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Blog
FAA SUPs Notices
BACKGROUND:
A sobering thought: The FAA’s SUP’s office in Washington DC
(AVR-20), continues to receive hundreds of Suspected Unapproved
Parts (SUPs) reports a year. Some turn out to be harmless or
unfounded, and some result in actions by certain agencies. Most are
handled without fanfare. In a few instances, when the FAA SUPs
office feels that the public needs to be apprised of the results of
an investigation, they will issue an Unapproved Parts Notice (UPN).
An example of when to issue a UPN may involve a repair station that
overhauled hundreds of parts that were not processed in accordance
with approved data, and the FAA could not positively determine who
in the aviation public were in possession of those parts. In this
case, the FAA would issue the UPN to the public for the obvious
reasons. On the other hand, if it was determined that the same
repair station produced only 10 such parts, and the repair station
and the FAA were able to contact all ten of the operators/owners of
those parts to effectively recall the parts, there’s really no
need to issue a UPN. Suffice it to say that even then the repair
station may face some “administrative actions” by the FAA. How
do you get these UPNs?
ACCESSING UPNs:
Being on distribution for UPNs depends on who you are. If you’re
an airline or repair station, someone in your organization is
already on distribution for these (most of the time). If you’re a
distributor it is very unlikely that you are on distribution. If you
are a distributor who is an ASA (Aviation Suppliers Association)
member, you’ll see these published in the ASA Newsletter. In any
event, you can access UPN’s directly at the FAA’s SUPs website
at:
http://www.faa.gov/avr/sups
In fact I urge you to poke around this web site for all the useful
information posted there regardless if you’re on distribution for
UPNs or otherwise. OK, just what in the world are you expected to do
with these UPNs?
WHAT SHOULD YOU DO WITH UPNs?
How you address UPNs depends again, on who you are.
Distributors: If you claim to have a wonderful Quality
System, and in particular if you are an accredited distributor, your
customers expect that you perform SUPs screening of the parts you
process. If, as part of your SUPs screening program you do not
methodically and routinely access UPNs, you are not being
sufficiently thorough in your Quality system (there, I said
it, and I meant it). Typically, when you get or access a new UPN
your first question should be “Have we been in receipt of, or
shipped parts that were affected by the UPN?” In most cases, the
UPN will list the name of a company, and perhaps some part numbers.
Have you purchased parts from that company? What about the part
numbers? A quick check of your inventory control system should
apprise you of that. If you make a determination that you have
shipped parts to a customer affected by the UPN, the right thing
to do is to apprise them of the fact, and work out a corrective
action plan with them as necessary. The overwhelming majority of the
time you won’t be affected by the UPNs, but consider the
following. If you deal in the aftermarket, there may be some
lingering affected parts that may eventually come across your
inspection system. Can you place warnings in your inventory control
system to apprise salespersons about accepting trace to a certain
company? How about circulating the UPN to your inspectors for a
‘read and sign’ effort?
Airlines and Repair Stations: If these types of companies
make the determination that parts installed or in their system are
affected by the UPN, they have to make the tough decision about what
to do with them. The corrective action depends on the circumstances.
For example, do the parts affect safety of flight, can a simple BITE
check or other visual check verify the airworthiness of the part,
how many parts are involved, will the parts have to be removed and
sent to a shop, etc? The realm of possibilities is really endless,
and to list the possible corrective actions is beyond the scope of
this Tech Log. I have the utmost confidence in the operators to make
the right decisions.
BEWARE THE PARTS WITH MULTIPLE CHAINS
OF CUSTODY.
Suppose you are inspecting a part and you have all its trace
documents in hand. At this time it is quite easy to determine if the
chain of custody (which may have changed hands several times)
involves a company affected by a UPN. But what about those parts
you’ve shipped or installed already? You’ve long ago filed the
trace documents, and your inventory control system will only tell
you from whom you directly purchased the part, not its chain
of custody. This masks a potential positive determination that you
have parts affected by a UPN. This is most troubling and
problematic. Do you have the resources to dedicate to search stored
boxes and boxes of trace documents because you think
there’s a possibility that a trace chain of custody may involve a
company named by a UPN? What you do really depends on your integrity
and wisdom. If you have a basis to assume that a reasonable
possibility exists of such trace, what will you do about it?
In a perfect world, someone at every aviation company involved with
aircraft parts would access and take responsible action when
affected by a UPN, then this problem would not be up for discussion.
But since this perfection does not exist, the industry can only rely
on informed, educated and responsible persons like yourself.
8/20/04
Roy Resto
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VP Technical Operations,
FAA-DAR
Phone: 414 875-2191
Fax: 414 875-0200
royboy@mbtrepair.com
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