Identifying unapproved parts
We need to be diligent in identifying unapproved parts. The FAA offers the following situations that could raise a red flag on a part being unapproved:
- The quoted price or the price advertised in trade magazines is significantly lower than the price quoted by other suppliers of the same part.
- A delivery schedule that is significantly shorter than that of the same part when existing stocks are depleted.
- The inability of a supplier to provide substantiating data demonstrating the conformity of the part.
- The inability of a supplier to provide evidence of FAA approval for the part.
Rodger Holmstrom, a retired FAA Safety Program safety manager, offers a tip on avoiding unapproved parts. “You have heard that old saying ‘If it sounds too good to be true, it probably is.’ Well, this is definitely true in the aviation industry. Be very wary of parts that are priced way lower than the industry average.”
Here are some more tips from the FAA that parts purchasers can use to help in identifying unapproved parts:
- 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 the part identification requirements have not been tampered with (e.g., serial numbers stamped over, label is improper or missing, viboretch 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.
Unapproved parts list
One key way to prevent unapproved parts from being installed on an aircraft is to keep up on unapproved parts notifications from the FAA. You can go to www.faa.gov/avr/sups/index.cfm to view the current list. The site also has other resources including a Frequently Asked Questions section that gives tips on identifying suspected unapproved parts.
Current PMA list
Another thing to keep in mind is that unapproved parts are sometimes misrepresented as PMA parts. If you are not sure, it is best to check for yourself. For a current list of FAA PMAs, you can log onto http://www.faa.gov/aircraft/air_cert/design_approvals/pma/
Keeping unapproved parts from entering the system
Our responsibility does not end with trying to identify unapproved parts. We must do our part to ensure that we do not allow unapproved parts to enter the aviation system. The main way we can do this is to ensure proper disposition of life-limited or unairworthy parts. If items are to be salvaged, be sure to destroy or mutilate them to make them unusable. If the owner asks for the parts back, he or she should be educated on proper mutilation procedures. But be careful with liability. Do not destroy or mutilate a part that does not belong to your company (a customer’s part) without his or her direct permission. Doing so can put you in a legal bind.
Also, be sure to remove data plates from unsalvageable parts and report them to the FAA.
These have been a few tips to help identify unapproved parts and keep them from entering the supply chain. To report suspected unapproved parts, you can fill out FAA Form 8120-11, Suspected Unapproved Parts Notification (obtained from your FSDO or in AC 21-29) and mail to:
SUP Program Office, AVR-20
13873 Park Center Road
Herndon, VA 20171
Tel: (703) 668-3720
Fax: (703) 481-3002
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