Maintenance and Manufacturing Policy Letters (MPL)

Subject: Number: MPL 8
Distribution of Aeronautical Products Revision No: 3
  Number of Pages: 2
File No: AARP-5009-0-8 Issue Date: May 6, 2003
1.  Purpose

1.1  This letter clarifies the distribution privileges of Approved Maintenance Organizations (AMOs), and explains the different uses for certification tags.

2.  Background

2.1  It was the original intent of the Airworthiness Manual that certification tags attached to new aeronautical products would be different from those attached to products released following maintenance. New products would be identified by a manufacturer's or distributor's tag, while those having undergone maintenance would be identified by a maintenance release tag.

2.2  The certification statements on the tags are different. The statement on the manufacturer and distributor tags attests to the conformity of the product as a whole, whereas the statement on the maintenance release tag certifies the proper completion of a discrete task.

2.3  It was recognized that for internal use, an AMO stores system would, in effect, meet all the requirements of a distributor for the types of products covered in the company scope of approval. It was also understood that an AMO may occasionally supply new aeronautical products to a third party, and that these products could carry the same tag that was used within the AMO.

2.4  There was no intent for AMOs to hold separate distributor approvals unless they wished to make distribution an established part of their operation, i.e. to conduct business as a distributor and distribute items outside their scope of approval. In any case, as noted earlier, it was not intended that AMOs would attach their maintenance release tags to new products.

2.5  The example of a maintenance release tag in the old AMA 575.217 contained a section to identify "previous certification". This was a carry over from the old AI-99 tag, which was a multi purpose document. Use of this section on a maintenance release tag would allow the tag to be used for the certification of new products, provided that this was properly supported by the AMO's approved procedures, and clearly identified on the tag. This could be done by adding a check box entitled "receiving inspection." The maintenance release would then refer to this inspection. For further clarity, the "previous certification" statement could be replaced by "source", "origin" or "traceability."

2.6  Another point of confusion was the means by which an AMO can exercise its limited distributor privileges. Some regions assumed that they come automatically as part of the AMO privileges, while others routinely issued a separate distributor approval. This latter course is potentially troublesome, as in effect it gives two separate approvals to a single element of the AMO's operation (the stores procedures).

3.  POLICY statement

3.1  Maintenance and Manufacturing Branch policy is as follows:

(a)  AMO applicants should not be granted separate distributor approvals unless their distribution activities warrant it. In such cases they must meet all the applicable requirements of Chapter 563 of the Airworthiness Manual. For normal purposes, any stores and tagging system acceptable for the internal use of an AMO should also be acceptable for the occasional supply of parts to third parties.

3.2  An AMO has four alternatives regarding the tagging of new products:

(a)  leave the original manufacturer's or distributor's tags on the items;

(b)  develop separate tags for new components. The tags should meet the requirements of the Chapter 563, except that they must identify the organization as an AMO, not an approved distributor. Such separate tags are not interchangeable;

(c)  use a standard maintenance release tag, and enter the phrase "Receiving inspection" in the description of work done; or

(d)  develop and use a maintenance release tag with an appropriate check box to indicate that the certification relates to the inspection of a new item.

4.  Effective Date

4.1  This policy comes into effect January 25, 2001.

5.  Expiry

5.1  This policy expires on April 28 2006, or upon inclusion of this material and AWM chapter 563 into the CARs and associated standards, whichever occurs first.

6.  Contact

6.1  The responsible division indicated below may be contacted for information regarding this MPL:

Policy Development, AARPC

D.B. Sherritt
Maintenance and Manufacturing