Sofema Aviation Services, www.sassofia.com, considers terminology related to FAA Unapproved Parts.
Introduction What is an Unapproved Part?
Note: Unapproved parts are not acceptable either within the FAA or EASA system. No part that is found to be not acceptable for fitment under FAA conditions will ever be acceptable to fit an EASA-registered aircraft.
A part that fails to meet any of the criteria pursuant to FAR Part 21. This definition also includes parts that have been intentionally misrepresented, including counterfeit parts.
Examples include:
Supplier-produced parts for an approved manufacturer are directly shipped to end-users without the Production Approval Holder's (PAH’s) authorization or a separate Parts Manufacture Authority's (PMA).
Note: Some suppliers to a PAH have direct ship authority to the end-user without the parts being originally processed by the PAH or its associate facility’s receiving inspection facilities. However, direct ship authority must be authorized in writing by the PAH or associate facility and does not apply to parts not specifically included in the PAH’s permission document.
The supplier must provide a signed direct ship declaration with the date of authorization and a statement of conformance with the shipment.
Parts that have passed through a PAH’s quality system that do not conform to the approved design/data.
Note 1: A new part released from a PAH’s quality system that does not conform to the applicable design data is considered to be a quality escape/nonconforming article.
Such a part is ineligible to be installed on a TC aircraft, and the recipient of such a part should contact the company that supplied the part for replacement. If a conforming replacement part is not provided, a SUP report may be warranted.
Note 2: Do not report parts damaged due to shipping or warranty issues as a SUP. Contact the provider/shipper for replacement.
Parts offered as having been produced under an FAA production approval, where no such FAA approval was issued.
Parts for which required documentation cannot be provided.
Note: Reporting parts that are missing documentation are acceptable but may not be optimal.
If your purchase order requested conformity documentation, you should reject the part for failure to meet the terms of the purchase order. Return the part to the vendor and request proper documentation before accepting the part.
Life-limited parts are misrepresented as new or having useful time left. If a part is determined to be repairable, it should be documented and controlled so that it is not returned to aviation service until it meets all the necessary airworthy requirements. If the owner determines that a part is not repairable, it should be scrapped in such a manner that it cannot be returned to aviation service.
If a salvaged part is received, proper documentation and examination are crucial to determining if it is eligible for installation on TC products. see FAA AC 21-43, Scrap or Salvageable Aircraft Products and Articles, Appendix E).
Parts previously installed on or manufactured for military aircraft that have not been shown to conform to type design criteria pursuant to FAA regulations.
Surplus parts (left-overs or production over-runs) produced by a company not possessing a PMA or direct ship authority, that were manufactured to satisfy a contract or purchase order with a PAH and were never accepted into the PAH-approved quality system.
Sofema Aviation Services and Sofema Online provide a regulatory training course covering the important subject of Suspect Parts within both FAA and EASA Jurisdictions.
The European Aviation Safety Agency (EASA) & Federal Aviation Agency (FAA) Suspect Parts Training - ½ Day course defines the SUPs policy of EASA & FAA; provides procedures to identify SUPs; and outlines investigative techniques which satisfy safety and enforcement responsibilities.
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