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Trace to Foreign Airlines

Ok, it’s time to get serious again, and this will be a long one. It really chaps my hide to hear of some company’s procedural prohibitions that are not based on sound logic. The whole discussion of restrictions on trace to foreign airlines falls in that category. Lets look at the range of points on the subject, and a recommended fix.

REALITY CHECK: First, lets understand that there is no regulatory basis for anyone to say they can’t accept parts with trace to a foreign airline. Nonetheless, Operators with such restrictions have placed language in their GPM’s or GMM’s reflective of the restriction making it a de-facto requirement, but again lets emphasize that such language does not have a regulatory basis. Later I’ll share a story of how one operator changed their procedures to allow such trace.

HISTORICAL ARGUMENTS: Most persons who have restrictions on such trace base it on the fact that they cannot assert that the part was maintained and operated in accordance with data approved by our administrator. That is a fundamental concern I agree with, and unless we can adequately address it, this discussion would be fruitless

• · NEW PARTS: The definition of new parts is a part that “…has no operating time or cycles” (ref ATA Spec 106). In other words, the part’s never been in service! If you receive the part with a statement that it was purchased from a Production Approval Holder (PAH), and based on your inspection the part indeed looks and smells new and has the required markings as other parts purchased directly from the PAH, what’s the logic of not using it? Now, it’s true that you may have a new computer, for example, and while in stock the foreign operator may have had it sent out for a modification. If you have such concerns, keep reading.

• PARTS OTHER THAN NEW: Here is where the concern about using approved data comes into play. Royboy suggests the following:

• Buy the part and have it sent either to your home shop or your approved MRO provider

• On your RO, add text apprising them that the part was purchased from a foreign operator, and that you want a hidden damage inspection performed in addition to an IRAN (Inspect and Repair As Necessary), or Overhaul as you see fit. If the shop hangs an 8130-3 on it, why not use the part? That shop is now attesting that the part conforms to the requirements of the approved maintenance data and is “Approved for Return to Service.”

AIRLINE CASE STUDY: Here’s the background: I used to work at a major airline, and at the time I left I was a QA Manager. There existed a time that this airline would not buy parts with trace to any foreign airline. They had fleets of aircraft that included aging 727’s and DC-10’s, and finding certain spare parts was becoming an increasing challenge for the purchasing staff. Enter the parts-challenged purchaser.

One fine day I had a conversation with a purchaser that went something like this:

Purchaser: “Roy, you know we have a parts pooling arrangement with many foreign airlines whereby we can use their parts (lease it or rent it) if one of our aircraft needs it while parked at their station, right?”

Roy: “Yes, of course I’m aware of it.”

Purchaser: “Well, if I want to convert that lease or rental into a purchase, I can’t do it, right?”

Roy: (now this guy is irritating me because I know he knows the answer) “As keeper of the sacred writ of GPM requirements, I have to inform you that the answer is no.”

Purchaser: “Why not?”

My mind now spins into an abyss caused by a clash between my institutional values and a confrontation with logic; Why not? After all, when we use a pooled part from a foreign airline, we are installing it on a “N” registered aircraft, flying U.S. citizens, over U.S. airspace, but we can’t convert that leased part into a purchase; Why not?

I diligently start to research the entire topic of purchases from foreign airlines. I read, I ask, I email, but I cannot find a regulatory basis for this! In fact some of the persons in high places I’ve spoken to about this seem quite agitated that someone is questioning this long-held prohibition. I conclude that in order to change it, and to gain approval signatures for the revision, I’m going to need a set of convincing controls everyone feels they can buy off on.

How’s this: As an airline, in order to participate in a parts pooling arrangement, you have to have an Operations Specification on your Certificate commonly called a D81 Op-Spec. This is issued by the FAA in accordance with their manual, FAA Order 8300.10, Volume 2, Chapter 84. The Op-Spec must list those foreign airlines participating in the pool agreement. Further, the Op-Spec says that “The certificate holder shall not use any part provided by any participant identified herein unless that part complies with applicable provisions of the Federal Aviation Regulations and the certificate holders manual.” So, you must have a procedure in your manual to assure that such foreign carriers can provide parts that meet the applicable portions of the FAR’s before you submit their name to the FAA for inclusion on the Op-Spec. Incidentally, this process is facilitated by the International Airlines Technical Pool, or IATP. So, for pooled parts there’s already a system in place to assure only airworthy parts are used, and that system has written procedures with oversight by the FAA (my eyebrows are seen to flutter up and down).

With this understanding, my envisioned central control for purchasing parts from foreign airlines would be that they must first already be on the D-81 Op-Spec which contains those aforementioned controls. In other words, if you can lease or rent the pooled parts from listed foreign airlines, you can also issue PO’s to them. To make a long story short, after much lobbying and writing additional supportive language, my management colleagues signed off on the GPM revision, and soon our purchasers had a whole new world-source of additional, hard to find parts.

At the 2002 Aviation Suppliers Conference, there was a session with a panel of airline reps where the audience could ask questions. Someone asked the panel about their policies on purchases of parts with trace to foreign airlines. Much to my surprise a few of the operators stated they had now instituted a policy similar to that pioneered by my former employer! WOOHOO!

Now, about buying parts from the military…Nah, check a future blog.

10/7/03

Roy Resto - VP Technical Operations, FAA-DAR
Phone: 414 875-2191   Fax: 414 875-0200
royboy@mbtrepair.com

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