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

“REMARKS” On Your Documents Are Your Friend

Me at home: ‘Honey, where’s the ketchup, did you finish it?’

Wife: ‘It’s in the fridge’

Me: ‘I looked, it’s not there’

The sound of pounding footsteps on a mission are heard marching to the fridge, whereupon an impressive and commanding opening swing of the door is given, the wife’s hand swivels like a whip, tip towards the now mysteriously reappeared bottle of ketchup and voila, there it is. I bow and kiss her backhand then meekishly apply the condiment.

Occasionally solutions to our problems are right in front of us, and like ketchup on a burger, sometimes it’s advisable to add additional words to season our documents for the many reasons we’ll discuss.

What are one of the entries that all these forms have in common?

  • ASA Statement Form
  • ATA Spec 106
  • Other Material Certifications
  • FAA 8130-3
  • EASA form 1
  • TC Form 1
  • CAAC ACC 038
  • ANAC Segvoo
  • CASA Form 1
  • CAA Form 1

As you’ve likely deduced, these all have provisions for Remarks. From my experience this feature is one of the most underutilized blocks in any form.

Use of this block can prevent a customer from rejecting your part or be used to explain issues that might otherwise cause angst upon receipt. Let’s look at some real-world examples.

  • I was in the process of issuing a DAR 8130-3 for about twenty new-condition Igniters. These were all serialized. The problem was they were in opaque packaging, and I could barely read the serial numbers on the parts. I would have to open each OEM packaged part and reseal them after the s/n verification. The applicant (old school term for the person asking that I issue the 8130-3) cringed that I was going to do so because the customer would see the OEM packaging had been opened and resealed and possibly reject the order for these new parts. The solution? I put a comment in the Remarks block:
    • “Note: The undersigned opened and resealed these Igniters for the purpose of verifying the serial numbers.”

    There was no problem with the customer and the Igniters were accepted.

    • Another time one of my Inspectors brought a part to my attention which had unusual coloration patterns on it. The MRO that Overhauled it said it was normal but still my Inspector and I were not 100% comfortable with it. This was the part:
    • We took some pictures and sent them to the Purchasing Customer who also confirmed it was normal. Based on this I insisted the Inspector put this in Remarks on our Cert:
    • “Note: The potentially unusual coloration patterns was shown to Mr. XXXX on XX/XX/XX via emailed pictures, and he stated this was normal and acceptable.”

    The part was accepted with no problems.

    • SIDEBAR: About similar occurrences: Many times, a lot of you communicate any unusual circumstances to your customer who, perhaps by email or a phone call say it’s alright and to ship it. ALWAYS keep this in mind: Is the person who told you to ship it the same person or department who will perform the receiving inspection? Unless your customer is a very small company, this is unlikely. So, the part goes to the customer, the Inspector rejects it and puts it in the hold area peppered with a new blemish against your company, only for the details to be sorted out a week later. In these situations, the timely use of a Note in the Remarks section of your cert (as per above for example), would have saved you time and embarrassment and contributed to on time payment.
    • On another occasion a friend asked me to evaluate about 15 pages of trace. Embedded within the pages of a Tear Down report from an MRO was the fact that the application of a Service Bulletin had changed the dash number of the part. This bit of information helped explain some concerns expressed about the trace paperwork. I strongly urged my friend to place an explanatory note in the Remarks block of his Material Certification to explain these acceptable circumstances. Salted thusly, the part and its 15 pages of Trace Documents sailed through the customer’s receiving inspectors.

    By the way, I wrote an article on the importance of MRO Tear Down reports which I hope you’ll find interesting. Here’s the link:

    https://www.aviationsuppliers.org/THE-VALUE-OF-TEAR-DOWN-REPORTS

    • Those silly ‘Fresh Tag’ requirements: Lets say you have a New condition part with an EASA Form 1 which is 4 years old. Your customer wants the part but has a 2-year fresh tag requirement. A common option is to have it sent to an MRO for a fresh tag. The problem is that an MRO cannot issue a tag who’s status is NEW… only approved manufacturers can do that. The MRO can state Inspected, for example. In your PO to the MRO ask that they put a statement in the Remarks block that the part was received in New condition on EASA Form 1 FTN (Form Tracking Number) 123456. When you ship the part send the EASA Form 1 and the fresh tag.

    Even though the fresh tag is now in Inspected status, under this simple example Royboy would support you marketing the part in New condition since the part still has zero Operating Time and Cycles, which is the de facto definition for New parts.

    By the way, regarding the ‘silly’ requirement in my characterization, here’s another article I wrote directly challenging it:

    https://www.aviationsuppliers.org/aftermarket-tags-overhauled-vs-repaired-vs-2-years

    TO MANUFACTURERS AND MROS.

    If your parts have shelf life, PLEASE put this information in the Remarks Block of your Airworthiness Release Certificate; some of you do and some of you don’t, and it may get overlooked on page 3 of your certs or Tear Down Report.

    IN SUMMARY: Regardless of what form and ERP system you are using, these all have provisions for the addition of free text. Use it for Remarks!

    This article was written without the use of AI assistance.

    Over ‘n out

    Roy ‘Royboy’ Resto

    www.AimSolutionsConsulting.com

    Posted By Jeanne Meade | 4/2/2024 11:40:42 AM
     

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