September 17, 2021, ©. Leeham News: Last week, we looked at the Production facilities and tooling. In order to bring in revenue, we need to deliver aircraft.
But to have the right to deliver aircraft we need a Production Certificate in addition to our Type Certificate for the design. We need to start the work to get a Production Certificate well before we flight test the aircraft and complete the type certification work, Figure 1.
Now that things are going in the right direction in the development program and we have got our design certification project on track, we need to think ahead to obtaining production certification.
As mentioned in previous articles, in order to produce type-certified products, we need to have a Production Certificate or Production Organization Approval. Many jurisdictions, such as the US and Europe, allow production without a Production Certificate for a short period of time. This gives OEMs a bit of time to complete the production certification process after type certification.
Requirements on conformity, markings, record keeping, etc., are still applicable during this time. The authority can also inspect or test the produced units to ensure compliance. However, the reality is that this grace period is not long enough to establish the required systems and agreements if you don’t start long before you get your Type Certificate.
There are multiple requirements that an applicant needs to meet in order to obtain the production certificate. The biggest component is the approval of the Quality Management system.
The production certificate holder needs to develop detailed procedures for every step of the production and its quality checks, document them in a quality manual, and obtain approval for it all from the authority.
The system needs to give the regulator confidence that the OEM will manufacture products consistently conforming to the approved type design. For example, how does the manufacturing team know that they are using the right parts when assembling the aircraft (and not parts made to earlier/later production releases of the aircraft).
How do you avoid that the wrong specification part or even test parts or parts received back for service end up in a production aircraft?
When the manufacturing team receives a part that does not conform to the type certified design, the manufacturing team needs to take action. How parts non-conformances and damage/repairs shall be handled is closely regulated.
Is it OK to repair the part and make it conformant or must the part be scrapped? What are the revision markings that shall be on a part that has been worked on to make it conformant?
Perhaps one of the most challenging aspects, and part of why we need to start early, is the requirement for supplier oversight and control. As the Production Certificate holder we will be responsible to ensure our supply chain also has an appropriate quality management system and sends us only conforming parts.
We must have the appropriate inspection, change management, and notification processes in place to manage this over time. We will also be subjected to regulatory audits, and if our house is not in order the regulator can stop the production.
Many suppliers for other industries may not want to constrain their own supply chain and production processes with these burdens (and therefore refuse our business). Others are OK to work in aeronautics but will charge us significantly more (sometimes as much as 10X!) for parts as a result.
We must realize it’s a substantial burden and risk to engage with suppliers that don’t have experience of being a supplier to this industry. We must teach the supplier what is required and closely monitor him for compliance for quite some time.
Keep in mind, the production certificate holder is responsible for ensuring supplier-provided articles conform to the design. If we do not flow down quality requirements and reach agreements with suppliers during the initial program we could end up stopping the line or having a significant cost increase as we have to adjust the work scope with a supplier or even seek for a replacement.
If there’s a quality problem that wasn’t found before delivery, such as the Boeing 787 circumferential join issue, the OEM must be able to track and designate all non-conforming aircraft and then propose an action plan to get them to full certification standard.
Keep in mind, these are only a few examples of the quality system requirements you need to implement to receive a Production Certificate. The applicant OEM and his supply base must meet more requirements, such as having a data retention procedure in place and established own audit programs to get a production certificate.