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CAVU Café: Royboy’s Prose & Cons

*Note: The views expressed in CAVU Café: Royboy’s Prose & Cons blog are those solely of the writer and are not necessarily shared by the Aviation Suppliers Association or the Association’s staff, members, or Board of Directors.

 

   About Roy Resto

 

C of C’s, BEWARE THE DIFFERENCES

Some gestures are universally understood. When a person with first aid skills observes another person at a restaurant frantically clutching their throat, that is a universal sign that aid should be rendered to extricate the offending victual from the patron’s airway. One of my callings in life is to let drivers know when one of their taillights is out. I’ll pull up alongside and gesture with a circular motion for them to roll down their windows, whereupon I inform them of the condition requiring further maintenance. That circular-motion gesture continues to be universally understood, even though most cars these days have electric windows. When it comes to understanding C of C’s, however, it seems that these documents are not so universally understood.

 

I have often overheard conversations between sales/purchasing persons describing the types of documentation to be expected with a shipment. “C of C” is quite common, but not all C of C’s are created equal, and in some cases, not worth much. The following discussion refers to C of C’s as may be expected from a manufacturer or distributor of new or aftermarket parts.

 

WHAT DO THESE MEAN?

  • Certificate of Conformity
  • Certificate of Compliance
  • Certificate of Conformance

CERTIFICATE OF CONFORMITY:

Certain words in aviation carry a great deal of weight, such as the term ‘Airworthy’. Another term with considerable gravity is ‘Conformity’. When someone attests that an airplane, assembly, part, repair, or alteration conforms, they are generally stating that it conforms to one or a combination of the following:

  • Drawings
  • Specifications
  • Approved Instructions
  • Industry standards or approvals
  • Aviation Regulations
  • Company standards
  • Government Approvals

In the aircraft parts sales world, these are the characteristics of a Certificate of Conformity:

  • They are issued by a manufacturer. Note: some distributors, such as those with extensive fastener sales, are equipped to make determinations of conformity. But the vast amount of Certificates of Conformity are issued by the manufacturer.
  • They state that the part conforms to some of the subjects cited above
  • They are signed
  • The person signing is ‘authorized’ by the manufacturer to do so.
  • They are indeed most valuable as the document to determine airworthiness.

CERTIFICATE OF COMPLIANCE:

Usually, these are affirmations that the supplier has complied with your purchase order. I’m found to scratch my head while wondering about the worth of this type of C of C. Excuse me but remember your Business Law 101 classes? Is a Purchase Order a contract? Yes it is. If you have not accurately fulfilled the PO, you have not fulfilled a contract, so such a Certificate of Compliance seems wholly superfluous.

 

CERTIFICATE OF CONFORMANCE:

These seem to fall somewhere between the two previously discussed types.

 

REALITY CHECK, PLEASE:

Greatly clouding this discussion are the following realities:

  • There are no regulations that state one or the other C of C applies, or that language must follow certain guidelines. Because of this:
  • You’ll often see the terms mixed from one supplier to another
  • Some suppliers such as Distributors, Brokers, or Stockists use the term Certificate of Conformity on their own documentation, but they have not, nor are equipped to make such determinations of Conformity.
  • In referring to their own documents, some distributors use the term C of C, when they should be using the term “Material Cert.” (Such as an ATA Spec 106 cert.).
  • Some agreements and contracts require the supplier to provide a specifically worded C of C, but there is no harmony in this language either. Of course in this case you must comply with that agreement or contract.
  • Any C of C usually does not look like a ‘certificate’. The term harks back to the day when indeed, these did look like frame-able certificates with ruffles and flourishes at the margins, and a few still carry this format. Regardless, the C of C statement may be a tiny 4-font paragraph, or in a Material Certification made to resemble an 8130-3 or EASA/CASA/TCCA form 1.

THE REGULATED WORLD OF CONFORMITIES:

Up to now we’ve basically confined our discussion to the distribution of aircraft parts. If it seems there’s not much uniformity in that world concerning C of C’s, then my subtle hints have not been missed. For persons not involved in the distribution of aircraft parts, there really is a world of regulated conformities. These typically involve, but are not limited to, activities such as the following:

  • The qualification of new parts, engines, or aircraft undergoing the certification process
  • The inspection of, and declarative conformity statement that an aircraft or part thereof, which has undergone modifications or alterations, has met the requirements of the approved data, and conforms to that data.

In this world, statements of conformity, language, and the forms to be used are highly regulated by the applicable Civil Aviation Authorities.

 

BEWARE THE DIFFERENCES

The question becomes, What value do you place on C of C’s and why? Consider the following, re-summarized:

  • Some persons use an ATA Spec 106 Material Certification (or a non-copywrited variation) and call this their C of C. In the landscape version, these look amazingly like an 8130-3 or EASA/CASA/TCCA form 1. Unenlightened recipients of such a form may place undue value on these because of this resemblance. These are not airworthiness documents! These ‘certs’ do have value however, as a form which summarizes that the supplier (such as a distributor, broker, or stockist) attests to the information regarding trace, condition, and last certifying company, among others.
  • I’ve read some C of C statements that are so weak, I’m seen to gesture a roll of the shoulders and accompanying ‘So what?”, worthless. Many years ago during a meeting of the FAA’s Suspected Unapproved Parts Steering Committee (now disbanded) of which I was a member, an airline buddy presented a compilation of about a dozen actual C of C statements from as many sources. There were great variations which continue today, so beware!

As with the great variation in C of C statements, there is variation in written processes and procedures, agreements, contracts, legal reviews, and in some locales, laws. This blog is not meant to pre-empt those, but to be food for thought. Feel free to post your comments on the blog site; they are welcomed.

 

Back to gestures. Have you noticed, since face to face social interaction has been greatly supplanted by electronic social media, the dominance of hand, bodily or facial gestures is on the wane? Because of this, the reaction has been the immergence of those emoticons; yes my lips are pressed and my head is shaking from side to side ;-)

 

 

Over ‘n out

Roy ‘Royboy’ Resto

www.linkedin.com/in/royresto

Posted By Roy Resto | 1/9/2013 11:28:50 AM
 

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