OTTO OGYR627Y Quality and Repair Station Instruction Manual
- June 1, 2024
- OTTO
Table of Contents
OTTO OGYR627Y Quality and Repair Station
Product Information
Specifications
- Manufacturer: OTTO
- Address: 2 East Main Street Carpentersville, IL 60110
- FAA Repair Station No.: OGYR627Y
Product Usage Instructions
Access by EASA and FAA
Outside audits by bodies such as suppliers, customers, and regulatory
bodies like FAA and EASA are welcomed at any time. OTTO cooperates with
investigations and enforcement of EU regulations and EASA procedures.
Work Orders/Contracts
OTTO receives a separate contract for each repair request. Contracts are
reviewed, any ambiguities are clarified with the customer prior to repair
commencement, and repairs are checked against the customer repair request for
conformance.
Approved Design and Repair Data
Communication of repairs is done through the OTTO RMA and W/O systems.
Customer approval may be required before repair commencement. OTTO’s repair
data is automatically approved as it is the design approval holder.
Airworthiness Directives
OTTO ensures applicable AD’s are current and verified before repair
commencement. Upon knowing applicable AD’s, the Repair Work order is amended
for completeness. A statement in Section 12 of the 8130-3 Tag indicates if
actions were concluded.
Release and Acceptance of Components
For EASA Repair, OTTO certifies that work was carried out by EASA Part-145.
Any conflicts between AD and customer requirements are documented on the
applicable 8130. Details referring to AD, service bulletins, and approved data
are referenced in block 12.
FAQ
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Q: What should I do if there is a conflict between Airworthiness Directives and customer requirements?
A: Any conflicts should be documented on the applicable 8130. Details referring to the AD, service bulletins, and approved data should be referenced in block 12. -
Q: Is customer approval required before repair commencement?
A: In cases where customer approval is required prior to repair commencement, it shall be obtained.
EASA Supplement To The OTTO Quality/Repair Station Manual
OTTO 2 East Main Street Carpentersville, IL 60110
FAA REPAIR STATION NO.: OGYR627Y
This supplement does not form part of the FAA FAR-145 Repair Station Manual.
Compliance with this EASA Supplement combined with the ongoing FAA FAR-145 Repair Station Manual forms the basis for OTTO’s European Aviation Safety Agency (EASA) Part-145 approval. The enclosed material outlines OTTO’s obligations for EASA Part-145 approval as specified in the EASA MAG guidance.
List of Effective Pages
OTTO’s QRSM will always be revised in entirety. See Section 5 of the OTTO Quality/Repair Station Manual. OTTO will comply, and if required, revise our OTTO Quality/Repair Station Manual within ninety (90) calendar days of the applicable MAG notification.
Amendment Procedure:
See Section 5 (Document Control) for policies and procedures governing changes/amendments to this supplement and/or the Quality/Repair Station Manual. Within section 5, responsibilities for coordination and notification to the FAA (along with EASA if applicable) are outlined. OTTO understands that omissions to the above may result in the revocation of FAA and/or EASA approval.
Introduction:
Since 2000, OTTO has become the major source for the supply of various flight grips deployed throughout the world. Many of our OEMs have required that OTTO also become capable of repairing the grips we manufacture. By statement of this document, OTTO understands and intends its continued conformance to FAR Part 145 and 43.
Accountable Manager’s Commitment Statement:
This Supplement in conjunction with OTTO’s Approved FAA FAR 145 Quality/Repair Station Manual (Document# lQA00O00l) defines the organization and procedures upon which the condition of the EASA approval is based. By my signature, the applicable procedures which govern the process for any/all work done under the conditions of the EASA Part- 145 approval will be adhered to. It is also understood that the above noted procedures will not override the necessity of compliance with any additional requirements supplied by the EASA. OTTO also understands that EASA will issue an Approval Certificate and our repair station in an EASA published list whilst the EASA is satisfied that the procedures are being followed and work standards remain maintained. The fact of failure to comply with EASA requirements (or failure to perform according to FAA FAR 145 documentation) may result in revocation of certification is understood. OTTO will make sure that this statement is always signed by the current Accountable Manager to ensure continuous EASA Part-145 approval.
Approval Basis and Limitation
OTTO understands and agrees that all work will be performed in accordance with our current FAA FAR 145 Repair Station Rating of “Limited Accessory.” No work will be conducted which exceeds this distinction. However, OTTO understands that if the above is deviated, solely on a case-by-case basis, approval must be obtained via the JMCB.
Access by EASA and FAA
As stated in Section 17 (Internal Quality Audits) of the OTTO Quality/Repair Station Manual, outside audits, by any bodies (i.e. suppliers, customer, regulatory, FAA and EASA) are welcomed at any time. OTTO accepts investigation and enforcement relevant EU regulations and EASA procedures; OTTO as well, will cooperate with these actions.
Work Orders/Contracts
By OTTO’s Quality/Repair Station Manual, OTTO will receive a separate contract for each repair request. Upon receipt, that contract is reviewed. And although OTTO’s customer remains responsible for ultimate clarification of contract verbiage, any ambiguities are clarified with the customer before the commencement of the repair. Once the repairs are concluded, they will be checked against the customer repair request to ensure conformance.
Approved Design and Repair Data
OTTO is the OEM for the item being repaired. Our repair station will operate as follows:
- Product will be flagged for repair,
- Initial consult will be done to corroborate customers’ need for repair (see example of Repair Station Matrix in Appendix B),
- In-depth consult will be done to check for specific reasons for repair need, as well as any other undocumented (by customer) requirements for repair (see example of RMA in Appendix B),
- Once applicable AD’s and SB’s have been verified, a detailed repair procedure will be provided to the repair station via an OTTO W/O (see example of Router Appendix B),
- Repairs, and acceptance of repairs (with appropriate tagging), will be conducted prior to release (see example of 8130 on page VII of Appendix A, and example of an ATP in Appendix B).
Communication of the above-stated repairs will be communicated through the
OTTO RMA (by OTTO document 2QA000034) and W/O systems. In cases where customer
approval is required prior to commencement of the repair, it shall be
obtained.
For the fact that OTTO is the design approval holder, our repair data shall be
deemed automatically approved. Products are not considered critical (flight
safety), so resultant data shall not be sent to EASA for approval.
Airworthiness Directives
- In accordance with Section 9 (Process Control) of the Quality/Repair Station Manual…only those products that are controlled via OTTO’s ERP system, with the designation of “FAA” may be repaired. Controlled items will all contain revision controlled drawings, specifications, and equipment available to company personnel required for repair. Any additions to this list will be distributed to the FAA upon initiation of the change. The FAA Repair Station Capabilities list, or products which OTTO is allowed to repair, will be kept on OTTO’s ERP system.
- Prior to the commencement of repair, OTTO understands the responsibility (specifically given to the OTTO QA department via Repair Work Order direction) to ensure the applicable AD’s are current and verified. Once any/all applicable AD’s are known, the Repair Work order will be amended for repair completeness. Ultimately, OTTO will provide a statement in Section 12 of the 8130-3 Tag indicating that the above action was, or was not, concluded.
Release and Acceptance of Components
OTTO understands and agrees that all work will be performed by our current FAA FAR 145 Repair Station Rating of “Limited Accessory.” No work will be conducted which exceeds this distinction. OTTO is the OEM for Components. Repair components used for repair will be new, and will never use used components. Once all products deemed repairable is completed, the rules governing the issuance of an 8130-3 tag will apply (in accordance with OTTO document 3QA000042). See attached example of a proposed 8130-3 tag for EASA Part 145 use.
Specifically for EASA Repair, the following note will be applied in Section
12:
“OTTO certifies that the work specified in Block 11/12 was carried out by EASA
Part-145 and in respect to that work, the component is considered ready for
release to service under EASA Part 145 Approval Number 145.6100”
If there is a conflict between the AD and the customer’s requirements, and the
end result means that the AD was not accomplished, it shall be documented on
the applicable 8130. All details referring to the AD, service bulletins,
and/or approved data will be referenced in block 12. 8130 tags Blocks 13a-13e
shall not be used.
Details to “other regulation specified” noted in Block 14a, will be provided
in Block 12. OTTO also understands that the only two cases where this applies
are as follows:
- Maintenance was not carried out
- Cases where particular maintenance requirements was only EASA approved, and not FAA-approved.
Authorized Signature Approval of 8130-3 tags is solely enforced by OTTO’s current roster of Certified Airmen Inspectors, or those holding a valid Repairman Certificate.
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Certificate of Airworthiness (C of A) Validity
- Does not apply to OTTO’s Limited Accessory rating.
-
Release of Aircraft After Maintenance
- Does not apply to OTTO’s Limited Accessory rating.
-
Reporting of Unairworthy Conditions
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In accordance with Section 13 (Control of Non-conforming Product), the following rules will apply:
If finished goods are found to be out of specification, the Director of Quality, or delegate, will determine severity of issue and if necessary, recall Finished Goods from customer.
Defects that are determined to be unairworthy, the Director of Quality Systems, or delegate, will report such situations immediately (within 72 hours), in writing, to EASA, the aircraft/component design organization, and the customer or operator.
At a minimum, the notification will include the following: -
Aircraft Registration Number
-
Type, make, and model of the article
-
Date of discovery of the failure, malfunction, or defect Nature of the failure, malfunction, or defect
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Time since last overhaul
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Apparent cause of the failure
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Above notification will take place using the following mediums:
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EASA online platform, Occurrence Reporting Form
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FAA Service Difficulty Report or FAA SUP report.
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In addition, any unairworthy condition shall follow the rules set forth in EASA Part 145, specifically requiring the use and proper distribution of EASA Form 44.
Product dispositioned for scrap shall be conspicuously marked, or positively controlled until physically deemed unusable.
Quality Monitoring System
Comprehensive, planned and documented internal quality audits are carried out at least once a year. The internal quality audits verify the effectiveness of the quality system, and verifies that the quality activities comply with the established, planned arrangements. With sufficient notice, outside audits, by any bodies (i.e. suppliers, customers, regulatory) are welcomed at any time.
Audits (both process and product) are scheduled on the basis of the status and
importance of the activity. Process and product audits will be required on
each product line (both controls and communications) within the above stated
schedule. In addition to the applicable standards, Internal Audits are
designed to meet contractual and/or regulatory requirements. Audits are
conducted by individuals independent of the area being audited. Management
having responsibility for the audited area, shall review, agree, and correct
any deficiencies highlighted by the audit within an agreed period. This will
encompass all internal departments, as well as, OTTO’s FAA Repair Station.
OTTO will repair only those items for which we are the OEM. Detailed
procedures used for the initial build of product are to also be used for the
repair orders. This process will ensure that a safe product will be delivered
according to the compliance guidelines outlined in 14 CFR, Part 43, Part 45,
and special EASA conditions.
Nonconforming conditions are followed up as a result of corrective action. The
corrective action process will be by Section 14, Corrective Action.
-
Provision of Hangar Space for Aircraft Maintenance
Does not apply to OTTO’s Limited Accessory rating. -
Contracted Maintenance
OTTO is the OEM for the item being repaired – there will be no contracted maintenance used in the repair of any returned item. -
Human Factors
The Director of Quality Systems shall be the Accountable Manager for the company’s FAA Repair Station. The duties include maintaining an adequate and knowledgeable staff to plan, perform, supervise, and inspect the work being performed. The Director of Quality Systems may delegate all duties to qualified persons; however, such delegation does not relieve the Director of Quality Systems of the overall responsibility.
Although company governing policies and procedures are included within the company handbook, individual departmental managers shall also be responsible for; but not limited to:-
Ensuring that all staff is adequately qualified experienced and trained to perform their assigned tasks, which includes
The monitoring of employee performance to ensure not only acceptable performance, but also
includes the well-being of the employee from not being over-worked. -
OTTO’s safety culture
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Overall company communication protocol
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Teamwork building
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Professionalism and integrity
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The quality of work performed by personnel within their respective departments.
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Including Human Error.
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Initiating, implementing and maintaining work instructions for their departments.
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Various procedures exist that allow for detection and rectification of maintenance errors which may endanger the safe operation of an aircraft. In addition, alternate procedures govern that personnel are trained to ensure an understanding of the Human Factors principles. These training sessions are recorded and maintained in the individual personnel file.
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Ensuring that all staff are familiar with, and have ready access to company and departmental procedures, and that the relevant procedures are effectively implemented.
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The provision and maintenance of an infrastructure required to achieve product conformity. This infrastructure includes;
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buildings, workspaces and associated utilities (including temperature, humidity, cleanliness, lighting),
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process equipment (both hardware and software),
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supporting services (such as transport or communication), and
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identification of resources to support operation and maintenance of the product.
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Air Carrier Line Stations
Not Applicable. -
Work Away From a Fixed Location
Not Applicable.
Example of a completed FAA Form 8130-3
Documents / Resources
| OTTO
OGYR627Y Quality and Repair
Station
[pdf] Instruction Manual
OGYR627Y, OGYR627Y Quality and Repair Station, Quality and Repair Station,
Repair Station, Station
---|---
| OTTO
OGYR627Y Quality and Repair
Station
[pdf] Instruction Manual
OGYR627Y, OGYR627Y Quality and Repair Station, Quality and Repair Station,
Repair Station, Station