Detecting & Reporting Suspected Unapproved Parts

NOTE: As the FAA are the leaders in SUP detection and reporting system, all the examples used refer to the FAA FARs.

They May Look the Same, BUT...

Counterfeit JT8D number 4-112" carbon seal spacers. The metal
rings were fabricated to be sold as Pratt & Whitney part number 525961
and are the subject of an FAA Airworthiness Directive 91-24-14

Unapproved parts may not be of the same high quality or be as fully compatible as those approved by the Federal Aviation Administration (FAA). Unfortunately, unapproved parts are not easy to detect because those who manufacture and distribute them go to great lengths to duplicate materials, part numbers, and serial numbers to coincide with the approved parts.

To make matters even more difficult, some of these parts may be available from the same suppliers that provided parts to the FAA Production Approval Holder (as defined in Federal Aviation Regulation (FAR) Part 21) under the original design. Therefore, without a detailed inspection or material analysis, unapproved parts can go undetected and enter into the aviation supply system. If you have any questions on a particular part, contact the production approval holders customer service department to verify part number, serial number, and/or date of manufacture.

Definition: Unapproved Part definition: A part, component, or material that has not been manufactured in accordance with the approval procedures in FAR § 21.305 or repaired in accordance with FAR Part 43; that may not conform to an approved type design; or may not conform to established industry or U.S. specifications (standard parts). Such unapproved parts may not be installed on a type certificated product, unless a determination of airworthiness can otherwise be made.

Examples of unapproved parts include, but are not limited to "counterfeit" or fraudulently marked parts, components, or materials:

Parts shipped directly to users by a manufacturer, supplier, or distributor who does not hold, or operate under the authority of a production approval for the part e.g., parts that a manufacturer produces in addition to those authorized by the production approval holder; and Parts that have been maintained or repaired and returned to service by persons or facilities not authorized under FAR Parts 43 or 145.

Who is Responsible for Airworthiness?
The performance rules for replacement of parts and materials used in the maintenance and alteration of U.S. certificated aircraft are specified in FAR §§ 43.13 and 145.57.

Continued airworthiness of the aircraft, which includes the replacement of parts, is the responsibility of the owner/operator per the requirements of FAR §§ 91.403, 121.363, 125.243, 127.13 1, and 135.413.

To ensure continued safety in civil aviation, it is essential that great care be used when inspecting, testing, and determining the acceptability of all parts and materials. Particular caution should be exercised when the identity of parts, materials, and appliances cannot be established or when their origin is in doubt.

How Unapproved Parts Get Into the System
Most aircraft parts distributors, aircraft supply companies, aircraft electronic parts distributors, etc., are not subject to certification or surveillance by the FAA. They are not required or responsible for establishing the airworthiness of parts they advertise and/or sell.

In some cases subcontractors have overproduced a production approval holder's part and later offer the surplus parts to a distributor, repair station, or airline as a replacement part. These parts are usually cheaper and delivered faster than if purchased from the authorized manufacturer. As a result, these parts bypass the certificated production approval holder's quality control system and become "unapproved parts."

Used life limited parts may be offered for sale with falsified records. This makes it difficult to determine or verify the actual time remaining limits for safe operation. These parts usually come from a cannibalized or damaged aircraft.

Life limited parts that have exceeded their time limit or have non repairable defects, are sold to part dealers where they are reworked or camouflaged to give the appearance of being serviceable. A salvaged part may be accompanied with counterfeit operating history or records that falsely account for its life limits.

New components or parts may be manufactured for the production approval holder but fail to meet the approved design, yet they may still enter into the spare part distribution system.

Inadequate mutilation of unsalvageable, life limited parts by aircraft repair stations and owners or operators, allowing some of these parts to be cosmetically doctored for resale. Inadequate methods of mutilation may include marking, spray painting, hammering or identification tagging.

Failure to remove and report data plates from aircraft/components when declared unsalvageable may allow their reuse. These data plates should be removed and the information reported to the FAA.

An FAA-approved part or standard part (manufactured to an industry or U.S. specification) illegally modified by an aircraft replacement parts distributor/broker would also be considered an unapproved part.

Guide to Detection of Unapproved Parts
Procedures should be established prior to purchasing parts to establish qualified suppliers who are authorized to manufacture or distribute FAA approved parts. The following criteria would help to identify and screen out potential unapproved parts suppliers:

1. The quoted price or the price advertised in trade magazines is significantly lower than the price quoted by other suppliers of the same part.
2. A delivery schedule that is significantly shorter than that of the same part when existing stocks are depleted.
3. The inability of a supplier to provide substantiating data demonstrating the conformity of the part.
4. The inability of a supplier to provide evidence of FAA approval for the part.

Regulation and Guidance
An approved aeronautical part conforms to a FAA-type design and is in condition for safe operation:

1. FAR Part 21, Certification Procedures for Products and Parts, Specifically:
FAR § 21.125, Approved Production Inspection System (APIS).
FAR § 21.143, Production Certificate (PC).
FAR § 21.303, Parts Manufacturing Approval (PMA), Standard Parts.
FAR § 21.305, Approval of Materials, Parts, Processes, and Appliances.
FAR § 21.500, (Import) Approval of Engines, Propellers.
FAR § 21.502, Materials, Parts, and Appliances.
FAR § 21.605, Technical Standard Order Authorization (TSOA).

2. Authority and responsibility to repair and install approved parts:
FAR Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration.
FAR Part 121, Certification and Operations: Domestic, Flag, and Supplemental Air Carriers and Commercial Operators of Large Aircraft.
FAR Part 127, Certification and Operations of Scheduled Air Carriers with Helicopters.
FAR Part 135, Air Taxi Operators and Commercial Operators.
FAR Part 145, Repair Stations.

Aeronautical replacement parts not produced, repaired, or installed in accordance with the above requirements are questionable because the parts' approved design and quality are unknown.

Guidance includes:

Advisory Circular 21-29, Detecting and Reporting Suspected Unapproved Parts.
Advisory Circular 20-62, Eligibility, Quality, and Identification of Approved Aeronautical Replacement Parts.

Buyers are Advised to

• Inspect product containers for damage, another supplier's name, or no markings.
• Cross check purchase orders with the delivery receipts for proper part number or component history card.
• Develop a means of ensuring the shelf or service life has not expired.
• Verify that part identification requirements have not been tampered with (e.g., serial numbers stamped over, label is improper or missing, vibro-etch or serial numbers at other than normal location).
• Inspect parts for visual defects or abnormalities (e.g., altered or unusual surface, absence of required plating, evidence of prior usage, scratches, new paint over old, attempted exterior repair, pitting or corrosion).
• Perform supplier audits, to ensure suppliers establish and maintain the quality requirements specified in the purchase order. The following are examples of subsystems that should be included in an audit program:

• Design data control to include latest revision.
• Supplier control.
• Material handling/control.
• Evidence of a production approval.
• Manufacturing/assembly control.
• Tool and gauge control.
• Tests and inspections.
• Records.

Failure to remove and report data plates from aircraft/components when declared unsalvageable may allow their reuse. These data plates should be removed and the information reported to the FAA.

An FAA-approved part or standard part (manufactured to an industry or U.S. specification) illegally modified by an aircraft replacement parts distributor/broker would also be considered an unapproved part.

South African Aviation Industry.

The referenced documents in the following text are in draft form, will shortly be available on the CAA website, or by sending an email to sdr@caa.co.za

1 REPORTING GUIDELINES

1.1 General

1.1.1 To assist in reporting SUPs, the CAA has produced a SUP Report Form (CAA Form CA 43-06). This form provides a standardised format which facilitates the submission of complete data and reduces the time and cost associated with processing the reports. The details on the form may be entered by either machine/computer printing or by hand using block capitals.

1.1.2 An electronic version of the CAA Form CA 43-XX is available for download via the Internet from the CAA web site (http://www.caa.co.za). A completed form can be submitted electronically via the Internet to CAA.

1.1.3 When reporting a SUP, as much descriptive information should be provided as possible on the part. Any supporting information, such as photographs and sketches of the suspected part, is also appreciated. However, SUPs should not be physically submitted to the CAA unless specifically requested by the CAA.

1.1.4 The use of abbreviations should be kept to a minimum, unless the particular term is universally used and no confusion could be caused as a result.

1.1.5 The completed form with necessary attachments can be forwarded to :

Carel Raath, Manager Defect Reporting

Fax: 011 545 1462 or 086 602 4471

sdr@caa.co.za

The names of individuals or companies reporting such SUPs will not be divulged to any other party

2 Notification of SUPs to industry

2.1 The CAA will disseminate safety information resulting from its investigation of SUP reports.

2.2 Based on the information discovered by the SUP investigation and any other relevant information, the CAA will determine whether the unsafe condition warrants the issuance of an Airworthiness Directive (AD) pursuant to Part 21.

2.3 If the investigation reveals that an unapproved part may exist but an AD is not warranted, the CAA will advise the affected individuals or organisations by direct mail, or issue a Maintenance Advisory Notice (MAN) as appropriate. The Maintenance Advisory Notices are available on the CAA web site (http://www.caa.co.za).

2.4 For any additional information or any help, please contact Carel Raath.

3 Use of parts removed from another aircraft

3.1 A person must not replace an aircraft component in an aircraft with a part that has been removed or salvaged from another aircraft (irrespective of whether or not that aircraft is still in service) where that component has not had maintenance carried out on it, unless that person can be reasonably satisfied that the replacement part is serviceable (having regard to the records of its performance in the aircraft from which it was removed), and the part performs satisfactorily when installed in the aircraft.

4 Disposal of scrapped parts

4.1 Parts determined to be unapproved or to have reached or otherwise exceeded their intended design lives are no longer permitted to be used for aviation purposes. Such parts are to be quarantined and rendered physically unserviceable where possible and disposed of in an appropriate manner unless otherwise advised by the CAA.

5 SUPs found in South Arica

5.1 In the South African Aviation community several Boeing 737 brake units were found that can be classified as SUP, then after investigation they were found to be Unapproved parts. On some of these units, the serial numbers were altered, and on others, the serial numbers were mutilated, and restamped on areas where they do not normally appear.

5.2 Number ground off, and new number stamped.

5.3 Number mutilated and restamped in a different location.