What are “Unapproved Parts?”
Aviation is such a complex industry, with so many (literal) moving parts. While learning about MRO (Maintenance, Repair, and Overhaul) operations, we touched briefly on the FAA Suspected Unapproved Parts Program, and I was intrigued. If you think about it, there are billions of aircraft parts in circulation in the U.S. Aviation Industry at any given moment. The majority of these parts are vital to aircraft operations, and can put passengers in danger if they fail. How do aircraft operators ensure that their parts are actually the high quality that they are relying on when they purchase them?
In 1993 the FAA created the Suspected Unapproved Parts Program in order to decrease the amount of aircraft parts in circulation with unknown or questionable history. The purchasing and installation of these unapproved parts can cause a hazard to flight operations, as their quality is undetermined and they may be unacceptable. The ultimate requirement of an aircraft operator is to maintain airworthiness as specified in the particular part of the Federal Aviation Regulations that governs that type of operation, which also includes all individual parts being in compliance.
Advisory Circular 21-29C defines a S.U.P. as, “A part, component, or material that is suspected of not meeting the requirements of an approved part. A part that, for any reason, a person believes is not approved. Reasons may include findings such as different finish, size, color, improper (or lack of) identification, incomplete or altered paperwork, or any other questionable indication.” So really, a S.U.P. could be anything.
The Advisory Circular makes a clear distinction between aircraft parts that are sold with the understanding that it is for decorative purposes only, and parts that are disguised as airworthy. It is the responsibility of the buyer to request and receive the documentation necessary to show the purpose of the part. Selling a part that is clearly not airworthy is not a crime, as long as the seller does not do it under the premise that it is airworthy.
How are they caught?
There is a process that the FAA has created to report a suspected unapproved part. First, you could call The Aviation Safety Hotline to report unsafe practices that affect aviation safety, including the manufacture, distribution, or use of an S.U.P. Their number is 1-800-255-1111 or 1-866-835-5322. If requested, the caller may remain anonymous.
There is also a standardized form, FAA Form 8120-11, that outlines the information needed about the S.U.P. This includes the date the part was discovered, the part serial number, information about the company that supplied the part, a description of the issue, and several other important facts that the FAA will need to investigate. This form can then be sent to the Aviation Safety Hotline via e-mail or to their physical address in Washington, DC. Although this is a relatively low-tech solution to the problem, it is a solid system for reporting S.U.P. and has done a lot of good.
The FAA then investigates the S.U.P., and if it is found to be unacceptable they will send out an Unapproved Parts Notification (UPN). These are available to the public, and can be found on the FAA website. The most recently posted UPN was put on the site on February 15th, 2018, and outlines various parts distributed by Genesis Aviation Inc. This report recommends that aircraft owners who have installed the parts to inspect and remove them from their aircraft to keep it airworthy.
Why even bother?
The goal of the S.U.P. program is to improve safety and promote transparency in aviation. By having a system in place to detect and report unapproved parts, aircraft maintenance personnel and aircraft owners have an easier way to ensure they are using the best parts available. Removing all unapproved parts from the U.S. Aviation Industry is a huge undertaking, but with the task force making it their personal mission it is much more likely to come to fruition.
This leaves one to wonder what happens to the company or individual that gets caught selling unapproved parts. According to a press release fact sheet sent out by the FAA on the matter, “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.”
Unapproved parts are a very serious matter that affect the safety of air travel. The FAA has created a great way for any possible unapproved parts to get caught and removed from the U.S. Aviation system.