“APPROVED PARTS”

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“APPROVED PARTS”“APPROVED PARTS”

PRESENTED

BY

DON E. GARDNER

AVIATION SAFETY INSPECTOR

CHARLOTTE FSDO #33

(704) 319-7020

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IA 2004IA 2004

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““APPROVED PARTS”APPROVED PARTS”““APPROVED PARTS”APPROVED PARTS”

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OUR GOAL...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 TOPICSTODAY’S TOPICS

• HISTORY

• DEFINITIONS

• ACTIONS

• INDICATORS OF FRAUD

• DEMONSTRATION

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BRIEF HISTORYBRIEF 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…continuedHISTORY…continued

• BUILD ON PAST INITIATIVES

• MAKE THE SUP PROGRAM

MORE EFFECTIVE

• CONCERNS OF CONGRESS AND

THE DOT/OIG

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HISTORY…continuedHISTORY…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 FAA ORDER 8120.10A DEFINES AN “APPROVED DEFINES AN “APPROVED

PART“AS...PART“AS...

FAA ORDER 8120.10A FAA ORDER 8120.10A DEFINES AN “APPROVED DEFINES AN “APPROVED

PART“AS...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 ... 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 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 ...ContinuedAPPROVED 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... PROPERLY PRODUCED MEANS...

PRODUCED

“I/A/W” THE

REQUIREMENTS

OR EXCEPTIONS

OF FAR Part 21.

FAR21

Part

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THERE ARE ELEVEN WAYS TO PRODUCE A PART “IAW THE REQUIREMENTS OR EXCEPTIONS

OF FAR PART 21”

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“PROPERLY PRODUCED” …continued

4) BILATERAL (Subpart N)

5) OWNER / OPERATOR (Subpart K)

6) TC WITHOUT SEPARATE PRODUCTION

AUTHORIZATION (Subpart F)

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7) PC INCLUDING A LICENSEE, PC

8) STANDARD PARTS (Subpart K).

9) REPAIR STATION UNDER STC OR FIELD

APPROVAL (FAA ORDER 8000.50, FAR 43)

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10) A REPAIR NOT FOR SALE AS A SEPARATE PART (Subpart K)

11) ANY OTHER MANNER

APPROVED BY THE ADMINISTRATOR (Subpart K).

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PROPERLY MAINTAINED MEANS... PROPERLY MAINTAINED MEANS...

IN ACCORDANCE WITH

FAR PART 43 AND 91

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FAR 43.13(a) 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)FAR 43.13(a)

CURRENT MANUFACTURER’S

MAINTENANCE MANUAL OR INSTRUCTIONS FOR

CONTINUED AIRWORTHINESS

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FAR 43.13 (b) says...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...FAR 43.13(b) says...

AT LEAST EQUAL TO ITS ORIGINAL OR PROPERLY

ALTERED CONDITION

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FAR 91 SAYS...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...

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PROPERLY DOCUMENTED MEANS...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”?

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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• 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.

IT MAY BE POSSIBLE,... BUTIT MAY BE POSSIBLE,... BUT

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OK, WHAT IS AN “UNAPPROVED PART?”

OK, WHAT IS AN “UNAPPROVED PART?”

IF A PART IS NOT AN

“APPROVED PART”

IF A PART IS NOT AN

“APPROVED PART”

THEN IT IS AN

“UNAPPROVED

PART”

THEN IT IS AN

“UNAPPROVED

PART”

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…AND IF YOU DON’T KNOW,…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 SUPs REPORTINGREPORTING

SUPs SUPs REPORTINGREPORTING

FAA Suspected Unapproved Parts (AVR-20)13873 Park Center Road, Suite 165

Herndon, VA 20171Phone: 703-668-3720

Fax: 703-481-3002www.faa.gov/avr/sups/

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Guidance forReporting SUPsGuidance 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 WHENSUPS ARE REPORTED?

WHO INVESTIGATES WHENSUPS ARE REPORTED?

• FOR NEW PARTS (MIDO)

• FOR REPAIRED PARTS (FSDO)

• FOR INSTALLED PARTS

(FSDO and/or MIDO )

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FAA Actions…continuedFAA Actions…continued

GATHER ALL

AVAILABLE

SUPPORTING

EVIDENCE

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FAA Actions…continued FAA Actions…continued

ASK THAT

SUSPECTED “UNAPPROVED

PARTS” BE QUARANTINED

AND HELD FOR

FURTHER INVESTIGATION

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YOUR ACTIONS...YOUR ACTIONS...

HAVE ADEQUATE

INCOMING

INSPECTIONS

PROCEDURES TO

DETECT “UNAPPROVED

PARTS”.

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Your Actions…continuedYour Actions…continued

CONDUCT INTERNAL

AUDITS AND SURVEIL

FOR UNAPPROVED

PARTS DURING ALL

FACILITY AND STOCK

ROOM INSPECTIONS.

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ALWAYS REQUIRE

CERTIFICATION

THAT PARTS

SUPPLIED ARE

“APPROVED

PARTS”

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Your Actions…continued 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…continuedYour 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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FORM

FITAND

FUNCTION

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DISPOSE OF

UNSALVAGEABLE

AIRCRAFT PARTS

AND MATERIALS

IAW AC # 21-38

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LEARN TO

RECOGNIZE

INDICATORS

OF FRAUD

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FRAUD IN THE... FRAUD IN THE...

• PARTS

• DOCUMENTATION

• FACILITIES

• PERSONNEL

• SUPPLIERS

• BROKERS

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TITLE 49 of the USC ( THE FARs )

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 USCTITLE 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”

• COUNTERFEIT PARTS ARE ALWAYS

“UNAPPROVED”.

• COUNTERFEIT PARTS ARE ALWAYS

REPORTABLE.

• COUNTERFEIT PARTS ARE

ALWAYS ILLEGAL , THEREFORE,

CRIMINAL...

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ANNOUNCINGANNOUNCING

GRAND OPENING OF...GRAND OPENING OF...

““PISTON POPPERS” PISTON POPPERS” INC.INC.

SALES / SERVICESALES / SERVICEof of

PISTONSPISTONS

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“APPROVED

PART”“APPROVED

PART”

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“UNAPPROVED

PART”“UNAPPROVED

PART”

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ASHTRAYASHTRAY

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SUSPECTED

“UNAPPROVED

PART”

SUSPECTED

“UNAPPROVED

PART”

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IN CONCLUSION WE M U S T !!!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” “FLY SAFE”

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??? QUESTIONS ?????? QUESTIONS ???

FAR’s PARTS

“APPROVED PARTS”

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