The FAA, Industry and Airplane Parts

An airplane is a highly complex machine depending on thousands or even millions of parts to fly safely. As part of its regulatory responsibility, the Federal Aviation Administration (FAA) works closely with industry to make sure that unapproved parts don’t threaten today’s all-time-high aviation safety record.

Many of the methods for designing and producing major aircraft products, such as airframes, engines and propellers, need specific FAA approval. The FAA grants approvals only after a stringent review of design criteria, facilities, processes and quality control systems. The agency continually monitors firms that have these production approvals to ensure they comply with regulations and the terms of their approvals.

Some approved parts don’t need specific FAA sanction. For example, the owner or operator of an aircraft can produce parts to maintain or alter their own product. Manufacturers often OK the use of “standard parts,” such as nuts and bolts, that meet specified industry-accepted criteria. Maintenance personnel also can make parts in the course of their aircraft repair work as long as such parts meet applicable design criteria. All these parts must comply with regulations and meet industry standards.

What’s a “SUP?”

Occasionally, parts that may not meet applicable requirements enter the aviation system. They can range from parts that lack proper documentation to parts that are actually counterfeit. Until the FAA determines whether items actually meet requirements, the agency calls them suspected unapproved parts, or “SUPs.”

SUPs can be parts rejected during production because of defects; parts for which required documentation is missing; parts that have been improperly maintained; and parts from military aircraft that have not been shown to comply with FAA requirements. Suspect unapproved parts may also include items from a supplier who produces parts for an approved manufacturer and then ships them directly to end users without the approved manufacturer’s authorization; there is no guarantee that they meet all quality control requirements.

Counterfeit parts may be new parts that are deliberately misrepresented as designed and produced under an approved system or other acceptable method. Counterfeit parts also may be used approved parts that have reached a design life limit or have been damaged beyond possible repair, but are altered and deliberately misrepresented as acceptable.

None of these types of parts should be installed on an aircraft.

Investigating SUP

To help guard against use of unapproved parts, the FAA created a special SUPs program in 1995. A special SUPs office, located in the Washington, DC area, coordinates the FAA’s efforts to identify, investigate and ultimately remove any such parts from spares stocks, or occasionally, from aircraft themselves.

SUPs are detected and reported in various ways. Anyone in the aviation community may directly notify the FAA using a special form or call in a complaint to the Aviation Safety Hotline (1-800-255-1111). FAA employees may discover SUPs during accident or incident investigations or routine surveillance activities.

The FAA categorizes suspect unapproved parts according to their potential effect on the safe operation of an aircraft. Category 1 parts are the most safety-critical; they could cause the crew to use emergency procedures if they fail during flight. Category 2 and 3 parts have less impact on aircraft safety, but the agency still checks them out thoroughly.

The SUP Detectives

The most important goals of a SUPs investigation are to trace suspect parts to their source, determine whether they pose a threat to aviation safety, and if so, take corrective action and remove them from the system. FAA investigators gather photographic evidence, copies of records and witness statements. Parts given to the inspector during the course of an investigation are officially cataloged. Investigators write detailed narratives to document the scope of the investigation and their findings. If criminal activity is suspected, the FAA coordinates its investigation with appropriate law enforcement authorities.

If the investigation determines a part is truly unapproved, several things happen. The unapproved parts must be accounted for or the potential end users must be notified. If end users cannot be notified directly, then the FAA sends out an Unapproved Parts Notification (UPN) alerting the aviation community to the problem. UPNs advise that the parts be deactivated or removed, depending on the type of aircraft.

UPNs reach a wide audience with Internet postings, e-mail and regular mail. Nearly 5,200 FAA employees and other federal workers receive UPNs via a mass e-mail. Another 56,000 have requested to receive them automatically from an FAA safety site. And approximately 5,000 repair stations and foreign civil aviation authorities receive UPNs by regular mail. Several associations also publish newly released UPNs in their newsletters, and when warranted, UPNs appear in FAA Advisory Circular 43-16.

Unapproved parts located in inventories should be immediately removed or segregated to prevent inadvertent installation. Air carriers and other operators should have procedures in place to segregate these parts so they won’t be installed on aircraft.

If the FAA determines that a manufacturer, air carrier or other user violated Federal Aviation Regulations regarding approved parts, they could be subject to anything from a warning letter to a stiff fine. In the case of criminal activity, the appropriate law enforcement authority and judicial system can pursue the case.

FMI: www.faa.gov/aircraft/safety/programs/sups/