Repair Station Training - Blue Tuna

1 Repair Station Training Suspected Unapproved Parts Detecting and Reporting Unapproved Parts Information The Goal of SUP Training &. Suspected Unapproved Parts Training provides guidance to References Repair Station Supervisors, Inspectors and Technicians in the detection and reporting of suspected unapproved parts (SUP). Title 14 CFR This SUP Training embraces the vision of the SUP Task Force Part 1 which is .. Part 21. Part 43 To promote the highest level of aviation safety by eliminat- Part 45 ing the potential safety risk posed by the entry of unap- Part 91 proved parts in the aviation community. Part 121. Part 135 Suspected Unapproved Parts Program Plan Part 145 Executive Summary, p.

2 Vi. Advisory Circular AC 21-29-B. AC 20-62. General FAA Info Outline of SUP Training Suspected Unapproved Parts Program Plan (Report Introduction found on FAA Web Site). Understanding the Exceptions SUP Web Site I. De nitions De ning terms relevant to SUP. FAA SUP Address II. Detection SUP Program Of ce AVR-20. 45005 Aviation Drive Steps for Detecting Suspected Unapproved Parts Suite 214. Dulles, VA 20166 III. Reporting What To Do once SUP are detected. Created by Blue Tuna Training & Documentation Page 1. Repair Station Training Suspected Unapproved Parts Detecting and Reporting Unapproved Parts CFR How SUP Applies to the Title 14 CFR Part (b). Performance Rules Goal of Maintenance.

3 Understanding the regulations. (b) Each person maintain- ing or altering, or perform- While Part (b) does not address approved parts speci cally ing preventive maintenance, the issue of the quality of parts factors into the goal of mainte- shall do that work in such a nance which is to return the article to its original or properly manner and use materials of altered condition.. such a quality, that the condi- tion of the aircraft, airframe, aircraft engine, propeller, or Introduction Understanding the Exceptions appliance worked on will be As stated in the Suspected Unapproved Parts Program Plan at least equal to its original Terminology 3-2. or properly altered condition (with regard to aerodynamic The language of 14 CFR can be construed to give me- function, structural strength, chanics, Repair stations, and airlines some exibility in selecting resistance to vibration and or even fabricating parts if they can determine that the item being deterioration, and other quali- worked on will be at least equal to its original or properly altered ties affecting airworthiness).

4 Condition. Part 43 contains no explicit requirement that mechan- ics or Repair stations use only approved parts or parts produced in accordance with Part 21.. Title 14 CFR Part Replacement and modi ca- 14 CFR Part is the key regulation for understanding the ap- tion parts. proved parts issue. (a) Except as provided in The Exceptions are noted in Part (b) they are: paragraph (b) of this section, no person may produce a (1) Parts produced under a type or production certi cate. modi cation or replacement part for sale for installation (2) Parts produced by an owner or operator for maintaining or alter- on a type certi cated product ing his own product. unless it is produced pursu- ant to a Parts Manufacturer (3) Parts produced under an FAA Technical Standard Order.

5 Approval issued under this subpart. (4) Standard parts (such as bolts and nuts) conforming to estab- lished industry or speci cations. Created by Blue Tuna Training & Documentation Page 2. Repair Station Training Suspected Unapproved Parts Detecting and Reporting Unapproved Parts Terms I. De nitions De ning terms relevant to SUP. Approved Parts The need for de ning terms is discussed in Suspected Unap- proved Parts Program Plan Terminology . Counterfeit Parts Issue: The concept of approved parts versus unapproved Distributors parts is not well understood because there is no single, comprehensive de nition of an approved part or other key Parts Manufacturing Approval terms used in the discussion of SUP issues.

6 Production Approval Holder Recommendation: The FAA should adopt de nitions of the following main terms used with regard to parts eligible Production Certi cates for installation in type certi cated products to ensure that use of the terminology in government and the public is con- Standard Parts sistent and promotes a common understanding and use of the concepts: approved part; unapproved part; standard Supplemental Type Certi cates part; and counterfeit part. Such de nitions are intended for the purpose of this Proposed Program Plan as well as for Suspected Unapproved Part the purpose of future respective guidance documents and for colloquial use, as opposed to legal de nitions. Hence, Technical Standard Order Au- the Task Force does not recommend regulatory changes to thorization adopt the de nitions.

7 Type Certi cates Discussion: The regulations do not explicitly state in a single place when a part is acceptable, or eligible, for instal- Unapproved Part lation in terms of its manufacture, documentation, and main- tenance status; however, all of these factors , the part's For additional terms see origin (be it through an FAA-approval or other acceptable AC 21-29B manufacture), its current condition in terms of maintenance, and the documentation for its origin and maintenance are addressed separately in the regulations and are related to a part's acceptability, or eligibility, for installation. The following De nitions are derived from the AC, and the Suspected Unapproved Parts Program Plan.

8 Created by Blue Tuna Training & Documentation Page 3. Repair Station Training Suspected Unapproved Parts Detecting and Reporting Unapproved Parts Approved Parts Approved Parts- are identi ed as parts which have met one of the following requirements: 1. Produced in accordance with a Parts Manufacturer Approval (PMA). 2. Produced in accordance with a Technical Standard Order Authorization (TSOA). 3. Produced during the Type Certi cate (TC) or the Supplemental Type Certi cate (STC). 4. Produced under a (TC) without a separate production authorization and an Ap proved Production Inspection System (APIS). 5. Produced under a Production Certi cate (PC). 6. Produced in accordance with an approval under a bilateral airworthiness agree ment.

9 (Manufactured in other countries recognized and approved by the FAA). 7. Approved in any other manner acceptable to the Administrator. 8. Produced as standard parts that conform to established industry or cations. ( MS, AN, SAE). 9. Produced by an owner or operator for the purpose of maintaining or altering their own product. 10. Manufactured by a Repair Station or other authorized person during alteration in accordance with an (STC) or Field Approval (which is not for sale as a sepa- rate part- only Repair ). 11. Fabricated by a quali ed person in the course of a Repair for the purpose of returning a (TC) product to service (which is not for sale as a separate part- only Repair ). Note: In summary, Approved Parts are those which are produced in accordance with the means outlined in FAA part 21, maintained in accordance with FAA parts 43 and 91, and meet applicable design standards.

10 Created by Blue Tuna Training & Documentation Page 4. Repair Station Training Suspected Unapproved Parts Detecting and Reporting Unapproved Parts Counterfeit Parts A part made or altered so as to imitate or resemble an Approved Part without author- ity or right and with the intent to mislead or defraud by passing the imitation as original or genuine. Distributors Brokers, dealers, re sellers, or other persons or agencies engaged in the sale of parts for installation in TC aircraft, aircraft engines, propellers, and in appliances. Parts Manufacturing Approval (PMA) [issued to rst tier suppliers]. FAA approval for design, manufacturing and installation of modi cation and replacement parts for sale and for installation on type certi cated products.