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Don’t you hate all those Latin terms that continue to linger in our language such as “pro Bono”, and “Quid-Pro-Quo” (isn’t that a fish delicacy in some parts? I’ll eat it if I don’t have to look at the eyes)? One that I must use with some regularity is “De Facto.” De facto is a Latin expression that means "in fact" or "in practice" but is not spelled out by law. Our industry’s current requirements for traceability are not clearly or overtly codified in any body of regulations, but one actuality remains indisputable; traceability has become de facto industry requirements.

A common recurring concept that I find myself routinely explaining to new persons (particularly those in sales and purchasing) is that the issue of airworthiness documentation is separate and distinct from trace documentation. For example, someone may ask,

The part and EASA Form 1 were pristine. The culprit? Gaps in the Traceability chain.

“But Royboy, it has an EASA Form 1 with it; it’s airworthy and ready to install, what’s the problem?”

As is my Modus Operandi, I smile, flutter my eyebrows, and launch into my well rehearsed ab initio speech. The fact is that many people assume a part with an airworthiness document (such as a FAA 8130-3 or EASA Form 1) settles all issues of traceability and documentation; that’s just non sequitor. Remember this, you can have a part with complete trace documents, but if it does not have airworthiness documents, the part is not ready for installation. On the other hand, you can have a part with airworthiness documents, but without complete traceability, most customers with robust Quality systems will reject the part. One is not good without the other, and must be treated as separate and distinct issues.

Just a quick review of what trace is. The definition of Traceability is: The ability via documentation to track aircraft parts, processes, and materials by lot, serial number or other means to the certificated source or manufacturer (ref ATA Specification 106 titled “Sources & Approved Parts Qualification Guidelines”, Chapter 1, Definitions).

Most companies accept trace to airlines or repair stations because, as the definition says, you’d be tracing it to a “Certificated Source”. Indeed these certificated sources have strict traceability requirements, so we accept their certificate as proof that they too obtained the parts from acceptable traceable sources. Think of trace as a successive and documented chain of custody. For new or factory new parts, the trace is to the Manufacturer, so that is easy. It’s not so easy when you deal with parts in the aftermarket. In this case, the part could have changed ownership several times, not to mention it’s condition. A thorough discussion of what traceability is, and what is acceptable is not the aim of this blog. I just hope you’ve established the separation of these issues in your business dealings.

By the way, I’ll have you know that this blog article is a pro-bono effort on my behalf.

4-09-08

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

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