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This text discusses the authorities' recognition of "other parties" approaches in the context of the ICOP scheme, addressing key questions and providing general views. It explores topics such as compliance with regulations, industry control of the scheme, and opportunities for authorities' oversight.
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Authorities Recognition of “Other-Party” Approaches Initial Authorities Comments 6th International Production & Airworthiness Meeting Boston, United States, 1st September 2005
Authorities Recognition of “Other Parties” Approaches Question: • Does the Authority Leadership Team agree that the ICOP scheme is acceptable ? Response from Leadership Team: • There is insufficient detail in the current proposal for the Leadership Team to accept the ICOP scheme, specifically:-
Key Topics for Authorities Authorities Recognition of “Other Parties” Approaches • Does the proposal satisfy FAR21/Part 21 ? • How will Industry actually control the scheme ? • Why is the proposal different to the PRI-NADCAP model ? • What are the opportunities for the Authorities to oversee ?
General Authorities Views Authorities Recognition of “Other Parties” Approaches • Supportive of the overall concept to reduce multiple assessments – no mention of use of a PAH/POA approval to demonstrate interface where it exists. • Analogy with P&AC Team 3 task to recognise other Authority approvals. • Can comply with FAR21/Part 21, provided that the POA/PAH can demonstrate that their specific requirements to meet the applicable requirements are addressed as when using any other third party – this is already accepted for participating organisations for the NADCAP model.
Key Authorities Questions (1) Authorities Recognition of “Other Parties” Approaches • Objective is for any POA/PAH/Supplier to recognise the other party scheme. Unless an Organisation participates in the IAQG Management activity, how can they demonstrate control of the scheme to meet FAR21/Part 21 requirements ? • What resource will be allocated to manage and maintain the system (including cross-sector standardisation) ? Previous attempts for JAA recognition encountered problems in this area. Current NADCAP scheme has significant resource commitment in order to achieve the global benefits.
Key Authorities Questions (2) Authorities Recognition of “Other Parties” Approaches • Should there be a mechanism for Authority oversight or participation in Certifying Bodies & Registrars ? • What are the benefits to the Authorities in accepting the scheme ? Reduction in number and competence of Supplier QA personnel employed by the primes would be undesirable. Benefit of releasing resource to widen surveillance of suppliers/second and lower-tier subcontractors and to support process and product audits is no longer being mentioned.