Suspected ‘Unapproved Parts’ Program Plan

1 Department of Transportation federal aviation AdministrationSuspected unapproved Parts Program PlanPrepared byThe FAA Suspected unapproved Parts TaskForceOctober 6, 1995 Table of ContentsiiTable of ContentsSection PageList of Overview of the SUPs Overview of the Proposed Program Task Force Task Force Task Force Scope of the Task Force s Task Force Organization of This SUPs Program Technical Support Organizational Data and Analysis Organizational Policy, Guidance, and Training Organizational National SUPs Program Office Regional/Directorate SUPs Coordinators and Local Regulatory Reporting Technical Responsibility for Parts Limitations on Parts Fabrication for Parts Distributors and SUPs Investigations and of Instructions for Continued of ContentsiiiTable of Contents, ContinuedSection Use of Joint aviation Authorities (JAA)

2 Form 1 and FAA Form Required part Surplus Military SUPs Case Salvageable and Scrap Removal of unapproved Parts From the Information Systems Relationships With Law Enforcement Transition Implementing the Principal A FAA SUPs Task Force MembersAPPENDIX B Selected Recent Initiatives Suspected unapproved Parts APPENDIX C Related ACs, Orders, and MemorandaAPPENDIX D SUPs Investigation ProceduresAPPENDIX E Parts Reporting System DatabaseAPPENDIX F Parts Receiving PolicyAPPENDIX G List of RecommendationsAPPENDIX H Task Force Charter Items Program plan Cross-Reference GuideList of AcronymsivList of AcronymsACAdvisory CircularACSC ivil aviation SecurityACOA ircraft Certification OfficeADAirworthiness DirectiveAFSF light Standards ServiceAGCO ffice of the Chief CounselAIRA ircraft Certification ServiceAIR-DUAerospace Industry Regulation of DistributorsARACA viation Rulemaking Advisory

3 CommitteeASIA viation Safety InspectorATAAir Transport Association of AmericaAVRR egulation and Certification OrganizationBBSB ulletin Board SystemCFRCode of federal RegulationsCOCC ertificate of ConformanceDBAD atabase AdministratorDCISD efense Criminal Investigative ServiceDoDDepartment of DefenseDOT/OIGD epartment of Transportation Office of the Inspector GeneralDRMO Defense Reutilization and Marketing OfficeEISE nforcement Information SystemFAAF ederal aviation AdministrationFARF ederal aviation RegulationsFBIF ederal Bureau of InvestigationList of AcronymsvList of Acronyms.

4 ContinuedFSCAP Flight Safety Critical Aircraft PartFOIAF reedom of Information ActFSDO Flight Standards District OfficeGAOG eneral Accounting OfficeIFCAI nstructions for Continued AirworthinessIPCI llustrated Parts CatalogIFOI nternational Field OfficeIVTI nteractive video teleconferencingJAAJ oint aviation AuthoritiesJARJ oint aviation RequirementsMIDOM anufacturing Inspection District OfficeMISM anagement Information SystemNPRMN otice of Proposed RulemakingPAATP arts Approval Action TeamPAHP roduction Approval HoldersPATP rocess Action TeamPMAP arts Manufacturer ApprovalPRSP arts Reporting SystemPTRSP rogram Tracking and Reporting SystemSFARS pecial federal aviation RegulationSTCS upplemental Type CertificateSUPS uspected unapproved part TCType CertificateTSOT echnical Standard Customs ServiceExecutive SummaryviExecutive SummaryThe federal aviation administration (FAA) convened a Task Force to conducta thorough review of the Suspected unapproved Parts (SUPs) issue and todevise a comprehensive Program plan to more aggressively address SUPs.

5 Thepurpose of the review was to build on past initiatives and to take the nextlogical step to making the SUPs Program more Task Force s review also took into account the concerns that had beenexpressed both within Congress and the Department of Transportation s Officeof the Inspector General regarding FAA SUPs policy and enforcement beinginconsistent and understanding of the complicated nature of the issues and the potentialsafety impact of SUPs led the FAA Regulation and Certification Organizationto set forth a vision for both the Task Force and the SUPs Program .

6 The visionis:To promote the highest level of aviation safety byeliminating the potential safety risk posed by the entry of unapproved parts in the aviation community. The Task Force was instructed to develop a comprehensive plan to achieve thisvision through a Program that could be implemented easily and would includean organizational structure capable of providing clear and consistent guidance,enhanced training, more timely SUPs case processing, access to usablemanagement information system data, and one that would also promoteworking closely with other law enforcement agencies in eliminating Force members were drawn from the FAA s Aircraft CertificationService, Flight Standards Service.

7 The Office of Civil aviation SecurityOperations, and the Office of the Chief Counsel. Task Force members wereSubject Matter Experts in the fields of maintenance, engineering,manufacturing inspection, law enforcement, or administrative law alldisciplines crucial to understanding the SUPs issue. Additionally, many TaskForce members represented a field perspective as opposed to a headquartersview since such members would have had the most recent experience withSUPs case Task Force s methodology included reviewing SUPs initiatives taken overthe past 5 years, including educational seminars, guidance material, and thecurrent prototype database being used to track SUPs cases.

8 In particular, theTask Force focused on existing policy guidance and advisory material, and alsoon obtaining a clear understanding of existing pitfalls in the current SUPsExecutive Summaryviiprogram. Task Force members applied their collective knowledge andunderstanding to identify areas for Program improvement and enhancement. As a result, the Task Force proposed a series of recommendations to beimplemented in four stages: immediate action, transition, operational phase,and sunset, in order to start immediately impacting the problems that werediagnosed without losing sight of longer-range Task Force recommends the following.

9 Clarify the FAA s Policy on SUPs Standardize the Use of SUPs Terminology Establish an FAA National SUPs Program Office Establish a New Parts Reporting Information System Improve Cooperation With Law Enforcement Agencies Target Receiving Inspection Procedures for Surveillance andEnforcement Clarify the Responsibility of Persons Performing Maintenance Expedite Rulemaking Improve SUPs Investigation Training for the FAA Workforce Define Procedures to Dispose of Scrap Parts Define Procedures to Remove unapproved Parts fromInventories and items are elaborated upon in Section , Overview of the ProposedProgram plan .

10 Introduction1 IntroductionThe federal aviation Regulations include a framework of rules governingthe design, manufacture, and use of aviation products and parts. Theseregulations, along with federal aviation administration (FAA) surveillance,inspection, and enforcement activities, are a key element in maintaining thehistorically high level of safety in air transportation. As part of its activities, the FAA periodically reviews and updates theregulations, and issues policy guidance to its inspectors and advisoryinformation to the industry to achieve compliance with the regulations.