AVIATION SAFETY NEWSLETTER
Thought for the month.....For every action there is an equal and opposite government program.
Approved Parts....One of the continuing programs in the FAA which has been growing for the past decade, involves approved parts. Ask just about any FAA airworthiness inspector a question on approved parts and probably the first reaction you will get is the rolling of his or her eyeballs into the back of their head. Talk to anybody who has been either flying or fixing airplanes for at least 20 plus years about aircraft parts and they'll probably respond with something like "…I don't know what all the fuss is about. We never had a problem before". Well this may or may not be so. The truth of the matter is that before the FAA began to make an issue of approved parts there were still unapproved parts being put on airplanes.
To begin to understand the whole issue of unapproved parts you would first have to know what an approved part is. It is common to refer to unapproved parts as "bogus parts", and a bogus part in the minds of most people correlates to counterfeit parts. It is accurate to say that counterfeit parts are unapproved parts. It is also possible for a part that has been legally manufactured for civil aircraft to become an unapproved part.
The FAA has published FAA Order 8120.10A "SUSPECTED UNAPPROVED PARTS PROGRAM". Its purpose is to establish procedures for FAA Inspectors involved in coordination, investigation and processing suspected unapproved parts (SUP's). This order provides definitions of terms that are used for the bogus parts issue. According to the Order, an unapproved part could have been manufactured in accordance with a Parts Manufacturer Approval (PMA), A Technical Standard Order (TSO), or other legitimate production approval. What makes these parts become unapproved is when they no longer conform to their FAA approved design.
This happens when the part is no longer serviceable; it has been repaired by a person or repair station who is not authorized to perform the repair and returned to service by that person or repair station; or if the repair was performed improperly. Just to reiterate, a legitimate part can become an unapproved part even if it was manufactured legally but was not maintained in accordance with the manufacturer's instructions, or it was repaired by a person or repair station that is not authorized to perform the maintenance and has then approved it for return to service.
Ok, so your 35 year old airplane needs a part that the airplane manufacturer no longer makes. You find the part at an airplane salvage yard. Can you use it? After all it came off of the same type of airplane that you want to put it on. The first thing you should insist on is some sort of a document attesting to its origin. In this situation have the salvage yard state on the invoice where the part came from. And we're not looking for the name of the salvage yard, that information should already be printed on the invoice. What you need is traceability to the airplane that it was removed from. The salvage yard should identify the make, model, and the serial number of the aircraft that the part was removed from. If you are going to pay good money for the part, and I'm sure you will if it is the only source, you deserve good information. If your salvage yard owner balks at providing this information a warning flag should go up in your mind. Why won't he freely give you that information? More and more these days this sort of documentation is being asked for and the more reputable yards are catching on to the need to provide it.
After you obtain the part, take it to a qualified mechanic or repair station for an inspection to determine its serviceability. There should be some type of nondestructive type inspection performed on the part. It may be a simple visual inspection. It may require a more exacting inspection such as a liquid penetrant or magnetic penetrant type inspection. The mechanic or repair station who performs the inspection is then required to make a maintenance record of the inspection that will state the airworthiness of the part. Without this determine of airworthiness the part is in a state that we call a suspected unapproved part (SUP) and will remain in this state until it is properly determined to be either approved or unapproved.
Because aviation is as regulated as it is, we have an obligation to demand from our parts suppliers tracebility for all parts. It doesn't matter if they are new or used parts. There are suppliers who will grumble, refuse, or even laugh when you ask for the documentation. If this happens maybe you should quickly find another supplier. The question you have to ask yourself is whether or not the low price for the undocumented part is as big a bargain as it first appears to be. If the part should fail soon after it was installed the FAA may not be your biggest problem. If your insurance underwriter becomes aware of an unapproved part being installed on your airplane they could come to the conclusion that your airplane did not meet the terms and conditions of airworthiness as spelled out on the front of your Airworthiness Certificate. Check your policy to see if you are covered when your airplane is flown in an unairworthy condition. Most don't!
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