Sofema Online (SOL) www.sofemaonline.com considers key aspects related to the use of alternate tooling within an EASA-approved Part 145 organisation
Introduction
Compliance with EASA Regulations: Ensuring all tools and equipment meet the standards set forth by EASA Part-145.A.40.
EASA Part 145 Approved Organizations must comply with these standards, particularly in using tools and equipment.
Adherence to the following processes and a focus on compliance, documentation, and continuous monitoring will ensure the effective use of alternative tooling within EASA-approved organizations.
Note: Employing qualified personnel and maintaining robust control systems are critical to meeting the regulatory requirements and ensuring the safety and reliability of maintenance operations.
Here, we consider critical aspects of alternative tooling within these organizations, focusing on key issues and challenges.
• Technical Data Availability – Access to detailed technical data for alternative tools is critical for proper assessment and validation.
• Calibration Standards – Adherence to calibration requirements and standards to maintain tool accuracy and serviceability.
• Personnel Qualification – Ensuring staff involved in the alternative tooling equivalence assessment are adequately qualified.
• Documentation and Traceability – Maintain detailed records and ensure calibration traceability to recognized standards.
Challenges
• Equivalence Assessment – Determining the equivalence of alternative tools to those specified in maintenance data.
• Risk Management – Implementing a risk-based approach for alternative tools when technical data is unavailable.
• Coordination and Communication – Ensuring effective communication between maintenance organizations, overseeing authorities, and EASA.
• Serviceability Monitoring – Continuously monitoring tool serviceability and compliance with calibration schedules.
Best Practices
• Tooling Need Evaluation – Conduct thorough evaluations to identify, classify, and list all required tooling.
• Clear Documentation – Maintain comprehensive documentation for tool specifications, acquisition, acceptance, and validation processes.
• Regular Calibration – Ensure tools are calibrated periodically according to manufacturer recommendations or recognized standards.
• Qualified Personnel – Employ staff with the appropriate qualifications and provide ongoing training for personnel involved in tool assessments.
• Efficient Record Keeping – Use robust control registers and labelling systems to track tool status and serviceability.
Processes
• Tooling Need Evaluation
o Identify and list all tooling required for the intended scope of work.
o Distinguish between permanently available tools and those that are leased or loaned.
o Ensure all tooling complies with maintenance data specifications or has been assessed for equivalence.
• Tooling Classification
o Standard Tooling: Commercially available tools generically identified by type or characteristics.
o Task Specific Tooling: Tools designed for specific maintenance tasks, identified by part number and vendor.
• Use of Tooling
o Standard Tooling: Ensure the end user has the knowledge to determine tool adequacy without formal equivalence assessment.
o Task Specific Tooling: Acquire exact tools as specified or assess and validate alternative tools if using different ones.
• Alternative Tooling Equivalence Assessment
o With Technical Data: Use available data to establish technical specifications, manufacture/acquire tools, and validate their functionality.
o Without Technical Data: Apply reverse engineering and risk-based approaches to establish equivalence, ensuring low-risk assessments are documented.
• Tooling Control Management
o Incoming Inspection: Verify new tools meet applicable standards and quarantine unserviceable tools.
o Control Register: Maintain inventory and status records of all tooling, ensuring traceability and accessibility.
o Labelling: Clearly label tools to indicate serviceability status and compliance with inspection or calibration requirements.
o Serviceability Monitoring: Monitor tool status, segregate unserviceable tools, and ensure timely calibration and servicing.
In summary, the use of alternative tooling in EASA Part 145 organizations is a complex but manageable aspect of aviation maintenance. It demands a proactive and systematic approach to compliance, rigorous validation procedures, and continuous oversight to maintain the highest safety and reliability standards in the aviation industry.
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