction at any time of the history of every material or part. The areas where the incoming checks are carried out and the materials or parts are stored pending completion of the checks should be physically segregated from other departments.

TESTS If relevant, the natural or legal person that produces under Subpart R should perform functional, ground and flight tests of the manufactured products. The production ground and flight tests for a new aircraft are specified by the declarant of the declaration of design compliance. These tests typically include: a check on the handling qualities; a check on flight performance (using normal aircraft instrumentation); a check on the proper functioning of all aircraft equipment and systems; a determination that all instruments are properly marked, and that all placards and required flight manuals are installed before the flight test; a check of the operational characteristics of the aircraft on the ground; and a check on any other items peculiar to the aircraft being tested. For production flight-test activities, the natural or legal person that produces under Subpart R may consider establishing a flight test operations manual (FTOM) (refer to AMC1 21L.A.127(b) and to point 21L.A.177(b)). If the design compliance of the engine is covered by the declaration of the aircraft design compliance, then the declarant of the aircraft design compliance should also provide the specifications for the functional test required for a new engine. These will normally include at least the following: break-in runs that include the determination of fuel and oil consumption and the determination of power characteristics at rated maximum continuous power and, if applicable, at rated take-off power; a period of operation at rated maximum continuous power; for engines that have a rated take-off power, part of that period should be at rated take-off power. The test equipment used for the test run should be capable of an output determination of accuracy sufficient to assure that the engine output delivered complies with the specified rating and operational limitations. If the design compliance of the propeller is covered by the declaration of the aircraft design compliance, then the declarant of the aircraft design compliance should also provide the specifications for the functional test required for a new propeller. These will normally include several complete cycles of control throughout the propeller pitch and rotational speed ranges. In addition, for feathering and/or reversing propellers, several cycles of feathering operation and reversing operation from the lowest normal pitch to the maximum reverse pitch should normally be required. After functional testing, each engine or propeller will need to be inspected to determine that the engine or propeller is in condition for safe operation. Such inspections are specified by the declarant of the aircraft design compliance and are normally including internal inspection and examination. The degree of internal inspections should normally be determined on the basis of the positive results of previous inspections conducted on the first-produced engine or propeller, and on the basis of in-service experience.

PROCEDURES FOR THE PRODUCTION DATA

(a)When a natural or legal person that produces under Subpart R develops its own manufacturing data from the design data package delivered by a declarant of design compliance, the procedures should ensure the correct transcription of the original design data.

(b)The procedures should define the manner in which applicable design data is used to issue and update the production/inspection data, which determines the conformity of products and parts. These procedures should also define the traceability of such data to each individual product or part for the purpose of stating the condition for safe operation and for issuing a statement of conformity (EASA Form 52B) or an EASA Form 1.

(c)During execution, all work performed should be accompanied by documentation that gives either directly or by means of appropriate references the description of the work as well as the identification of the personnel in charge of inspection and execution of the tasks for each of the different work phases.

INSPECTION OF PARTS IN PROCESS The purpose of the production inspection system is to carry out checks at suitable points during production and provide objective evidence that the correct specifications are used, and that processes are carried out strictly in accordance with those specifications. During the manufacturing process, each part should be inspected in accordance with an inspection plan that identifies the nature of all inspections required and the production stages at which they occur. The inspection plan should also identify any particular skills or qualifications required for personnel that carry out the inspections (e.g. NDT personnel). If the parts are such that if damaged, they could compromise the safety of the aircraft, additional inspections for such damages should be performed at the completion of each production stage.

ARCHIVING SYSTEM For guidance regarding archiving systems, please refer to GM1 21.A.7(a) and (b).

MAINTENANCE ACTIVITIES Point 21L.A.273(h) requires the natural or legal person that produces under Subpart R to have procedures that cover maintenance activities of new aircraft it has manufactured, as necessary to keep them in an airworthy condition. The natural or legal person that produces under Subpart R should not maintain a newly manufactured aircraft beyond the point at which the applicable operational rules require maintenance to be performed by an approved maintenance organisation (point 21L.A.275(e)). If the production organisation intends to maintain the aircraft beyond that point, it should apply for and obtain an appropriate maintenance approval (see Articles 3 and 4 of Regulation (EU) No 1321/2014).

MAINTENANCE OF AIRCRAFT Examples of such maintenance activities are the following: preservation, periodic inspection visits, etc.; embodiment of a service bulletin (SB); application of airworthiness directives (ADs); repairs; maintenance tasks resulting from special flights; and maintenance tasks to maintain airworthiness during flight training, demo flights and other non-revenue flights. Any maintenance activities should be recorded in the aircraft logbook. It should be signed off for attesting the conformity of the work performed with the applicable airworthiness data. If the aircraft logbook is not available, or if the production organisation prefers to use a separate form (for instance, for a large work package or for delivery of the aircraft to the customer), the production organisation should use EASA Form 53B which should subsequently become part of the aircraft maintenance records.