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A customer auditor recently performed an audit at our facility. He noticed some parts stored on the floor and wall, and wrote up this finding: “Some leading edges and cowls are stacked against the wall or on the floor without proper protection (cardboard, bubblewrap, wood, etc.)”. I countered that all these parts were in unserviceable condition. This did not deter the auditor from writing it up. I also noticed there was no citation to a standard for the writeup. Hmm...

Aviation quality standards require that parts and components be protected while in storage. For example, the ASA-100 requires “...that serviceable parts/components are adequately protected against the environment and damage by being properly wrapped, packaged, boxed, etc., as appropriate.” Admirably, note that this standard makes this distinction for serviceable parts. This in not so for other standards which make general statements about the protection of parts without distinguishing as to the condition of the parts.

Regarding unserviceable parts, it’s important that a distinction be made here. In the broad aviation community, there are really two types of unserviceable parts:

• Unserviceable parts that are “in service”

• Unserviceable parts that are “not in service”

“In service” unserviceable parts are those for example, in an airline’s rotable cycle; The parts are owned by the operator. On the other hand, “not in service” unserviceable parts are those not owned by any operator; typically those which may be found in a distributor’s inventory. Lets talk about both these types

IN SERVICE, UNSERVICEABLE PARTS: Many of you have worked at airlines, GA, military, or for third party MRO’s. If any mechanic or employee was observed to be man-handling, mistreating, or otherwise not properly handling unserviceable parts, a predictable voice would boom across the hangar, “You’re in big trouble mister!”. That the part was unserviceable and on its way to the repair shop was not a defense. After all, why subject the part to additional damage that will inflate the cost of repair or overhaul? That’s good policy. In fact, these parts should be given the same level of care and protection afforded serviceable parts. Fluid ports and electrical connectors should be capped, ESD components should be protected, etc.

NOT IN SERVICE, UNSERVICEABLE PARTS (as may be found in distributor inventories): First the obvious:

• The parts cannot enter service until they have been repaired, overhauled, inspected, etc.

• The parts are not in service, or in any operator’s rotable cycle or ownership.

Please, let me be clear and on record that it is my personal belief that any aircraft part in any condition should be given the protection previously discussed. But in the aftermarket I have discovered certain realities that have lead me to write this blog, and which mitigate such beliefs. The following are examples of such realities I’ve observed consistently at many distributor’s operations:

• Aftermarket distributors will frequently buy or be consigned lots of parts from airlines. Routinely, the reason is the airline is retiring a fleet, downsizing, in bankruptcy, or performing modifications (such as STC’s) and the superceded parts are now in your possession. Often the marketability of the parts are very low, reflective of the low purchase price for the lot. I’ve heard a general rule of thumb that if just 10% of the parts are sold, that a profit can be realized. The other 90% of the parts gather dust until being posted to the scrap roster.

• For as-removed or unserviceable parts, I’ve been shocked to open boxes just received from operators to see hardly a modicum of protection:

  • Unrestrained metal to metal contact

  • Electrical or fluid ports not capped

  • No ESD protection of ESD parts

  • Damage incurred in shipping due to improper packaging

  • Undeclared HAZMAT (Yep, I said it, and I meant it)

Now understand, I am genuinely, sincerely, not complaining or protesting these issues. I just wanted to illustrate these realities to be able to properly couch the following: For parts that are unserviceable, not in service, have a low probability of being sold, and that were received unprotected, is it practical to take the time and expense to protect them as we would serviceable parts?

It is universally understood that such lack of protection may contribute to higher overhaul or repair costs, if and when the part is sold, but that is a business decision. It would however, be a serious mis-characterization to look upon a firm with such unprotected parts and to conclude there is a concern with their quality system, there is not. Similarly, one should not assume that aftermarket firms have all or any of their unserviceable parts in unprotected states.

I’m glad to report that in my experience, firms with such parts who are accredited or have certified quality systems, that these parts are protected from the elements, and in secured areas with fire protection, so one could not rationally say that the parts are wholly unprotected.

Reasonable enough, make sense? I hope so...

 4/11/06

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

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