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“Back to Birth” or “Cradle to Grave” Records for Life Limited Parts

Its Friday afternoon, and the combined affect of all the coffee and chocolate Hostess Donettes I’ve been consuming is starting to make me feel feistier than usual. I’m thus in great shape to engage in the beloved sport of challenging those paradigms that seem to cost customers time and money; this usually because certain purchasing organizations have black and white rules that are outdated or un-enlightened. Let’s launch into an examination of why is it that some purchasers require ‘back to birth’ (AKA cradle to grave) records for purchases of life limited parts?

If you are buying a new part, the manufacturer no doubt is providing you the proper documentation that the part has zero time or cycles, and of course you have the appropriate trace to that manufacturer, a Production Approval Holder (PAH). With that established, it should be clear that in this tech log we are addressing the purchases of aftermarket parts with existing time or cycles.

First, we should make unequivocally clear that there is NO regulatory requirement for either the purchaser or provider of such parts to produce back to birth records, none, zip, nada. So why do some purchasers require it? It may seem intuitive or logical to require such records, but the plain truth is it is not necessary; all you really need is the part’s current status, but I’m getting ahead of myself. While I can’t recreate how the practice of requiring back to birth records started, we can look at a document that does require it. The Air Transport Association publishes many standards, and one that is commonly cited is ATA Specification 106, titled “Sources & Approved Parts Qualification Guidelines”, commonly called Spec 106. The current publication contains a Table B-1.1: “Aircraft Parts Documentation Requirements”. Under the column labeled “Life Limited”, is a Note 2 that states “The seller must supply documentation indicating the ‘cradle to grave’ history of the part.” In all my research, it seems that this is the lone document suggesting such practices. Does it harmonize with regulatory requirements?

FAR 43.10 is the big stick regulation on the subject and is titled “Disposition Of Life Limited Parts.” Paragraphs (c) (1) and (2) state the following:

(1) Record keeping system. The part may be controlled using a record keeping system that substantiates the part number, serial number, and current life status (my italics) of the part. Each time the part is removed from a type certificated product, the record must be updated with the current life status. This system may include electronic, paper, or other means of record keeping.

(2) Tag or record attached to part. A tag or other record may be attached to the part. The tag or record must include the part number, serial number, and current life status of the part. Each time the part is removed from a type certificated product, either a new tag or record must be created, or the existing tag or record must be updated with the current life status.

Regarding the sale of such parts. the same FAR says:

(d) Transfer of life-limited parts. Each person who removes a life-limited part from a type certificated product and later sells or otherwise transfers that part must transfer with the part the mark, tag, or other record used to comply with this section, unless the part is mutilated before it is sold or transferred.

Hmmm, no back to birth or cradle grave language here.

Lets try FAR 91.417, titled “Maintenance Records”. Paragraph (a)(2)((ii) states that the owner/operator must maintain records containing the following:

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

Hmmm, no back to birth or cradle grave language here either.

Well, lets try FAR 121.380 titled “Maintenance Recording Requirements.” Its paragraph (a)(2)(iii) requires records for:

(iii) The current status of life-limited parts of each airframe, engine, propeller, and appliance.

Oooohkaaay, still no back to birth or cradle to grave lingo. In fact, AC 43-9C paragraph 15 b., and AC 120-16D paragraph 605 1.b. contain the same language that requires only the current status of a life limited part be recorded and provided upon transfer or sale.

In today’s robust aftermarket arena, it’s common for parts to perhaps change owners several times. If you have a black and white policy that you will only purchase life limited parts when provided with back to birth or cradle to grave records, you’ve eliminated this source of parts, because you likely won’t get it unless you obtain the part from an owner who has been the sole operator of the part, and this is not guaranteed. Your black and white policy has unquestionably raised your operating costs, and that’s too bad because your policy is not a regulatory requirement. What must be guaranteed, and what should be your single concern, is the current status of the part; how many cycles and/or hours does the thing have? This answers your next question, how much life is left? The bottom line is that we should trust the airline or repair station to follow the aforementioned FARs and provide you an accurate ‘current status’ for your operational needs.

Exit stage right...

4/26/05

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

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