Suspected unapproved parts update
By Fred Workley
Suspected unapproved parts (SUPS) continue to be of concern to all those who install parts on aircraft. The Federal Aviation Administration (FAA) has just released the advanced copy of the new Advisory Circular on Detecting and Reporting Suspected Unapproved Parts. AC No. 21-29B will replace AC21-29A, dated July 16, 1992. Suspected Unapproved Parts (SUP) is a part, component, or material that is suspected of not meeting the requirements of an "approved part." Counterfeit parts are clearly unapproved parts according to the AC.
The part, according to the AC, may not be "approved" for many reasons, some of which include findings such as a different finish, color, size, incomplete or altered paperwork, and missing or improper identification per FAR Part 45. The AC points out that an "approved Part" which is used in an incorrect application should be addressed as a potential Part 43 violation. It is not considered a reportable SUP. Other Unapproved Parts, according the revised AC, are parts which have been improperly returned to service. In other words, parts maintained contrary to FAR Part 43 or Part 145.
Parts are considered SUPs if they have been maintained, rebuilt, altered, overhauled, or approved for return to service by persons or facilities not authorized to perform these services under Part 43 and /or Part 145. Parts which have been inspected and/or tested by persons not authorized to determine conformity to FAA-approved design data may be SUPs. Subsequently, these parts may also be found to be acceptable for installation with the performance of some maintenance which might be an inspection.
Also considered SUPs are parts which are shipped directly to the user by a manufacturer, supplier, or distributor, where the parts were not produced under the authority of the FAA, or in accordance with an FAA production approval (PC, APIS, PMA, or TSO) for that specific part. Parts are SUPs if they are shipped to an end user by a Production Approval Holder Ôs (PAH) supplier who does not have direct ship authority from the PAH.
Production runs that do not pass through an approved quality system are SUPs. Also considered SUPs are new parts which have passed through a PAHs quality system and are not found to conform to the approved design/data. On the other hand, parts damaged due to warranty or shipping are not considered SUPs. This damage may make these parts unserviceable, but they are not SUPs.
The AC also categorizes as SUPs parts that have been maintained, rebuilt, overhauled, altered, or approved for return to service and then found not to confirm to approved data. This would include parts produced by an owner/operator for the purpose of maintaining or altering their own product, or that have been approved for return to service and later found not to conform to approved data.
It is important for you to understand that the definition of SUPs does not include parts currently in the inspection or repair process. Thus, parts removed for maintenance are not SUPs, whether or not they have removal-record traceability. Parts in this status may be considered not acceptable for installation because they are worn out, broken, past their life limit, exceed their shelf life, or require inspection an/or repair. In other works, these parts are not presently serviceable, but not necessarily unapproved. Once maintenance has been accomplished, in accordance with Part 43 and proper maintenance records prepared, these parts may be installed on a Type Certificated aircraft by an installer.
Study the new Advisory Circular, AC 21-29B when it is available to you. It contains definitions for approved and suspected unapproved parts. There is an interesting section on the background of the SUPs issue. The AC also gives guidelines for detection of SUPs in the procurement and acceptance procedures. Reporting procedures and the instructions for FAA Form 8120-11, the SUPs Notification form, are also in this Advisory Circular.
We will take a look at what can be done to identify suspected unapproved parts as well as steps you can take to keep unapproved parts from entering the parts inventory.
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