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“APPROVED PARTS”

PRESENTED BY

DON E. GARDNER AVIATION SAFETY INSPECTOR

CHARLOTTE FSDO #33 (704) 319-7020

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IA 2004

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““APPROVED PARTS”APPROVED PARTS”

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OUR GOAL...

TO ELIMINATE THE POTENTIAL SAFETY RISK

POSED BY “UNAPPROVED” PARTS,….

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and to accomplish

that...

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WE MUST KEEP “UNAPPROVED PARTS”

OUT OF THE AVIATION SYSTEM.

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TODAY’S TOPICS• HISTORY

• DEFINITIONS

• ACTIONS

• INDICATORS OF FRAUD

• DEMONSTRATION

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BRIEF HISTORY• AUGUST 1995 SUP TASK FORCE

CONVENED.

• AFS, AIR, LEA, AGC AND OTHERS.

• CONDUCTED A THOROUGH REVIEW OF THE SUP ISSUE.

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HISTORY…continued

• BUILD ON PAST INITIATIVES

• MAKE THE SUP PROGRAM

MORE EFFECTIVE

• CONCERNS OF CONGRESS AND

THE DOT/OIG

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HISTORY…continued

TASK FORCE WAS

A CROSS

SECTION OF

FIELD AND

HEADQUARTERS

PERSONNEL.

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What is an

“APPROVED PART” ?

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FAA ORDER 8120.10A FAA ORDER 8120.10A DEFINES AN “APPROVED DEFINES AN “APPROVED

PART“AS...PART“AS...

• PRODUCED IAW REQUIREMENTS or EXCEPTIONS OF FAR Part 21,

• MAINTAINED IAW FAR Part 43 & 91,and

• MEETS APPLICABLE DESIGN STANDARDS.

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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

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APPROVED DESIGN MEANS

• All pertinent information defined

• Drawings and specifications show the configuration of the part.

• Airworthiness limitations defined.

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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.

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PROPERLY PRODUCED MEANS...

PRODUCED “I/A/W” THE

REQUIREMENTS OR EXCEPTIONS OF FAR Part 21.

FAR21

Part

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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)

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“PROPERLY PRODUCED” …continued

4) BILATERAL (Subpart N)

5) OWNER / OPERATOR (Subpart K)

6) TC WITHOUT SEPARATE PRODUCTION AUTHORIZATION (Subpart F)

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“PROPERLY PRODUCED” …continued

7) PC INCLUDING A LICENSEE, PC

8) STANDARD PARTS (Subpart K).

9) REPAIR STATION UNDER STC OR FIELD

APPROVAL (FAA ORDER 8000.50, FAR 43)

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“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).

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PROPERLY MAINTAINED MEANS...

IN ACCORDANCE WITH FAR PART 43 AND 91

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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

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FAR 43.13(a)

CURRENT MANUFACTURER’S

MAINTENANCE MANUAL OR INSTRUCTIONS FOR

CONTINUED AIRWORTHINESS

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FAR 43.13 (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.

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FAR 43.13(b) says...

AT LEAST EQUAL TO ITS ORIGINAL OR PROPERLY

ALTERED CONDITION

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FAR 91 SAYS...

• 91.7 (a) NO PERSON MAY OPERATE A CIVIL AIRCRAFT UNLESS IT IS IN A AIRWORTHY CONDITION

• 91.403 (b) NO PERSON MAY PERFORM MAINTENANCE …AS PERSCRIBED IN THIS SUBPART …INCLUDING FAR PART 43 ...

• 91.403 (c) NO PERSON MAY OPERATE AN AIRCRAFT FOR WHICH A MANUFACTURER MAINTENANCE MANUAL OR INSTRUCTIONS...

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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.

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HOW DOES AN INSTALLER KNOW THEY ARE USING “APPROVED PARTS”?

BY USING ONLY

“APPROVED” PARTS

FROM AN APPROVED

SYSTEM!!

OR

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DETERMINE THAT PARTS CONFORM TO TYPE DESIGN BY USING TECHNICAL DATA, BLUE PRINTS

OR OTHER SPECIFICATIONS.

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DID YOU KNOW ?

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• ITS POSSIBLE TO COMPLY WITH FAR 43.13 (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

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OK, WHAT IS AN “UNAPPROVED PART?”

IF A PART IS NOT AN “APPROVED PART”

THEN IT IS AN

“UNAPPROVED PART”

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…AND IF YOU DON’T KNOW,

THEN IT IS A

SUSPECTED “UNAPPROVED PART”

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SUP IF A DETERMINATION

CANNOT BE MADE, QUARANTINED THE PART,

BECAUSE IT MIGHT REQUIRE REPORTING AS A SUP

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SUPs SUPs REPORTINGREPORTING

FAA Suspected Unapproved Parts (AVR-20)13873 Park Center Road, Suite 165

Herndon, VA 20171Phone: 703-668-3720

Fax: 703-481-3002www.faa.gov/avr/sups/

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Guidance forReporting SUPs

• AC 21-29B Detecting and Reporting Suspected Unapproved Parts.

• FAA ORDER 8120-10A Suspected Unapproved Parts Program

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WHO INVESTIGATES WHENSUPS ARE REPORTED?

• FOR NEW PARTS (MIDO)

• FOR REPAIRED PARTS (FSDO)

• FOR INSTALLED PARTS

(FSDO and/or MIDO )

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FAA Actions…continued

GATHER ALL AVAILABLE

SUPPORTING EVIDENCE

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FAA Actions…continued ASK THAT SUSPECTED

“UNAPPROVED PARTS”

BE QUARANTINED AND

HELD FOR FURTHER

INVESTIGATION

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YOUR ACTIONS...

HAVE ADEQUATE INCOMING

INSPECTIONS PROCEDURES TO

DETECT “UNAPPROVED PARTS”.

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Your Actions…continued CONDUCT INTERNAL

AUDITS AND SURVEIL FOR UNAPPROVED

PARTS DURING ALL FACILITY AND STOCK ROOM INSPECTIONS.

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Your Actions…continued

ALWAYS REQUIRE

CERTIFICATION THAT PARTS

SUPPLIED ARE “APPROVED

PARTS”

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Your Actions…continued

• USE APPROPRIATE TECH DATA TO

COMPLY WITH 43.13(a).

• IF NEEDED, REQUEST FAA or DER ENGINEERING SUPPORT TO DOCUMENT

COMPLIANCE.

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Your Actions…continued IF REQUIRED, DEMONSTRATE

COMPLIANCE WITH 43.13 (b) BY SHOWING

THAT A PART IS EQUAL TO ITS ORIGINAL OR

PROPERLY ALTERED CONDITION .

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Your Actions…continued

FORMFIT

AND

FUNCTION

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Your Actions…continued

DISPOSE OF

UNSALVAGEABLE

AIRCRAFT PARTS

AND MATERIALS

IAW AC # 21-38

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Your Actions…continued

LEARN TO RECOGNIZE INDICATORS OF FRAUD

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FRAUD IN THE...

• PARTS• DOCUMENTATION• FACILITIES• PERSONNEL• SUPPLIERS• BROKERS

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TITLE 49 of the USC ( THE FARs )

• IMPROPER DESIGN• IMPROPER MANUFACTURING• IMPROPER MAINTENANCE• SALE OF PARTS IMPROPERLY

• DESIGNED• MANUFACTURED • MAINTAINED

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TITLE 18 of the USC

• FRAUDULENT DESIGN• FRAUDULENT MANUFACTURING• FRAUDULENT MAINTENANCE• SALE OF PARTS FRAUDULENTLY

• DESIGNED• MANUFACTURED• MAINTAINED

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“COUNTERFEIT PARTS”• COUNTERFEIT PARTS ARE ALWAYS

“UNAPPROVED”.• COUNTERFEIT PARTS ARE ALWAYS

REPORTABLE.• COUNTERFEIT PARTS ARE ALWAYS ILLEGAL , THEREFORE,

CRIMINAL...

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ANNOUNCINGANNOUNCINGGRAND OPENING OF...GRAND OPENING OF...

““PISTON POPPERS” PISTON POPPERS” INC.INC.

SALES / SERVICESALES / SERVICEof of

PISTONSPISTONS

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“APPROVEDPART”

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“UNAPPROVEDPART”

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ASHTRAY

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SUSPECTED“UNAPPROVED

PART”

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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”

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“FLY SAFE”

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??? QUESTIONS ???

FAR’s PARTS