Date: January 1, 1986
Subject: Distributor Standards and Procedures
This advisory provides information concerning Chapter 563, Subchapters A, B and C of the Airworthiness Manual and sets forth acceptable means, but not the sole means, of compliance with its requirements. It covers only those sec-tions where further discussion, information and examples would be helpful. The numbering of the paragraphs of this advisory refers to the applicable sec-tions of the Subchapters.
Since a distributor does not normally hold current approved design data and because he would find it difficult, if not impossible, to inspect most aero-nautical products on receipt, dependence in regard to conformity must be placed on the source of aeronautical products, proper identification, accept-able airworthiness certification traceable to the source, and to objective evidence of conformity either received from the source, or known to be held by the manufacturer, or maintenance organization.
The standard parts and materials referred to in Section 563.103 (a)(1)(iii) are those which are manufactured to the requirements of established standards acceptable to the aircraft industry and to civil and military authorities of Canada or to the equivalent authorities of other nations. Examples are AN, NAS, SAE and MIL specifications.
The organization of a distributorship and terms of reference of the various departments responsible for distribution operations should be clearly defined. Means must be established to ensure that all product control operations which could affect the integrity of the aeronautical products are effective and properly coordinated.
563.105 Product Control System
The complexity of a distributor's product control system will vary with the volume and types of aeronautical products which he is seeking approval to distribute. A distributor therefore, need only be concerned with those aspects of a product control system which apply to his particular organiza-tion.
A well prepared product control system manual is an asset to a distributor. It should assist in assuring prospective customers that the aeronautical pro-ducts which the distributor provides can be shown to meet approved design data. The manual also provides distributor's management personnel with an overview of the methods used to meet DOT requirements for approval, showing the department or person responsible for ensuring that the requirements are met on a continuing basis.
Written procedures are required to ensure that each product control system function is performed in a consistent manner regardless of changes in person-nel. The following paragraphs provide amplification of Section 563.105(b) but are not meant to be all-inclusive or restrictive in content or in the function covered.
A distributor is responsible for establishing the airworthiness of each aero-nautical product he provides to a customer. His most important task therefore is to ensure that he acquires his aeronautical products from sources as out-lined in Section 563.103.
All incoming aeronautical products should be segregated until they can be identified and inspected. Each incoming product should be checked against purchasing requirements to ensure that it is the correct product, that it has been properly identified, and that inspection data and proper certifica-tion has been included with the shipment.
When identified, inspected as necessary and found acceptable, material should be transferred to storage, carrying with it, as applicable, proper identifica-tion and certification information. Unacceptable material should be segre-gated, and if necessary held in quarantine for subsequent disposal action.
Segregation and Storage
Adequate facilities are required to isolate, protect and maintain positive identification of certified aeronautical products held in storage for distri-bution. Any product with a specified shelf life should be monitored for time expiry dates and purchasers advised of the life remaining. Split batches or individual aeronautical products segregated from an original shipment with a blanket certification should be appropriately identified and cross-referenced to the incoming shipment and certification documentation.
A distributor should have in his possession, or have his supplier hold and make available to him on request, objective evidence of conformity in the form of inspection records.
The two years prescribed for the retention of records is a minimum period only. The need to retain records beyond two years is left to the best jud-g-ment of the distributor.
An approved distributor may issue release certificates under the authority of the DOT approval, provided that the products which he certifies are in good condition, were acquired from approved sources identified in section 563.l03, and certified by the suppliers as conforming to approved design data.
Signing privileges are granted to persons who are authorized by the distri-butor and registered with DOT. Such persons should be knowledgeable of the distribu-tors product control system and be able, at any time, to demonstrate the methods employed by the organization to determine product conformity. Distributors should be aware that only approved persons who are registered with DOT may lawfully sign release documentation under the authority of a DOT approval for any aeronautical product destined for embodiment in a civil air-craft.
563.203 Application for Approval
It is recommended that a distributor contact the appropriate DOT regional office prior to submitting an application for approval to ensure that he has all the pertinent data and information, and that he understands DOT require-ments. It is important at this time to establish a convenient means of com-municating and exchanging information and data, therefore the distributor should assign a liaison person authorized to investigate and resolve problems on his behalf.
DOT will require access to the applicant's facilities, product control system procedures and records applicable to requests for approval, and may request special assistance from the distributor.
563.209 Approval Limitations
A distributor approval is granted only to the organization named on the Certi-ficate of Approval and only for the location, or locations, stated therein. Therefore, if any changes occur in ownership or location, the organization will cease to be approved unless DOT has been notified of the change and a new Certificate of Approval has been issued.
To obtain a new Certificate of Approval the holder is obliged to inform DOT of a change of business ownership or location in sufficient time to avoid possible loss of approval coverage. The issue of a new Certificate of Ap-proval will entail an inspection survey by DOT to verify continuing compliance with the previously approved product control system manual and, in the case of a new owner, to review company policy that could impact on the airworthiness of any product being processed by the distributor.
563.211 Authorized Signatories
Only those persons whose names are registered with DOT are authorized to sign release certifications. Such persons are nominated by the approved organization with the knowledge that as authorized signatories they will be making certifi-cations which, if made in error or found to be false, could have a serious affect on the approval status of the organization.
An approved organization should therefore ensure that its authorized signa-tories are experienced and trustworthy individuals on whom it can rely for the certification of its release certificates and of the products described therein.
563.303 Certification -Aeronautical Products
The release certification should be made on a document positively identifiable to the organization issuing it. Preferred documents are Release Notes or tags although other forms may be used provided that they contain the same informa-tion and the certification statement. The forms or tags should be designed to include the following information:
- The approved distributor's name and address,
- The distributor's approval number,
- A description of the product, i.e., name, part or model number, serial number (if applicable) and product manufacturer,
- A certification stating: I hereby certify that the aircraft parts, appli-ances and/or materials described herein were acquired from a source of supply that is consistent with the conditions under which the Department of Transport distributor approval No. has been granted.
- The signature of an authorized signatory.
All entries on airworthiness certification documents should be typewritten or printed in permanent ink.
563.305 Certification for Export
To obtain export certification for a product a distributor will be required to show evidence of conformity to approved design data. Acceptable evidence will be that which is traceable to either an approved manufacturer or an approved maintenance organization.
A properly completed release note or tag, as previously described in 563.305 may be used for airworthiness certification for export of aeronautical pro-ducts other than aircraft engines, engine modules and propellers in which case a Certificate of Airworthiness for Export is mandatory. To be acceptable to a foreign civil aviation authority the release note, tag, or Certificate of Airworthiness for Export, as appropriate, must be signed and stamped by a DOT Airworthiness Inspector or an Airworthiness Inspection Representative.
All entries on the form 24-0025, example shown at Appendix A figure 1, should be typewriters or clearly printed in permanent ink describing each aeronau-tical product to the extent that absolute correlation can be estab-lished between the product and the export certification. It is essential that each item on the form is completed, as applicable, and that the "Type Approval No." is stated as the data authorized by the civil aviation authority of the importing country, eg., when exporting to the USA the authorized type approval should be the FAA Type Certificate number or Supplemental Type Certificate number. The information required in item 11 "for installation on" should be completed to identify the make and model of aircraft, or aircraft engine on which the product is approved for installation. Any deviation or nonconform-ity to the pertinent design, test or quality requirements must be recorded, together with the approval from the civil aviation authority for such devia-tions or nonconformities, in the space assigned for "Remarks".
When signed by the DOT Airworthiness Inspector or the Airworthiness Inspection Representative, as applicable, the documents will be included for shipment with the product or, in the case of the form 24-0025, for mailing by the dis-tributor to the civil aviation authority of the importing country or in the case of the USA, to the importer.