Above and Beyond
Aerospace requirements include more than AS9100
by Dale K. Gordon
Much has happened in the last 12 months relative to aerospace industry quality management system standards. It was with some anticipation and not much fanfare that the latest revision of AS9100, Quality Management Systems—Requirements for Aviation Space and Defense Industries was released.
This latest edition of the standard was a two-fold revision by the International Aerospace Quality Group (IAQG). Not only was it revised to correspond to the root document, ISO 9001:2008, but it was also a significant update to the aerospace requirements of organizations that manufacture and supply products to the aviation, space and defense industries.
This revision of the standard was broadened to be more inclusive of all aspects of the customers and users of the products that concern the IAQG. It is also more detailed to ensure supply chain requirements for registering organizations are aligned with current industry practices. But the update to AS9100 wasn’t the only change. Other standards that align closely with AS9100 received the same level of attention but not necessarily the publicity.
Two lesser-known but equally important IAQG standards were also revised and updated in the last year: 9110—Quality Management Systems—Requirements for Aviation, Maintenance, Repair and Overhaul Organizations; and 9120—Quality Management Systems—Requirements for Aviation, Space and Defense Distributors.
Like AS9100, these two standards were updated to account for ISO 9001:2008. They were also expanded and amplified to be more inclusive of the broader market requirements they serve.
IAQG 9120 is applicable to a narrow section of the aviation, space and defense supply chain, but it’s a critical one nonetheless. In thinking about the original supply chain model (Figure 1), the distribution organizations are shown as foundational—just above raw materials. They often supply commercial off-the-shelf (COTS) items manufacturers.
But this isn’t a totally accurate characterization of the organizations that serve these customers and the markets in general. In fact, they have taken on ever-increasing importance in the life cycle of products. They’re included not only in the distribution of COTS parts, but also in inventory management of major subassemblies for maintenance organizations’ aircraft and critical support at all levels of the supply chain, including original equipment manufacturers (OEMs) and end-item users.
To reflect how important these organizations are to the proper functioning of the product and customer satisfaction, there were significant changes made to IAQG 9120:
This standard is for use by organizations that procure parts, materials and assemblies and resell these products to a customer in the aviation, space and defense industries. This includes organizations that procure products and split them into smaller quantities, including those that coordinate a customer controlled service on the product. This standard is not intended for organizations that maintain or repair products. Organizations that perform work that affect or could affect product characteristics or conformity should use the IAQG-developed 9100 or 9110 standards, as appropriate.1
The standard itself includes automatic exclusions to clause 7.3—design and development, and clause 7.5.2—validation of processes for production and service provisions. But, in a change from the previous version of the standard, clause 7.1—planning of product realization was not excluded. This is in line with the current global acknowledgement that use of the word "product" and the service provided are the same.
Changes in the 9120 standard include definitions for counterfeit and suspected unapproved parts. This issue is an important and serious concern for the industry and reflects the role of the distribution organizations in safeguarding the integrity and safety of the products into which their items are incorporated.
Also added to the standard was the AS9100 definition of risk, which has the same implications for a distribution organization as it does for a design and manufacturing organization.2
As with all IAQG standards, 9120 borrows heavily from the 9100 standard to keep industry requirements as common and streamlined as possible. Some differences include a minimum seven-year record retention requirement in clause 4.2.4, which was changed because the minimum regulatory requirement for some documentation was only two years. Given the long lead times and product-use shelf life, the industry believed two years was insufficient.
This revision to 9120 also adds the requirement from 9100 for configuration management. Configuration status and identification must be maintained at all times while the products are in the control of distribution organizations.
The requirements for supplier control (purchasing clause 7.4), which in the case of distribution can be anyone from the original product OEM to intermediaries or value-added suppliers, was significantly expanded and aligned with 9100. This is an area of significant importance that ensures distribution organizations provide safe and reliable products that meet customer and regulatory requirements every time.
This coincides with verbiage that was added to clause 7.5.3—identification and traceability, which again forms one of the key responsibilities of the distribution function to ensure proper application and use of the products organizations provide to their customers.
Overall, the 9120 standard is complementary to the 9100 standard and is intended for use by organizations that fill vital inventory and distribution roles in the aviation, space and defense industries.
In addition, there is the IAQG 9110 standard, which is also modeled after 9100 and is meant to serve a vast, global and ever-growing network of maintenance and repair organizations that keep aviation products safe and operating cost effectively.
One difference between the 9100 and the 9110 standards is that the aviation maintenance industry is marked by a coexistence of certificated and noncertificated repair stations. In this context, certificated means the repair station has been assessed by a national aviation authority (NAA), such as the Federal Aviation Administration in the United States, and has been issued a certificate to operate.
Noncertificated repair stations fall outside the NAA’s regulatory oversight and are subject to monitoring and oversight only by their customers (for example, airlines and OEMs). It should be noted, however, that the monitoring exercised over noncertificated repair stations is not as vigorous as many stakeholders would like to see.3
The 9110 standard builds off several themes addressed in 9100 and 9120, including the provisions to prevent counterfeit and suspected unapproved parts from being installed on aviation products. Risk management with respect to the maintenance, repair and overhaul (MRO) activities ensure the processes and work performed don’t produce unintended consequences.
Maintenance, repair and modification of aircraft and aircraft components can be large and complex projects that need to be adequately managed.4 In response, 9110 includes the project management requirements of the 9100 standard for structured and controlled planning and managing of product overhaul, repair and maintenance.
The 9110 standard includes all the new regulatory requirements for MRO organizations, including human factors, which recognize that the individuals performing the work are extremely critical to the outcomes of the process and that physical fitness, physiological characteristics, personality, stress, fatigue, distraction, communication and attitudes can have as much influence on process success as a badly worn tool.
The human factor requirements are designed to ensure safe interactions among the individuals performing the work and the procedures, data, equipment, facilities and external influences. Complementing the human factor requirements is the emphasis on training and training programs, which is an amplification of clause 6.2.2, to meet regulatory statues and to form best practices for all MRO organizations.
Other unique items to the 9110 standard include the emphasis on technical data and safety management systems (SMS). While it is implied in the 9100 and 9120 standards, it is explicit in 9110 that technical data must be available to ensure the aircraft or component—and related operational and emergency equipment—can be maintained for serviceability and airworthiness.
In addition, 9110 introduces to MRO organizations the need for an SMS within their business practices. The 9110 standard introduces some initial components required for a SMS (for example, establishment and maintenance of a safety policy and safety objectives).
Not done yet
While the IAQG has published the revisions to these three standards, the work is not yet complete. To implement these revisions properly, extensive work is ongoing to develop and coordinate a cohesive and well-controlled training process for the registration bodies and auditors of the new standards’ requirements.
This will also include the new audit documentation process (IAQG 9101) that will be part of any certification activity. This process is expected to be available worldwide to all accredited and interested individuals late in the first half of 2010.
The IAQG, which is comprised of many of the major global aviation, space and defense manufacturers, has charted the future quality requirements for itself and the supply chain. The adopting organizations can now select the appropriate standards for their product or service and begin to work on implementation.
- SAE International, SAE AS9120, Quality Management Systems—Requirements for Aviation, Space and Defense Distributors, June 2009.
- Dale K. Gordon, "Risk and Quality Management," Quality Progress, January 2009.
- Sidney Vianna, "Aerospace Standard for Maintenance, Repair, and Overhaul Services Improves Safety," Quality Digest, Sept. 28, 2009.
Dale K. Gordon is the group director of quality and compliance for Woodard Airframe Systems in Skokie, IL. He earned a bachelor’s degree in industrial engineering from General Motors Institute (now Kettering University) in Flint, MI, and an MBA from Butler University in Indianapolis. Gordon is an ASQ fellow, past chair of the American Aerospace Quality Group and contributor to the AS9100 series of aerospace standards.