What is COS?
While PMA manufacturers may be primarily concerned with manufacturing a part to be used in service, they also have a responsibility to provide support for that product after it enters service. Perhaps the biggest element of this duty involves ensuring that components maintain safe operation after delivery.
Continued Operational Safety (COS) is the answer to this industry burden. In Order 8110-42C, the FAA requires all PMA holders to be “responsible for the continued operational safety of their designs” and suggest the use of a COS program for complex or critical parts.
In November 2004, the FAA challenged the PMA industry to develop guidance on the implementation of a COS program. Since that time, MARPA has outlined the ideal setup for such a program using the experience of the association’s membership. While a COS program can take on many forms and include a variety of different elements, the MARPA guidance provides a standardized methodology for ensuring operational safety of a manufactured part.
Link to MARPA COS Guidance
Elements of a COS Program
Under the MARPA guidance, an effective COS program implements the following three procedures into the company’s quality system: problem prevention; part monitoring; and problem response actions. Information and experience gained from the latter two elements are also fed back into the preventative measures within the program.
Problem Prevention
- Preventative procedures include internal audits to monitor compliance with airworthiness standards, a defined design review and safety analysis process, a new part development planning process. Additionally, companies looking to manufacture PMAS should carefully review existing provider inputs, such as service bulletins and airworthiness directives affecting the part to be manufactured. A review board should also be set up to evaluate design changes with substantiating data.
- On the manufacturing side, companies should enact a program to verify the conformity of produced parts, evaluate and select suppliers based on well-established criteria, and develop a system to ensure that manufacturing processes and services are carried out by competent personnel in accordance with approved specifications.
- Another preventative element of the system involves a COS program manager and an organization to ensure that the COS program is effective and complies with all regulatory and guidance material. A separate board should be established to investigate, evaluate, and act on non-conforming material control and disposition processes in accordance with the FAA-approved quality system.
Part Monitoring
- Part monitoring occurs for all components that have entered service and is used to proactively detect safety issues with the part. This process involves a closed loop system to evaluate and respond to all inquiries or notifications of service problems, a part-specific system to track the performance data of a certain part, and recordkeeping of part delivery information to each buyer. Furthermore, each PMA holder must have a system to review all new and revised type certificate-holder maintenance instructions, applicable service bulletins, and airworthiness directives affecting the part. Data collected through part monitoring is used in coordination with preventative efforts to ensure that service information is used to proactively ensure safety for new parts.
Problem Response
- Problem response actions are designed to occur after a part issue is identified. The company should report failures, malfunctions, defects, and service difficulties with the FAA and make customers aware of any problem with the component. Following an identified problem, a response team should draw on member expertise to investigate the problem and the PMA holder should have the capability to provide a failure analysis of any problem.
- In-service problem identification also requires that the PMA manufacturer’s safety board develops and implements a field corrective action plan and conducts risk analysis of field reports that might indicate a reliability or safety issue with a part. The company should also be able to gauge the effectiveness of a corrective action plan that verifies proper communication among customers, suppliers, and the PMA holder. All information gathered from problem identification.
Why Implement COS?
While current FAA guidance only requires a COS program for the manufacture of certain parts and does not specify detailed elements of such a program, this initiative is likely to grow in the future. The FAA is currently considering implementing MARPA guidance into an updated order with more stringent COS program criteria. Additionally, as more organizations adopt this system, a COS program will increasingly become a mark of quality and safety in the parts manufacturing industry.
Many companies may already have elements of a COS system currently in place, thus displacing the cost of implementation. The MARPA COS Committee will soon be circulating a survey to all MARPA members to determine if they possess any elements of a COS program. Cooperation with this effort is highly appreciated, and will help strengthen MARPA and FAA efforts to ensure the highest level of safety in the PMA industry.
For more information on COS, please contact MARPA.
