“APPROVED PARTS”
PRESENTED
BY
DON E. GARDNER
AVIATION SAFETY INSPECTOR
CHARLOTTE FSDO #33
(704) 319-7020
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IA 2004
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“APPROVED PARTS”
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OUR GOAL...
TO ELIMINATE THE
POTENTIAL SAFETY RISK
POSED BY “UNAPPROVED”
PARTS,….
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and
to accomplish
that...
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WE MUST KEEP
“UNAPPROVED PARTS”
OUT OF THE AVIATION
SYSTEM.
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TODAY’S TOPICS
• HISTORY
• DEFINITIONS
• ACTIONS
• INDICATORS OF FRAUD
• DEMONSTRATION
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BRIEF HISTORY
• AUGUST 1995 SUP TASK FORCE
CONVENED.
• AFS, AIR, LEA, AGC AND
OTHERS.
• CONDUCTED A THOROUGH
REVIEW OF THE SUP ISSUE.
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HISTORY…continued
• BUILD ON PAST INITIATIVES
• MAKE THE SUP PROGRAM
MORE EFFECTIVE
• CONCERNS OF CONGRESS AND
THE DOT/OIG
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HISTORY…continued
TASK FORCE WAS
A CROSS SECTION
OF FIELD AND
HEADQUARTERS
PERSONNEL.
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What is an
“APPROVED PART” ?
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FAA ORDER 8120.10A DEFINES
AN “APPROVED PART“AS...
•
PRODUCED IAW REQUIREMENTS
or EXCEPTIONS OF FAR Part 21,
•
MAINTAINED IAW FAR Part 43 & 91,
and
•
MEETS APPLICABLE DESIGN
STANDARDS.
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An Easier Way of Remembering ...
IS A PART THAT IS ELIGIBLE
FOR INSTALLATION ON A TC’d
PRODUCT
•
•
•
•
IF:
IT HAS AN APPROVED DESIGN
IT IS PROPERLY PRODUCED
IT IS PROPERLY MAINTAINED
IT IS PROPERLY DOCUMENTED
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APPROVED DESIGN MEANS
• All pertinent information defined
• Drawings and specifications show
the configuration of the part.
• Airworthiness limitations defined.
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APPROVED DESIGN ...Continued
• Test procedures and desired results
detailed and written.
• Actual design approval document,
e.g., STC, TC, Letter of Approval.
• Some may have “FAA Approved”
written or stamped.
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PROPERLY PRODUCED MEANS...
PRODUCED
“I/A/W”
THE
REQUIREMENTS
OR EXCEPTIONS
OF FAR Part 21.
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THERE ARE ELEVEN WAYS TO PRODUCE A PART
“IAW THE REQUIREMENTS OR EXCEPTIONS OF
FAR PART 21”
1) PMA (Subpart K)
2)
TSO (Subpart 0)
3)
TC
(Subpart B) OR
STC (Subpart E)
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“PROPERLY PRODUCED” …continued
4)
BILATERAL (Subpart N)
5) OWNER
(Subpart K)
/ OPERATOR
6) TC WITHOUT SEPARATE
PRODUCTION
AUTHORIZATION (Subpart F)
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“PROPERLY PRODUCED” …continued
7) PC INCLUDING A LICENSEE,
8) STANDARD
PC
PARTS
(Subpart K).
9) REPAIR
UNDER
STC
STATION
OR FIELD APPROVAL
(FAA ORDER 8000.50, FAR
43)
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“PROPERLY PRODUCED” …continued
10) A
REPAIR
NOT FOR SALE
AS A SEPARATE PART (Subpart K)
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ANY OTHER MANNER
APPROVED BY THE
ADMINISTRATOR (Subpart K).
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PROPERLY MAINTAINED MEANS...
IN ACCORDANCE WITH
FAR PART 43 AND 91
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FAR 43.13(a)
SHALL USE THE METHODS TECHNIQUES
AND PRACTICES PRESCRIBED IN THE
CURRENT MANUFACTURER’S
MAINTENANCE MANUAL OR
INSTRUCTIONS FOR CONTINUED
AIRWORTHINESS
OR OTHER METHODS TECHNIQUES AND
PRACTICES ACCEPTABLE TO THE
ADMINISTRATOR
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FAR 43.13(a)
CURRENT
MANUFACTURER’S
MAINTENANCE MANUAL OR
INSTRUCTIONS FOR
CONTINUED
AIRWORTHINESS
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FAR 43.13 (b) says...
EACH PERSON MAINTAINING OR ALTERING, OR
PERFORMING PREVENTIVE MAINTENANCE, SHALL
DO THAT WORK IN SUCH A MANNER AND USE
MATERIALS OF SUCH QUALITY, THAT THE
CONDITION OF THE AIRCRAFT, AIRFRAME,
AIRCRAFT ENGINE, PROPELLER, OR APPLIANCE
WORKED ON WILL BE AT LEAST EQUAL TO ITS
ORIGINAL OR PROPERLY ALTERED CONDITION.
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FAR 43.13(b) says...
AT LEAST EQUAL TO ITS
ORIGINAL OR PROPERLY
ALTERED CONDITION
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FAR 91 SAYS...
• 91.7 (a) NO PERSON MAY OPERATE A
CIVIL AIRCRAFT UNLESS IT IS IN A AIRWORTHY
CONDITION
• 91.403 (b) NO PERSON MAY PERFORM
MAINTENANCE …AS PERSCRIBED IN THIS
SUBPART …INCLUDING FAR PART 43 ...
• 91.403 (c) NO PERSON MAY OPERATE
AN AIRCRAFT FOR WHICH A MANUFACTURER
MAINTENANCE MANUAL OR INSTRUCTIONS...27
PROPERLY DOCUMENTED MEANS...
• NEW PARTS, DOCUMENTED
IAW FAR PART 21 AND 45,
including... DATA PLATES, ID
PLATES, PMA MARKINGS, ETC.......
• OVERHAULED OR
REPAIRED PARTS,
DOCUMENTED IAW FAR
PART 43.9.
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HOW DOES AN INSTALLER KNOW THEY
ARE USING “APPROVED PARTS”?
BY USING ONLY
“APPROVED” PARTS
FROM AN APPROVED SYSTEM!!
OR
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DETERMINE THAT
PARTS CONFORM TO
TYPE DESIGN BY
USING TECHNICAL
DATA, BLUE PRINTS OR
OTHER
SPECIFICATIONS.
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DID YOU KNOW ?
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IT MAY BE POSSIBLE,... BUT
• ITS POSSIBLE TO COMPLY WITH FAR 43.13 (b)
USING A PART THAT TECHNICALLY DOES
NOT MEET THE DEFINITION OF “APPROVED
PARTS”,
• HOWEVER, IT IS THE POSITION OF THE “SUPs
TASK FORCE” THAT USING SUCH PARTS
SHOULD NOT BE STANDARD PRACTICE
• BECAUSE INSTALLERS DO NOT NORMALLY
DETERMINE A PARTS CONFORMITY TO TYPE
DESIGN.
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OK, WHAT IS AN
“UNAPPROVED PART?”
IF A PART IS NOT AN
“APPROVED PART”
THEN IT IS AN
“UNAPPROVED
PART”
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…AND IF YOU DON’T KNOW,
THEN IT IS A
SUSPECTED
“UNAPPROVED PART”
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SUP
IF A DETERMINATION
CANNOT BE MADE,
QUARANTINED THE PART,
BECAUSE IT MIGHT REQUIRE
REPORTING AS A SUP
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SUPs REPORTING
FAA Suspected Unapproved Parts
(AVR-20)
13873 Park Center Road, Suite 165
Herndon, VA 20171
Phone: 703-668-3720
Fax: 703-481-3002
www.faa.gov/avr/sups/
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Guidance for
Reporting SUPs
• AC 21-29B Detecting and Reporting
Suspected Unapproved Parts.
• FAA ORDER 8120-10A
Suspected Unapproved
Parts Program
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WHO INVESTIGATES WHEN
SUPS ARE REPORTED?
• FOR NEW PARTS (MIDO)
• FOR REPAIRED PARTS (FSDO)
• FOR INSTALLED PARTS
(FSDO and/or MIDO )
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FAA Actions…continued
GATHER ALL
AVAILABLE
SUPPORTING
EVIDENCE
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FAA Actions…continued
ASK THAT
SUSPECTED
“UNAPPROVED
PARTS”
BE QUARANTINED
AND
HELD FOR
FURTHER
INVESTIGATION
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YOUR ACTIONS...
HAVE ADEQUATE
INCOMING
INSPECTIONS
PROCEDURES TO
DETECT “UNAPPROVED
PARTS”.
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Your Actions…continued
CONDUCT
INTERNAL AUDITS
AND SURVEIL FOR
UNAPPROVED PARTS
DURING ALL
FACILITY AND
STOCK ROOM
INSPECTIONS.
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Your Actions…continued
ALWAYS
REQUIRE
CERTIFICATION
THAT PARTS
SUPPLIED ARE
“APPROVED
PARTS”
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Your Actions…continued
• USE APPROPRIATE TECH DATA TO
COMPLY WITH 43.13(a).
• IF NEEDED, REQUEST FAA or DER
ENGINEERING SUPPORT TO DOCUMENT
COMPLIANCE.
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Your Actions…continued
IF REQUIRED,
DEMONSTRATE
COMPLIANCE WITH
43.13 (b) BY SHOWING
THAT A PART IS
EQUAL TO ITS
ORIGINAL OR
PROPERLY ALTERED
CONDITION .
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Your Actions…continued
FORM
FIT
AND
FUNCTION
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Your Actions…continued
DISPOSE OF
UNSALVAGEABLE
AIRCRAFT PARTS
AND MATERIALS
IAW AC
# 21-38
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Your Actions…continued
LEARN TO
RECOGNIZE
INDICATORS
OF FRAUD
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FRAUD IN THE...
•
PARTS
• DOCUMENTATION
• FACILITIES
• PERSONNEL
• SUPPLIERS
• BROKERS
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TITLE 49 of the USC
( THE FARs )
•
•
•
•
IMPROPER DESIGN
IMPROPER MANUFACTURING
IMPROPER MAINTENANCE
SALE OF PARTS IMPROPERLY
• DESIGNED
• MANUFACTURED
• MAINTAINED
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TITLE 18 of the USC
•
•
•
•
FRAUDULENT DESIGN
FRAUDULENT MANUFACTURING
FRAUDULENT MAINTENANCE
SALE OF PARTS FRAUDULENTLY
• DESIGNED
• MANUFACTURED
• MAINTAINED
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“COUNTERFEIT PARTS”
•
COUNTERFEIT PARTS ARE ALWAYS
“UNAPPROVED”.
•
COUNTERFEIT PARTS ARE ALWAYS
REPORTABLE.
•
COUNTERFEIT PARTS ARE
ALWAYS ILLEGAL , THEREFORE,
CRIMINAL...
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GRAND OPENING
OF...
“PISTON POPPERS”
INC.
SALES / SERVICE
of
PISTONS
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“APPROVED
PART”
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“UNAPPROVED
PART”
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ASHTRAY
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SUSPECTED
“UNAPPROVED
PART”
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IN CONCLUSION WE
M U S T !!!
PREVENT
“UNAPPROVED PARTS”
FROM ENTERING THE
AVIATION SYSTEM.
PREVENT
“UNAPPROVED PARTS”
FROM BEING INSTALLED.
PURGE
THE AVIATION SYSTEM OF
“UNAPPROVED PARTS”
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“FLY SAFE”
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??? QUESTIONS ???
FAR’s
PARTS
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