Manufacturing Regulators& Distributors
Recently, a question was posed to the Airline Suppliers Association (ASA) from a distributor that works closely with several United States manufacturing companies. A manufacturer had obtained PMA on an aviation part. This same company also made similar parts for use with ground support equipment. The distributor's query concerned the separation between the aviation and non-aviation quality systems, and the extent to which this production quality system had to be extended through the quality procedures of the distributor.
Separating Aviation and Non-Aviation Fabrication
It seems that one of the manufacturers with whom the distributor worked was wondering whether the aviation regulations required it to do anything special because it made non-aviation parts in the same facility as the one in which aviation parts were made.
Every FAA production approval requires a quality system that imposes certain minimal controls on the production process. Such controls include recordkeeping requirements. For this reason, there will be specific requirements for any manufacturer's production quality system associated with the aviation parts manufactured under a FAA Parts Manufacturer Approval (PMA).
A PMA manufacturer is required to show that each article manufactured under the production approval conforms to an FAA approved design (the design component of the PMA). Obviously, the manufacturer will need to have some way to separate PMA parts from those that do not meet the design requirements of the PMA; but this should not necessarily imply that non-aviation parts do not meet the same engineering requirements as the PMA parts.
When a manufacturer produces both aviation and non-aviation parts, this does not always require separate production lines. It is possible for the manufacturer to produce non-PMA parts to the same design parameters as those produced under a PMA. From an engineering standpoint, the only difference between the PMA parts and the non-PMA parts would be the markings on the parts - the production line may be split at the part-marking phase, with lots being chosen for PMA marking or other marking, depending on their intended final market. This is a common practice in some facilities that manufacture both civil aviation and military aviation parts.
There may be business reasons for a manufacturer to plan a system that separates parts created under a PMA from those created outside the scope of the PMA. The real decision should take into account liability concerns, manufacturing efficiency, quality concerns, and customer needs.
In at least one case reported to ASA, an FAA representative told the manufacturing company that it was required to keep records of where all of the parts it manufactured were sent to support the claim that certain parts were manufactured without the intent that they be installed on aircraft (and were therefore exempt from the FAA-PMA rules). This "requirement" is not supported by the regulations, even though it may have represented sound business advice for that particular company. Like all "sound business advice" received from a United States Government representative, it is optional. The FAA does not have the power to require a company to keep records concerning non-aviation parts, and no regulation requires a PMA holder to maintain destination records on PMA parts - instead, the regulations require the PMA holder to maintain inspection records on completed PMA parts, which must be kept for two years.
One reason that a distinction might be made between PMA and non-PMA parts is because the FAA aftermarket part rules only apply to parts manufactured with the intent that they be installed on aircraft (or on their component parts). In an enforcement action, the FAA would try to prove that certain parts were manufactured outside the scope of the PMA, but were still produced with the intent that they be sold for installation on an aircraft. Proving this is the FAA's burden in an enforcement action. If the manufacturer keeps part-by-part records detailing the intended installation of the part (aviation vs. non-aviation), then this could help the FAA prove its case if the manufacturer violated the PMA parts rules. This is one important reason that the FAA would want a company to maintain such records - it permits the FAA to hang the company with its own paperwork. On the other hand, these sorts of records can help the manufacturer defend itself in an enforcement action if the PMA rules have not been violated. However, the state of the PMA rules and guidance today make it difficult to be certain that one is not violating the manner in which an individual FAA inspector will interpret the regulation.
Effect on Distributors
The reason this became important to an ASA member is that the distributor was asked to do two things based on the FAA manufacturing inspector's requirement.
First, the FAA inspector required that the manufacturer's distributors disclose to their customers, to double-check that the manufacturer's end-user expectations were being met. Just as there is no FAA regulation to require a manufacturer to keep records of end-users of parts, there is also no FAA regulation that requires a distributor to keep and disclose a list of its customers. If a distributor chooses to share this information with a manufacturer, then this should be a business decision based upon the needs of the manufacturer and distributor. This information would be a commercial document that should not ordinarily be available to the FAA inspector.
The second requirement communicated to the distributor was quite disturbing. This came from a different FAA inspector, through a different manufacturer in a similar situation. The manufacturer had obtained PMA on most of its parts but not on everything it manufactured. An FAA inspector apparently told the manufacturer that if it supplied parts without FAA production approval to an aviation parts distributor, then it must obtain a statement from the distributor that "the parts are being purchased for installation on an aircraft and is [sic] approved by the aircraft manufacturer."
There are serious problems with this situation. First, the manufacturer appears to be producing parts for sale for installation on an aircraft without benefit of a PMA or other exception to the PMA rules. This appears to represent a likely violation of the PMA rule, unless the manufacturer can demonstrate that it did not intend the parts to be sold for aviation use at the time they were manufactured. Even though the FAA bears the burden to demonstrate intent, a wise manufacturer should be prepared to prove its own intent in its own defense.
Second, the distributor is being asked to produce a document that could be used in an enforcement action against the manufacturer, and that appears to have no other possible purpose. Distributors should be very cautious if asked to disclose, in writing, that the parts it is buying are intended for aviation use when the distributor knows that the parts are not manufactured under a PMA or one of the exceptions to the PMA rules. In some cases, the manufacturer may be violating the regulations, and the document is intended to be used by the FAA in an enforcement action. Even when no laws are broken, this sort of transaction may be labeled as a Suspected Unapproved Part (SUP) transaction, and rumors of a SUP investigation can harm a company's business.
The third problem with the statement requested is that it asks the distributor to attest to an approval by the production certificate (PC) holder (like Boeing or Pratt & Whitney). In most cases, this is not possible because the PC holder has not "approved" the part. In fact, except when it is manufactured under a direct ship authority, there is generally no mechanism for a PC holder to approve manufacturing by a third-party manufacturer. Only the FAA has the power to grant production approval to a United States manufacturer. In the cases where the parts manufacturer has been granted direct ship authority by the PC holder, the manufacturers should possess the necessary paperwork to document the transaction, and the distributor should ask the manufacturer for copies of the direct ship documentation.
Some distributors may feel that a part is approved by the PC holder if it is listed in the illustrated parts catalog (IPC). Do not fall into this trap. Do not use the IPC listing as the basis for a statement that a part is approved by the PC holder. Listing a part number in an IPC does not mean that the manufacturer of the part has production approval, and it does not mean that the manufacturer of the part has direct ship authority. It only means that the PC holder buys the part, inspects it within the context of its own quality system, and installs it when it meets the inspection requirements. Except in the most unusual cases, a distributor should not attest to the proposition that a PC holder has granted any form of approval to another company's parts unless those parts have been run through the PC holder's own quality system (in which case they may be approved parts by virtue of the PC holder's own production approval).
Aviation parts distributors sometimes purchase parts that are manufactured outside of the scope of the PMA rules. One reason they do this is upon the request of an air carrier or other customer. The customer's engineering department may have made a determination that the part is acceptable for installation.
AMT's Annual Aviation Distributor Listing
Adams Aviation Supply Co. Ltd., Hunter House, Biggin Hill Airport, Kent, TN16 8BN, England, (44) 1959 576129; Distributor of maintenance items: avionics, instruments, and pilot supplies to customers worldwide.
Aero Quality Sales, 47 Harbor View Ave., Stamford, CT 06902, (800) 288-1954; Distributor of nickel-cadmium and lead acid batteries, battery servicing, and GSE. As an authorized, stocking distributor for Marathon, SAFT, Gill, Concorde, Christie, Tronair, and Aero Design PMA packs; we carry a multi-million dollar inventory that enables us to same day shipping of stock items.
AeroSafe Products Inc., PO Box 4755, Marietta, GA 30061, (888) 666-7885; Manufacturer and distributor of cleaning agents and equipment as well as Giliberti electric ground support equipment. Visit our web site at www.aerosafe.com.
Aerospace Products International (API), 3778 Distriplex Dr. North, Memphis, TN 38118, (901) 365-3470; A distributor of over 150 lines of aerospace products selling to the general aviation, regional and commercial airline, and military markets. In addition to its Memphis site, API also operates full-service locations in Calgary and Montreal. Visit our web site at www.apiparts.com.
Airparts Co. Inc., 2310 NW 55th Ct., Bay 128, Ft. Lauderdale, FL 33309, (954) 739-3575; and 1991 Airport Rd., Wichita, KS 67208, (316) 943- 2377; Distributor of aircraft parts, accessories, equipment and tools including airframe and engine items, GSE, and shop tools.
Airparts Depot, The, PO Box 460492, San Antonio, TX 78246, (210) 494-1520; An online distribution service created to provide aircraft operators with one single aircraft parts and supplies source. From brand name consumables, avionics, and compontents to pilot supplies; customers can find it all on www.airpartsdepot.com.
Allied International Corp., 7 Hill St., Bedford Hills, NY 10507, (914) 241-6900; Distributor for a variety of products from Parker Hannifin - Stratoflex Div., Federal Mogul Champion, Southwest Products Co., Electro Adapter Companies, and Eurofarad.
Ascent Aviation Products, One Mill St., Parish, NY 13131, (800) 272-3681; Supplies a variety of aviation petroleum, chemical, and service products, as well as Surface Seal® Coated Glass for aircraft windshields. Customer support representatives are available 24 hours for emergency services.
AV-OX Inc., 6734 Valjean Ave., Van Nuys, CA 91406, (818) 787-3852 and 1812 Production Ct., Louisville, KY 40299, (502) 499-5432; Sales, service, and product support for aviation oxygen equipment. Scott Aviation authorized distributor.
Aviall Inc., 2075 Diplomat Dr., Dallas, TX 75234, (972) 406-6693; The world's largest independent distributor of new aviation parts, representing some 180 quality manufacturers and distribute parts to more than 13,000 general aviation operators and 300 airlines worldwide. From an ISO 9002-registered central distribution facility in Dallas, to stocking locations worldwide, Aviall is focused on providing the best service in the industry. www.aviall.com
Aviation Fabricators 805 N. 4th St., Clinton, MO 64735, (660) 885-7531; Offers STC products include divans and cabin utility enhancement products. CRS capabilities encompass seats, recline acuators, ovens, and many other components. Visit us at www.aviationfabricators.com.
AVGROUP Inc., 3580 Pierce Dr.,Atlanta, GAÊ30341, (800) 458-6177; A stocking distributor of avionics, instruments, and rotablesÊfor corporate and regional turbine-powered aircraft. Avgroup specializes in support the Citation, King Air, and Cheyenne airframes, but also offers full lines of Garrett pressurization equipment, Starter/Generators, and Wheels and Brakes for all airframes up to Hawker and Gulfstream.
AVMATS, 750 N. Beechcraft Ave., Chesterfield, MO 63005, (636) 532-2674; Parts sales, component OHC, and aircraft sales.
AVPAC, 3410 W. Mathis St., Lincoln, NE 68524, (800) 228-1836; AVPAC, the Aviation Parts and Components Network, is Duncan Aviation's sourcing solution for aircraft parts, rotables, components and avionics. AVPAC has an inventory of more than 250,000 line item parts for corporate and general aviation aircraft. Visit our web site at www.avpac.com.
Cessna Citation Parts Distribution, Five Cessna Blvd., Wichita, KS 67215; (316) 517-7541 or (800) 835-4000; World's largest holder and supplier of Citation jet parts and ground support equipment. Offering competitively priced new, exchange, and rental parts. Same day shipping at no extra charge.
Corporate Rotable & Supply, 6701 NW 12th Ave., Ft. Lauderdale, FL 33309, (954) 972-2807 or (800) 338-5387; Since 1982, CRS has been supporting Gulfstream, Learjet, Falcon, Challenger, Hawker and Sikorsky S-76 operators. CRS maintains one of the largest most comprehensive privately owned inventories available to support corporate flight departments worldwide. Visit our web site at www.corporaterotable.com.
Davis Instrument Mfg. Co. Inc., 4701 Mt. Hope Dr., Baltimore, MD 21215, (410) 358-3900; Distributor of test, measurement, and control equipment with a new emphasis on calibration services. Desser Tire and Rubber Co. Inc., 6900 Acco St., Montebello, CA. 90640, (800) 247-8473;
Desser Tire is the largest independent aircraft tire distributor in the United States. We sell over 120,000 tires and tubes each year from Goodyear, Michelin and McCreary aircraft tires. Visit our web site at www.desser.com.
Eastern Aero Supply Inc., 1001 N. 10th St., Millville, NJ 08332, (800) 257-8148; Distributors of most major aviation product lines. FAA approved Aeroquip hose assembly shop on premises.
Executive Beechcraft, 10 Richards Rd., Kansas City, MO 64116, (800) 821-7992; Offers TCAS II for Beechcraft King Air 200 owners. The Collins system is widely used in the commercial airline segment worldwide, and is now becoming familiar territory for business operators also. Visit our web site at www.executivebeechcraft.com.
Falcon Crest Aviation Supply Inc., 8318 Braniff, Houston, TX 77061, (713) 644-2290; Distributors of major aviation manufacturers, Class I, II, III, unlimited repair station, TSO'd Aeroquip hose shop, on-the-shelf accessory exchange program.
Flame Enterprises, 20945 Osborne St., Canoga Park, CA 91304, (800) 854-2255 and 295 Mary Frances Ct., Frederick, MD 21703, (888) 352-6332; Distributor for relays, circuit breakers, switches, and more. Product lines include: Leach Int'l, T.I. Klixon, CII Tech., CII-Hartman, Korry Electronics, Teledyne, OTTO Controls, Eaton, Deutsch, and more.
Gradient Lens Corp., 207 Tremont St., Rochester, NY 14608, (800) 536-0790; Offers the line of rigid and flexible Hawkeye® borescopes. Visit our web site at www.gradientlens.com.
HS Electronics Inc., 1665 W. 33rd Pl., Hialeah, FL 33012, (305) 821-5802; Wholesale distributor of connectors, relays, switches, circuit breakers, TYRADS, terminals, contacts, wire and cable insertion-extraction tools. Visit us at www.HSElectronics.com.
Herber Aircraft Service Inc., 1401 E. Franklin Ave., El Segundo, CA 90245, (800) 544-0050; An authorized distributor for Aeroquip Aerospace and Industrial products including Marman and Rynglok products. Distributors for Lord, Thermoid, and Flexfab, as well as Herber E.G.T. Harnesses. 24/7 AOG service available on hose kits and assemblies. Visit our web site at www.herberaircraft.com.
Instrument Associates Inc., 60 S. Bayles Ave., Pt. Washington, NY 11050, (516) 944-8800; Since 1947, our equipment, instruments and parts for all types of general aviation, commercial and military aircraft have been distributed worldwide. We stock over 100,000 line items, specializing in Ametek (U.S. Gauge and G.E.). Other lines offered are Bendix, Kollsman, Weston, Honeywell (Sperry), and more. Visit us at www.instrumentassoc.com.
Inventory Locator Service (ILS), 3965 Mendenhall, Memphis, TN 38115, (901) 794-5000; ILS brings buyers and sellers of aviation parts together - worldwide. Suppliers list inventory on the ILS mainframe computer for easy access by buyers and ILS gives buyers the information to contact the sellers directly.
Kell-Strom Tool Co. Inc., 214 Church St., Wethersfield, CT 06109, (800) 851-6851; Distributor of hand tools and equipment. Products offered include: Apex bits, Cooper hand tools, Weller, Branson Ultasonic cleaners, New York Twist Drill, Pelican Lights and Cases and much more. Please see our web site at www.kell-strom.com.
Leavens Aviation Inc., 2555 Derry Rd. E., Mississauga, ON, Canada, L4T 1A1, (905) 678-1234 or (800) 263-6142; Transport Canada Approved Distributor of aircraft parts and supplies. Visit us at our web site www.leavensaviation.com.
Mart Corp., The, 2450 Adie Rd., Maryland Heights, MO 63043, (314) 567-7222; Distributor for Mart Power Washers for cleaning piston and jet engine components including turbine blades.
Memphis Group, The, 3900 Willow Lake Blvd., Memphis, TN 38118, (901) 362-8600; Worldwide distributors of airborne navigation, communications, HF communications, inertial navigation systems, and avionics test equipment. Suppliers of engines, engine spares, QECs, rotables and expendables. Visit www.memphisgrp.com.
Omaha Airplane Supply, 1101 Avenue H, Ste. G, Carter Lake, IA 51510, (712) 347-6666; and 2945 Redondo Ave., Long Beach, CA 90806, (562) 595-4301; Distributors of all major product lines for general aviation, corporate aircraft, regional and major airlines. Two complete stocking warehouses to serve the aviation industry. The Omaha location has an FAA approved Aeroquip hose shop. PartsBase.com, 7171 N. Federal Hwy., Boca Raton, FL 33487, (561) 443-3320; An online marketplace for the aviation, aerospace and defense industries offering a database of over 40 million line-items and services. Parts listing, searching, procurement, RFQs, auctions, can be managed from a user-friendly, cost-effective interface that never closes. Visit us at our web site www.partsbase.com.
Penn Yan Aeroparts, 2499 Bath Road Airport, Penn Yan, NY 14527, (800) 727-7230 and 615C Herndon Ave., Orlando, FL 32803, (800) 899-2957; Wholesale distributor for GA parts, engines, and consumables. Product lines include: Champion, Goodyear, Lycoming, Continental, Precision, GE, Gill, Concorde, LAMAR, RAYJAY and more. World's largest RAPCO distributor. Visit www.pennyanaeroparts.com.
Pratt & Whitney Canada Corp., 1000 Marie Victoria Blvd., Longueuil, Quebec, Canada, J4G 1A1 (450) 468-7730; Provides total after sales support for all Pratt & Whitney Canada Corp. engines worldwide. Parts distribution, accessory repair-overhaul-exchanges, rental-exchange engines, and component repairs-exchanges.
Precision Heliparts Inc., 495 Lake Mirror Rd., #800G, Atlanta, GA 30349, (800) 537-4140; Sales of instruments, electronics, and electrical accessories for helicopters.
Professional Aviation Associates, 4694 Aviation Pkwy, Ste. K, Atlanta, GA 30349, (800) 283-2105 or (404) 767-0282; Distributes spare parts for Beech King Air, Beechcraft 1900, and Learjet