Blog  

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 salespersons 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

• 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.

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 use the term Certificate of Conformity, 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.).

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 regulation 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 or aircraft undergoing the certification process

• The inspection of, and declarative conformity statement that an aircraft or part, 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.

Back to gestures, and the “roll down your window” signal: There is shortly going to be a generation of youngsters that will have no idea of what that means, since I know of no modern car that does not have electric windows. On the day that I roll up to a car and give the “roll down your window” gesture, and I’m met by a momentary quizzical look, followed by an obscene gesture, I’ll know that day has arrived.

6-6-08

Roy Resto - VP Technical Operations, FAA-DAR
Phone: 414 875-2191   Fax: 414 875-0200
royboy@mbtrepair.com

site map