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“APPROVED PARTS”. PRESENTED BY DON E. GARDNER AVIATION SAFETY INSPECTOR CHARLOTTE FSDO #33 (704) 319-7020. IA 2004. “APPROVED PARTS”. OUR GOAL. TO ELIMINATE THE POTENTIAL SAFETY RISK POSED BY “UNAPPROVED” PARTS,…. and to accomplish that. WE MUST KEEP “UNAPPROVED PARTS”

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Approved parts

“APPROVED PARTS”

  • PRESENTED

  • BY

  • DON E. GARDNER

  • AVIATION SAFETY INSPECTOR

  • CHARLOTTE FSDO #33

  • (704) 319-7020


Ia 2004

IA 2004


Approved parts

“APPROVED PARTS”


Our goal

OUR GOAL...

  • TO ELIMINATE THE POTENTIAL SAFETY RISK POSED BY “UNAPPROVED” PARTS,….


Approved parts

and

to accomplish

that...


Approved parts

  • WE MUST KEEP “UNAPPROVED PARTS”

  • OUT OF THE AVIATION SYSTEM.


Today s topics

TODAY’S TOPICS

  • HISTORY

  • DEFINITIONS

  • ACTIONS

  • INDICATORS OF FRAUD

  • DEMONSTRATION


Brief history

AUGUST 1995 SUP TASK FORCE CONVENED.

AFS, AIR, LEA, AGC AND OTHERS.

CONDUCTED A THOROUGH REVIEW OF THE SUP ISSUE.

BRIEF HISTORY


History continued

BUILD ON PAST INITIATIVES

MAKE THE SUP PROGRAM MORE EFFECTIVE

CONCERNS OF CONGRESS AND THE DOT/OIG

HISTORY…continued


History continued1

HISTORY…continued

  • TASK FORCE WAS A CROSS SECTION OF FIELD AND HEADQUARTERS PERSONNEL.


Approved parts

  • What is an

  • “APPROVED PART” ?


Approved parts

FAA ORDER 8120.10A DEFINES AN “APPROVED PART“AS...

  • PRODUCED IAW REQUIREMENTS or EXCEPTIONS OF FAR Part 21,

  • MAINTAINED IAW FAR Part 43 & 91,

    and

  • MEETS APPLICABLE DESIGN STANDARDS.


An easier way of remembering

IS A PART THAT IS ELIGIBLE FOR INSTALLATION ON A TC’d PRODUCTIF:

IT HAS AN APPROVED DESIGN

IT IS PROPERLY PRODUCED

IT IS PROPERLY MAINTAINED

IT IS PROPERLY DOCUMENTED

An Easier Way of Remembering ...


Approved design means

All pertinent information defined

Drawings and specifications show the configuration of the part.

Airworthiness limitations defined.

APPROVED DESIGN MEANS


Approved 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.

APPROVED DESIGN ...Continued


Properly produced means

PROPERLY PRODUCED MEANS...

  • PRODUCED “I/A/W”

  • THE REQUIREMENTS OR EXCEPTIONS OF FAR Part 21.

FAR

21

Part


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)

THERE ARE ELEVEN WAYS TO PRODUCE A PART “IAW THE REQUIREMENTS OR EXCEPTIONS OF FAR PART 21”


Properly produced continued

4)BILATERAL (Subpart N)

5)OWNER / OPERATOR (Subpart K)

6)TCWITHOUT SEPARATE PRODUCTION AUTHORIZATION (Subpart F)

“PROPERLY PRODUCED” …continued


Properly produced continued1

7)PC INCLUDING A LICENSEE, PC

8)STANDARD PARTS (Subpart K).

9)REPAIR STATIONUNDER STC OR FIELD APPROVAL(FAA ORDER 8000.50, FAR 43)

“PROPERLY PRODUCED” …continued


Properly produced continued2

10)A REPAIRNOT FOR SALE AS A SEPARATE PART (Subpart K)

11)ANY OTHER MANNERAPPROVED BY THE ADMINISTRATOR (Subpart K).

“PROPERLY PRODUCED” …continued


Properly maintained means

PROPERLY MAINTAINED MEANS...

  • IN ACCORDANCE WITH FAR PART 43 AND 91


Far 43 13 a

FAR 43.13(a)

SHALL USE THE METHODS TECHNIQUES AND PRACTICES PRESCRIBED IN THECURRENT MANUFACTURER’S MAINTENANCE MANUAL OR INSTRUCTIONS FOR CONTINUED AIRWORTHINESS

OR OTHER METHODS TECHNIQUES AND PRACTICES ACCEPTABLE TO THE ADMINISTRATOR


Far 43 13 a1

FAR 43.13(a)

CURRENT MANUFACTURER’S MAINTENANCE MANUAL OR INSTRUCTIONS FOR CONTINUED AIRWORTHINESS


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.


Far 43 13 b says1

FAR 43.13(b) says...

AT LEAST EQUAL TO ITS ORIGINAL OR PROPERLY ALTERED CONDITION


Approved parts

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...


Approved parts

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.


How does an installer know they are using approved parts

BY USING ONLY

“APPROVED” PARTS

FROM AN APPROVED SYSTEM!!

OR

HOW DOES AN INSTALLER KNOW THEY ARE USING “APPROVED PARTS”?


Approved parts

DETERMINE THAT PARTS CONFORMTO TYPE DESIGN BY USING TECHNICAL DATA, BLUE PRINTS OR OTHER SPECIFICATIONS.


Approved parts

  • DID YOU KNOW ?


It may be possible but

IT MAY BE POSSIBLE,... BUT

  • 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.


Ok what is an unapproved part

IF A PART IS NOT AN“APPROVED PART”

THEN IT IS AN“UNAPPROVED PART”

OK, WHAT IS AN “UNAPPROVED PART?”


And if you don t know

…AND IF YOU DON’T KNOW,

  • THEN IT IS A

  • SUSPECTED “UNAPPROVED PART”


Approved parts

SUP

IF A DETERMINATION CANNOT BE MADE, QUARANTINED THE PART, BECAUSE IT MIGHT REQUIRE REPORTING AS A SUP


Approved parts

SUPs REPORTING

FAA Suspected Unapproved Parts (AVR-20)13873 Park Center Road, Suite 165Herndon, VA 20171Phone: 703-668-3720Fax: 703-481-3002www.faa.gov/avr/sups/


Guidance for reporting sups

Guidance forReporting SUPs

  • FAA ORDER 8120-10ASuspected Unapproved Parts Program

  • AC 21-29B Detecting and Reporting Suspected Unapproved Parts.


Who investigates when sups are reported

WHO INVESTIGATES WHENSUPS ARE REPORTED?

  • FOR NEW PARTS (MIDO)

  • FOR REPAIRED PARTS (FSDO)

  • FOR INSTALLED PARTS (FSDO and/or MIDO )


Faa actions continued

FAA Actions…continued

  • GATHER ALL AVAILABLE SUPPORTING EVIDENCE


Faa actions continued1

FAA Actions…continued

  • ASK THAT SUSPECTED “UNAPPROVED PARTS”

  • BE QUARANTINED AND

  • HELD FOR FURTHER INVESTIGATION


Your actions

YOURACTIONS...

  • HAVE ADEQUATE INCOMING INSPECTIONS PROCEDURES TO DETECT “UNAPPROVED PARTS”.


Your actions continued

Your Actions…continued

  • CONDUCT INTERNAL AUDITS AND SURVEIL FOR UNAPPROVED PARTS DURING ALL FACILITY AND STOCK ROOM INSPECTIONS.


Your actions continued1

Your Actions…continued

  • ALWAYS REQUIRE CERTIFICATION THAT PARTS SUPPLIED ARE “APPROVED PARTS”


Your actions continued2

USE APPROPRIATE TECH DATA TO COMPLY WITH 43.13(a).

IF NEEDED, REQUEST FAA or DER ENGINEERING SUPPORT TO DOCUMENT COMPLIANCE.

Your Actions…continued


Your actions continued3

Your Actions…continued

  • IF REQUIRED, DEMONSTRATE COMPLIANCE WITH 43.13 (b) BY SHOWING THAT A PART IS EQUAL TO ITS ORIGINAL OR PROPERLY ALTEREDCONDITION .


Your actions continued4

Your Actions…continued

FORM

FIT

AND

FUNCTION


Your actions continued5

DISPOSE OF UNSALVAGEABLE AIRCRAFT PARTS AND MATERIALS IAW AC # 21-38

Your Actions…continued


Your actions continued6

Your Actions…continued

  • LEARN TO RECOGNIZE INDICATORS OF FRAUD


Fraud in the

FRAUD IN THE...

  • PARTS

  • DOCUMENTATION

  • FACILITIES

  • PERSONNEL

  • SUPPLIERS

  • BROKERS


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


Title 18 of the usc

TITLE 18 of the USC

  • FRAUDULENT DESIGN

  • FRAUDULENT MANUFACTURING

  • FRAUDULENT MAINTENANCE

  • SALE OF PARTS FRAUDULENTLY

    • DESIGNED

    • MANUFACTURED

    • MAINTAINED


Counterfeit parts

“COUNTERFEIT PARTS”

  • COUNTERFEIT PARTS ARE ALWAYS “UNAPPROVED”.

  • COUNTERFEIT PARTS ARE ALWAYS REPORTABLE.

  • COUNTERFEIT PARTS ARE

  • ALWAYS ILLEGAL , THEREFORE, CRIMINAL...


Announcing grand opening of

ANNOUNCINGGRAND OPENING OF...

“PISTON POPPERS” INC.

SALES / SERVICE

of

PISTONS


Approved parts

“APPROVED

PART”


Approved parts

“UNAPPROVED

PART”


Approved parts

ASHTRAY


Approved parts

SUSPECTED

“UNAPPROVED

PART”


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”


Fly safe

“FLY SAFE”


Questions

??? QUESTIONS ???

  • FAR’s PARTS


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