AML STC expansion
Conformity records review for an AML STC model-list expansion
This work reviews the conformity records behind an approved model list expansion, confirming that the articles tested and the installations inspected were the configuration the evidence claims. It serves avionics and equipment suppliers extending an STC to new models, before submission. The review checks article identity, configuration, and test eligibility so a test result rests on a conforming article rather than an uncontrolled one. You receive a gap assessment, a conformity-to-configuration reconciliation, and a closure plan for the articles that cannot be tied down.
When this review is needed
- Test evidence supports the expansion and each result has to rest on an article whose conformity is documented.
- Testing was performed at more than one facility and article identity has to be consistent across the records.
- An installation was inspected for the added models and its conformity has to tie to the controlled configuration.
- A reviewer will trace a test result back to the article it ran on and the supplier wants that trace intact first.
The problem
A test result is only worth the conformity of the article it ran on. On an expansion, test evidence is drawn from campaigns spread across time and facilities, and the record that proves a given article was the intended configuration can be thin or missing. An article tested to an engineering build rather than a released configuration, or an installation whose conformity was never documented, leaves a result that reads as valid while its foundation is uncontrolled.
What gets reviewed
- Article identity for each test confirmed and tied to the result it supports
- The configuration of each test article reconciled to a controlled release
- Eligibility to test confirmed so each article was conforming when the test ran
- Installations inspected for the added models tied to the controlled configuration
- Results whose supporting article cannot be tied to a controlled configuration identified
- Untied articles assembled into a closure plan for the STC holder
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Identify what is missing against the means of compliance.
What gets validated
- Each test result identifies the article it ran on by part and serial number
- The configuration of every test article traces to a controlled release
- Test eligibility is documented so the article conformed at the time of test
- Inspected installations for the added models tie to the controlled configuration
- No test result rests on an article whose conformity cannot be reconstructed
Evidence normally required
- The conformity records and inspection reports for the test articles
- Test reports identifying the articles and installations tested
- The configuration index and release records for the tested versions
- Article part and serial identification across the test campaigns
- The installation descriptions for the added aircraft models
Common discrepancies
- A test article built to an engineering configuration rather than a released one
- A result whose article identity is missing or inconsistent across facilities
- An inspected installation with no documented tie to the controlled configuration
- Conformity that cannot be reconstructed because the article was modified after test
What is at stake
A test result standing on a non-conforming or undocumented article is a result a reviewer can set aside, and setting one aside can pull down every requirement that result was meant to close. Reconstructing conformity after the fact is often impossible once the article has been modified, returned, or scrapped, so the evidence has to be re-earned by re-test. That is late cost the expansion cannot easily absorb.
How the work runs
Identify the articles
Tie each test result to the specific article it ran on by part and serial number.
Reconcile to a release
Confirm each article's configuration traces to a controlled release and was eligible at test.
Check installation conformity
Confirm inspected installations for the added models tie to the controlled configuration.
Plan the untied articles
Sequence results whose conformity cannot be reconstructed into a closure plan before submission.
What the buyer receives
- A gap assessment of results whose article conformity is missing or weak
- A conformity-to-configuration reconciliation across the test evidence
- A closure plan for the articles that need re-test or documented conformity
Who uses the output
- STC holders confirming test results rest on conforming, documented articles
- Certification leadership deciding where a result must be re-earned by re-test
- Program managers scoping conformity gaps against the schedule
How the work fits into the transaction or program
Conformity records sit under the test evidence the verification trace relies on. Where the verification review confirms a result closes a requirement, this review confirms the result itself rests on a conforming article, so the two run together. A conformity gap found here is also a hole in the verification the expansion depends on.
Start with a single asset
Reduce finding cycles by checking the package first.
Jurisdiction-specific considerations
FAA and EASA both require test evidence to rest on a conforming article, but the form of conformity documentation and the role of the authority's own witnessing can differ. The review notes where the conformity record is thin so a result holds for either authority reviewing the expansion.
Regulatory limits
This work reconciles conformity records to the controlled configuration. It does not perform conformity inspections, issue a conformity determination, or make a compliance finding on the test evidence.
What this review does not cover
- Performing the conformity inspection of any article or installation
- Issuing a statement of conformity for a test article
- Any finding of compliance on the test evidence
Specific to this review
- A test result inherits the conformity of its article: prove the article was uncontrolled and the result is set aside with it.
- Conformity is the hardest evidence to reconstruct after the fact, because a modified, returned, or scrapped article cannot be re-inspected in the state it was tested.
- Article identity fragments across multi-facility campaigns, so consistent part and serial tracking is where conformity most often breaks on an expansion.
Sources
U.S. Government (eCFR). Type certificates, STCs (Subpart E), TSO authorizations (Subpart O), PMA (Subpart K), and export airworthiness approvals (Subpart L).
Federal Aviation Administration. STC application process, certification basis, and continued airworthiness obligations of an STC holder.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Federal Aviation Administration. FAA type certification process, certification basis establishment, and compliance findings.
Frequently asked questions
What if we cannot reconstruct conformity for a test article after the fact?
If the article was modified, returned, or scrapped, its conformity at the time of test often cannot be re-established, and the result it supports has to be re-earned by re-test on a conforming article. The review identifies these results early so the re-test is planned into the schedule rather than discovered as a finding.
Relevant glossary terms
Related pages
Where this fits
Talk to an engineer who has done this work
We will walk through your current state, the records or evidence involved, and a scoped first engagement.
Talk through the aircraft, records, evidence, deadline, and next useful step.