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Trace to the Military or Government

Let me ask you a question: Your customer needs some NAS960-3 washers. The market is dry, but you locate some new-condition parts with trace to a military or government source. Will you or your customer accept them? Without any discussion or second thoughts, mostly all commercial operators will answer flatly, ‘no thanks’. It’s time for us to re-examine this ‘stinkin thinkin’. After all, operators have rethought their previous taboo’s against purchases of PMA parts, and trace to foreign airlines; this to the betterment of their bottom line, so lets see if we can similarly knock a few holes in this ivory tower.

Why is this a good time to rethink this? The military and government (herein jointly referred to as ‘government’) are increasingly using traditional civilian platforms to perform their missions. In just the heavy-iron sector we increasingly see DC-9, DC-10, 707, 727, 737, 757 and 747 platforms adapted to the government’s use. Paralleling this trend is the government’s mandate to use where possible, Commercial Off The Shelf (COTS) parts and systems. This means that if there is a readily available commercial part or system that will meet the government’s needs, use it. Although traced to a government source, do you think some of those parts are identical to, and eligible for use in the civilian market? Of course you silly wabbit. Is it possible that some of those parts may find themselves offered for sale on the aftermarket? Well duh! If they are both eligible and available, why not use them? OK, enough of the introduction. Let’s start from the beginning.

In the commercial aircraft parts aftermarket, there has long been a de facto prohibition on the use of parts with trace to the military or the government. This black and white prohibition even extends to parts that are without question, demonstrably eligible to be installed on civilian, type certificated aircraft. First, a reality check please! There is NO FAR that prohibits use of parts that are traced to government sources, zero, nada, zilch. On the other hand, there is the expressed understanding that these parts (as with any part regardless of trace) must meet the requirements of the FAR’s regarding Eligibility and Airworthiness (of course). 

A critical document to become familiar with is the FAA’s Advisory Circular 20-142, titled “Eligibility and Evaluation of U.S. Military Surplus Flight Safety Critical Aircraft Parts, Engines, and Propellers.” This AC gives excellent guidance on the logic you should use to determine a part’s eligibility. Of particular interest is the AC’s definition of “Dual Use Product/Part”, which it defines as ‘Any product or part manufactured for civil application by a Production Approval Holder (PAH) authorized by the FAA which is also procured under a U.S. Military contract. The part or product has the identical part number and configuration as its civil counterpart; it was manufactured using the same FAA approved design, materials, and manufacturing processes. These could also include any product (or part thereof) originally produced for the military which currently holds a normal, utility, acrobatic, or transport type certificate (TC) issued under (FAR) section 21.27.’ I won’t try to duplicate or paraphrase the information in this AC, but suffice it to say that after it’s been read a few times, the light should come on. 

Questions of eligibility aside, traditional arguments against use of government parts centered around the following concerns:

• What type of Maintenance Data/Program were the product or parts operated under?

• What type of environment or stresses were the parts subjected to?

Great questions! Send the part to an FAA Repair Station and have them inspect the part. You should state all the facts related to the purchase, and ask for a hidden damage inspection. If they hang an 8130-3 tag on it, you’re good to go. 

As many enlightened operators have done, they have placed internal controls on the purchases of PMA parts, and parts with trace to foreign airlines, to allow such purchases. Internal controls can also be established for purchases with trace to government sources. 

Now back to those NAS960 washers. They’re new, standard parts, and with a C of C. They’ve never been placed in operation, and would pass your inspection. Do you take them? But Royboy, they’re traced to a government source. Excuse me, can some common sense prevail here? Sorry, my customer won’t accept that trace. I’m seen to roll my eyes, press my lips, and tap my fingers frustratingly on the desk. Oh well, some day...

3/2/05

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

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