1 “APPROVED PARTS” PRESENTED BY DON E. GARDNER AVIATION SAFETY INSPECTOR CHARLOTTE FSDO #33 (704)

2

3 IA 2004

4 “APPROVED PARTS”

5 OUR GOAL... TO ELIMINATE THE POTENTIAL SAFETY RISK POSED BY “UNAPPROVED” PARTS,….

6 and to accomplish that...

7 WE MUST KEEP “UNAPPROVED PARTS” OUT OF THE AVIATION SYSTEM.

8 TODAY’S TOPICS HISTORY DEFINITIONS ACTIONS INDICATORS OF FRAUD DEMONSTRATION

9 BRIEF HISTORY AUGUST 1995 SUP TASK FORCE CONVENED. AFS, AIR, LEA, AGC AND OTHERS. CONDUCTED A THOROUGH REVIEW OF THE SUP ISSUE.

10 HISTORY…continued BUILD ON PAST INITIATIVES MAKE THE SUP PROGRAM MORE EFFECTIVE CONCERNS OF CONGRESS AND THE DOT/OIG

11 HISTORY…continued TASK FORCE WAS A CROSS SECTION OF FIELD AND HEADQUARTERS PERSONNEL.

12 What is an “APPROVED PART” ?

13 FAA ORDER A 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.

14 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

15 APPROVED DESIGN MEANS All pertinent information defined Drawings and specifications show the configuration of the part. Airworthiness limitations defined.

16 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.

17 PROPERLY PRODUCED MEANS... PRODUCED “ I/A/W” THE REQUIREMENTS OR EXCEPTIONS OF FAR Part 21. FAR 21 Part

18 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)

19 “PROPERLY PRODUCED” …continued  4) BILATERAL (Subpart N)  5) OWNER / OPERATOR (Subpart K)  6) TC WITHOUT SEPARATE PRODUCTION AUTHORIZATION (Subpart F)

20 “PROPERLY PRODUCED” …continued 7) PC INCLUDING A LICENSEE, PC  8) STANDARD PARTS (Subpart K).  9) REPAIR STATION UNDER STC OR FIELD APPROVAL ( FAA ORDER , FAR 43)

21 “PROPERLY PRODUCED” …continued 10) A REPAIR NOT FOR SALE AS A SEPARATE PART (Subpart K) 11) ANY OTHER MANNER APPROVED BY THE ADMINISTRATOR (Subpart K).

22 PROPERLY MAINTAINED MEANS... IN ACCORDANCE WITH FAR PART 43 AND 91

23 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

24 FAR 43.13(a) CURRENT MANUFACTURER’S MAINTENANCE MANUAL OR INSTRUCTIONS FOR CONTINUED AIRWORTHINESS

25 FAR (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.

26 FAR 43.13(b) says... AT LEAST EQUAL TO ITS ORIGINAL OR PROPERLY ALTERED CONDITION

27 FAR 91 SAYS (a) NO PERSON MAY OPERATE A CIVIL AIRCRAFT UNLESS IT IS IN A AIRWORTHY CONDITION (b) NO PERSON MAY PERFORM MAINTENANCE …AS PERSCRIBED IN THIS SUBPART …INCLUDING FAR PART (c) NO PERSON MAY OPERATE AN AIRCRAFT FOR WHICH A MANUFACTURER MAINTENANCE MANUAL OR INSTRUCTIONS...

28 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.

29 HOW DOES AN INSTALLER KNOW THEY ARE USING “APPROVED PARTS”? BY USING ONLY “ APPROVED” PARTS FROM AN APPROVED SYSTEM!! OR

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

31 DID YOU KNOW ?

32 ITS POSSIBLE TO COMPLY WITH FAR (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,... BUT

33 OK, WHAT IS AN “UNAPPROVED PART?”  IF A PART IS NOT AN “APPROVED PART”  THEN IT IS AN “UNAPPROVED PART”  THEN IT IS AN “UNAPPROVED PART”

34 …AND IF YOU DON’T KNOW, THEN IT IS A  SUSPECTED “UNAPPROVED PART”

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

36 SUPs REPORTING FAA Suspected Unapproved Parts (AVR-20) Park Center Road, Suite 165 Herndon, VA Phone: Fax:

37 Guidance for Reporting SUPs AC 21-29B Detecting and Reporting Suspected Unapproved Parts. FAA ORDER A Suspected Unapproved Parts Program

38 WHO INVESTIGATES WHEN SUPS ARE REPORTED? FOR NEW PARTS (MIDO) FOR REPAIRED PARTS (FSDO) FOR INSTALLED PARTS (FSDO and/or MIDO )

39 FAA Actions…continued GATHER ALL AVAILABLE SUPPORTING EVIDENCE

40 FAA Actions…continued ASK THAT SUSPECTED “UNAPPROVED PARTS” BE QUARANTINED AND HELD FOR FURTHER INVESTIGATION

41 YOUR ACTIONS... HAVE ADEQUATE INCOMING INSPECTIONS PROCEDURES TO DETECT “UNAPPROVED PARTS”.

42 Your Actions…continued CONDUCT INTERNAL AUDITS AND SURVEIL FOR UNAPPROVED PARTS DURING ALL FACILITY AND STOCK ROOM INSPECTIONS.

43 Your Actions…continued ALWAYS REQUIRE CERTIFICATION THAT PARTS SUPPLIED ARE “APPROVED PARTS”

44 Your Actions…continued USE APPROPRIATE TECH DATA TO COMPLY WITH 43.13(a). IF NEEDED, REQUEST FAA or DER ENGINEERING SUPPORT TO DOCUMENT COMPLIANCE.

45 Your Actions…continued IF REQUIRED, DEMONSTRATE COMPLIANCE WITH (b) BY SHOWING THAT A PART IS EQUAL TO ITS ORIGINAL OR PROPERLY ALTERED CONDITION.

46 Your Actions…continued FORM FIT AND FUNCTION

47 Your Actions…continued DISPOSE OF UNSALVAGEABLE AIRCRAFT PARTS AND MATERIALS IAW AC # 21-38

48 Your Actions…continued LEARN TO RECOGNIZE INDICATORS OF FRAUD

49 FRAUD IN THE... PARTS DOCUMENTATION FACILITIES PERSONNEL SUPPLIERS BROKERS

50 TITLE 49 of the USC ( THE FARs ) IMPROPER DESIGN IMPROPER MANUFACTURING IMPROPER MAINTENANCE SALE OF PARTS IMPROPERLY DESIGNED MANUFACTURED MAINTAINED

51 TITLE 18 of the USC FRAUDULENT DESIGN FRAUDULENT MANUFACTURING FRAUDULENT MAINTENANCE SALE OF PARTS FRAUDULENTLY DESIGNED MANUFACTURED MAINTAINED

52 “COUNTERFEIT PARTS” COUNTERFEIT PARTS ARE ALWAYS “UNAPPROVED”. COUNTERFEIT PARTS ARE ALWAYS REPORTABLE. COUNTERFEIT PARTS ARE  ALWAYS ILLEGAL, THEREFORE, CRIMINAL...

53 ANNOUNCING GRAND OPENING OF... “PISTON POPPERS” INC. SALES / SERVICE of PISTONS

54 “APPROVED PART” “APPROVED PART”

55 “UNAPPROVED PART” “UNAPPROVED PART”

56 ASHTRAY

57 SUSPECTED “UNAPPROVED PART” SUSPECTED “UNAPPROVED PART”

58 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”

59 “FLY SAFE” “FLY SAFE”

60 ??? QUESTIONS ??? FAR’s PARTS