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Certificate of Conformity

You are now eminently qualified to start a 145 company

Administrator
Shoreham EGKA, United Kingdom

I just did a certificate of conformity at work. In this case, creating your own means your customer doesn’t find out who your supplier is

The only ones I know are 2cv handbrake Robin flap lever and 2cv door lock Robin canopy lock, but there must be millions

EGHO-LFQF-KCLW, United Kingdom

The funny bit is when you (the mfg) don’t have ISO9000 so somebody who wants it buys your product via an ISO9000 stockist. We’ve had loads of that over the years.

This happens in aviation too. You can get an 8130-3 from some US parts stockist, covering a pile of bits, some of which they bought from non-145 manufacturers. And same in EASA-world; I posted loads of dodgy CofCs here over the years, like that 1968 p-clip – example. A CofC issued by a stockist is even more worthless than one issued by a manufacturer. As previous link shows, the stockist business is rife with old parts which were bought up from stocks from gone-bust airlines and which are sold simply as brand new.

The problem with us getting cynical like this is that it p1sses off everybody who works in the trade – because their livelihood relies on it. Then they go on strike and stop posting

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

ISO9000. It’s junk

I’m so glad I’m not the only person who thinks that.

Peter wrote:

anally retarded “quality manager”

A few years ago we were the only people in Europe that stocked a particular product that conformed to a new quality standard in Brazil. We had an enquiry from a new customer, who sounded very desperate (so the price went up, of course ). They paid, we shipped the goods. I waited a few days, and called them trying to sell them other (non-Brazilian) products:

  • Customer: “are you ISO9001 certified?”
  • Me: “no”
  • Customer: “ we can’t buy from you then”
  • Me: “that’s odd, because we supplied you last week”
  • Customer: “impossible, we can only buy from ISO9001 certified companies”
  • Me: “it was you I spoke to last week, and here’s your order number”
  • Customer: “no, that could never have happened”
    And so on…
EGHO-LFQF-KCLW, United Kingdom

In fact I got fed up doing it (it’s a waste of my time) and added a bit of text to our delivery notes saying that the delivery note is also the certificate of conformity. I know I’m not selling rubbish, so as far as I’m concerned it’s not necessary

We do the same

But some customers want a specific format.

The big problem is that you rarely find out if a particular customer has a really anally retarded “quality manager” who simply rules “do not buy from Company X” and Purchasing then goes elsewhere because everybody wants an easy life. Then “you” are happy because nobody has questioned your CofC. This is why so many companies got ISO9000. It’s junk, but it keeps the doors open. My little business never did ISO9000 but I have probably lost a lot of business by not having it. You get a consultant in for about 5k and he generates a load of forms and a quality manual; it’s all fake.

Yes, but neither the FAA or anyone else for that matter may ever even pay a visit to the manufacturer of standard parts. The factory could in principle be a warehouse selling cheap parts and CofCs, or a combination

Yes; it is worthless in reality.

It is like a non EASA145 company issuing EASA-1 forms, by renting the printing facility of a nearby EASA145 company. I got hammered here some years ago for saying this was pretty worthless, but the same guy then emailed me saying he does exactly that! Because he cannot afford his own 145, so a bunch of them share somebody’s 145…

The system is as good as the people operating it. In reality your best and probably only assurance of genuine parts is that nobody will bother counterfeiting an obscure part. I mean, if you bought a KLN94 on US Ebay, it’s not gonna be a fake, is it Or an APEM milspec toggle switch which is €100 or €10 on Ebay in original packaging (I like those). But a Canon camera battery on Amazon is about 90% likely to be a fake one.

Administrator
Shoreham EGKA, United Kingdom

I sometimes have to do certificates of conformity at work. Essentially MS Word, copy paste customer’s name, address, invoice number and product specification. If it looks really serious I might sign it and use the company stamp. But the customer should know all this already

This is usually for more regulated markets, e.g. medical (or aviation), where someone has to put a piece of paper in a file. Like supplier questionnaires, it’s unlikely the piece of paper is looked at before it’s put in the file, or ever looked at again.

In fact I got fed up doing it (it’s a waste of my time) and added a bit of text to our delivery notes saying that the delivery note is also the certificate of conformity. I know I’m not selling rubbish, so as far as I’m concerned it’s not necessary.

EGHO-LFQF-KCLW, United Kingdom

Peter wrote:

A CofC may be a legal requirement by the national CAA, as A&C says it is in his case.

Yes, but neither the FAA or anyone else for that matter may ever even pay a visit to the manufacturer of standard parts. The factory could in principle be a warehouse selling cheap parts and CofCs, or a combination. The system relies on the industry itself checking up on the manufacturers. For Boeing for instance, it’s in their interest to do a continuous and thorough investigation and surveillance of the manufacturer. A re-seller may have a much larger interest in price over quality, and no one checks if the re-seller do a proper investigation of the manufacturers. The link is broken, a CofC is not worth anything, unless of course, the re-seller use the same manufacturers as the big industry players. And if they do, then a CofC is a redundant piece of paper, just like it is for Boeing. They have no use for, and don’t use CofCs.

The elephant is the circulation
ENVA ENOP ENMO, Norway

No form needed for Part 91. An FAA A&P has the authority to inspect and declare airworthy.

However, most European based A&Ps, and European based FAR145 companies, don’t know this, or don’t agree with it. In the case of a company supplying a part they have an incentive to source a higher priced part, of course.

Administrator
Shoreham EGKA, United Kingdom

Ok I see that for an EASA aircraft you need a CofC to fit the part.

What about my N reg aeroplane?

As an EASA 145 company the C of C gives us the authority to fit parts

One point worth amplifying is that the CofC / 8130-3 / EASA-1 may well be a legal requirement (per EASA) for accepting the part from the supplier, but it doesn’t in itself authorise its installation.

For example, someone wrote years ago on the US Socata site that if a part comes with an EASA-1 from Socata, it is legal to install on a TB aircraft. That is complete nonsense. The form just certifies that the part is what it says it is, and/or was inspected IAW some spec, etc. Many people – particularly in Europe, with the EASA-1 – think there is an implied suitability for an application, but there is no such thing. PMA, for example, is something else.

There are no certified switches in aviation. Strange, but true. A switch is deemed “certified” along with the aircraft.

That is probably true for most small parts. You probably can’t find a TSOd toggle switch… Also the US has the “standard parts” regime which covers nuts, bolts, nutplates, etc. But these still need to come with a bit of paper, if required in your jurisdiction.

I note that some of the switches for my aircraft come with a CofC and cost 60 quid. Yet identical ones without cost 20 quid. I struggling to see why my one can use the former and not the later.

Ostensibly, traceability i.e. assurance it is not a fake part. It may be blindingly obvious that nobody would fake some obscure item, but…

We like to think that a bolt from Aircraft Spruce is a quality item. This is not so. It may or may not be so, and a CofC means nothing

A CofC may be a legal requirement by the national CAA, as A&C says it is in his case.

Of course the part can still be a fake part. The way this is usually done, certainly in the electronic component business, is this: somebody makes 10,000 of a certain fake chip. It is possibly just an empty package (no silicon inside). He buys 10,000 of the real part, and sends it back for a refund. But he sends back the fake ones. He then sells the real ones somewhere. I’ve had that… it works because the distributors don’t do any testing (or meaningful inspection) on the parts which get returned.

Ultimately, yes, you can get a brick with a CofC. And anyway a CofC (or any “form”) is meaningless for any part which doesn’t have a serial number (or a batch number, at a stretch) printed on it. But that is being practical, not legal

Administrator
Shoreham EGKA, United Kingdom
17 Posts
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