Ac21 38

U.S.
Department
of Transportation
Federal Aviation
Administration
Suspected ‘Unapproved Parts’

Program Plan
Prepared by
The FAA Suspected ‘Unapproved Parts’ Task
Force
October 6, 1995
Table of Contents
Section Page
List of Acronyms ......................................................................................................................iv

Executive Summary..................................................................................................................vi
1.0 Introduction......................................................................................................................1-1
1.1 Overview of the SUPs Problem ..................................................................................1-2
1.2 Overview of the Proposed Program Plan ....................................................................1-5
1.3 Vision ........................................................................................................................1-10
1.4 Task Force Mission ...................................................................................................1-10
1.5 Task Force Charter....................................................................................................1-11
1.6 Task Force Composition ...........................................................................................1-12
1.7 Scope of the Task Force’s Work...............................................................................1-12
1.8 Task Force Methodology ..........................................................................................1-13
1.9 Organization of This Document ................................................................................1-14
2.0 Policy ...............................................................................................................................2-1
3.0 Terminology ....................................................................................................................3-1
4.0 SUPs Program Organization............................................................................................4-1
4.1 Technical Support Organizational Element.................................................................4-2
4.2 Data and Analysis Organizational Element.................................................................4-4
4.3 Policy, Guidance, and Training Organizational Element ............................................4-4
4.4 National SUPs Program Office Staffing......................................................................4-5
4.5 Regional/Directorate SUPs Coordinators and Local Offices ......................................4-6
5.0 Regulatory Issues.............................................................................................................5-1
5.1 Reporting SUPs...........................................................................................................5-1
5.2 Records........................................................................................................................5-3
6.0 Technical Issues...............................................................................................................6-1
6.1 Responsibility for Parts Installation ............................................................................6-1
6.2 Limitations on Parts Fabrication for Repairs...............................................................6-3
6.3 Parts Distributors and Brokers ....................................................................................6-4
6.4 SUPs Investigations and Penalties ..............................................................................6-6
Investigation Process ..................................................................................................6-6
Seizure of Parts ...........................................................................................................6-8
Civil Penalties .............................................................................................................6-9
6.5 Instructions for Continued Airworthiness ...................................................................6-9
Table of Contents ii
Table of Contents, Continued
Section Page
6.6 Use of Joint Aviation Authorities (JAA) Form 1 and FAA Form 8130-3.................6-10
6.7 Required Documentation...........................................................................................6-11
6.8 Part Criticality ...........................................................................................................6-12
6.9 Surplus Military Parts................................................................................................6-14
6.10 SUPs Case Files/Records ........................................................................................6-17
6.11 Salvageable and Scrap Parts....................................................................................6-18
6.12 Removal of “Unapproved Parts” From the System.................................................6-20
7.0 Information Systems Strategy..........................................................................................7-1
8.0 Relationships With Law Enforcement Agencies .............................................................8-1
9.0 Training............................................................................................................................9-1
10.0 Implementation ............................................................................................................10-1
10.1 Transition Issues......................................................................................................10-1
10.2 Implementing the Principal Recommendations.......................................................10-3
APPENDIX A — FAA SUPs Task Force Members

APPENDIX B — Selected Recent Initiatives – Suspected “Unapproved Parts”
APPENDIX C — Related ACs, Orders, and Memoranda
APPENDIX D — SUPs Investigation Procedures
APPENDIX E — Parts Reporting System Database
APPENDIX F — Parts Receiving Policy
APPENDIX G — List of Recommendations
APPENDIX H — Task Force Charter Items Program Plan Cross-Reference Guide
Table of Contents iii

List of Acronyms
AC Advisory Circular
ACS Civil Aviation Security
ACO Aircraft Certification Office
AD Airworthiness Directive
AFS Flight Standards Service
AGC Office of the Chief Counsel
AIR Aircraft Certification Service
AIR-DU Aerospace Industry Regulation of Distributors
ARAC Aviation Rulemaking Advisory Committee
ASI Aviation Safety Inspector
ATA Air Transport Association of America
AVR Regulation and Certification Organization
BBS Bulletin Board System
CFR Code of Federal Regulations
COC Certificate of Conformance
DBA Database Administrator
DCIS Defense Criminal Investigative Service
DoD Department of Defense
DOT/OIG Department of Transportation Office of the Inspector General
DRMO Defense Reutilization and Marketing Office
EIS Enforcement Information System
FAA Federal Aviation Administration
FAR Federal Aviation Regulations
FBI Federal Bureau of Investigation
List of Acronyms iv
List of Acronyms, Continued
FSCAP Flight Safety Critical Aircraft Part
FOIA Freedom of Information Act
FSDO Flight Standards District Office
GAO General Accounting Office
IFCA Instructions for Continued Airworthiness
IPC Illustrated Parts Catalog
IFO International Field Office
IVT Interactive video teleconferencing
JAA Joint Aviation Authorities
JAR Joint Aviation Requirements
MIDO Manufacturing Inspection District Office
MIS Management Information System
NPRM Notice of Proposed Rulemaking
PAAT Parts Approval Action Team
PAH Production Approval Holders
PAT Process Action Team
PMA Parts Manufacturer Approval
PRS Parts Reporting System
PTRS Program Tracking and Reporting System
SFAR Special Federal Aviation Regulation
STC Supplemental Type Certificate
SUP Suspected “Unapproved Part”
TC Type Certificate
TSO Technical Standard Order
USCS U.S. Customs Service
List of Acronyms v
Executive Summary
The Federal Aviation Administration (FAA) convened a Task Force to conduct
a thorough review of the Suspected “Unapproved Parts” (SUPs) issue and to
devise a comprehensive program plan to more aggressively address SUPs. The
purpose of the review was to build on past initiatives and to take the next
logical step to making the SUPs program more effective.
The Task Force’s review also took into account the concerns that had been
expressed both within Congress and the Department of Transportation’s Office
of the Inspector General regarding FAA SUPs policy and enforcement being
inconsistent and insufficient.
An understanding of the complicated nature of the issues and the potential
safety impact of SUPs led the FAA Regulation and Certification Organization
to set forth a vision for both the Task Force and the SUPs program. The vision
is:
To promote the highest level of aviation safety by
eliminating the potential safety risk posed by the entry of
“unapproved parts” in the U.S. aviation community.
The Task Force was instructed to develop a comprehensive plan to achieve this
vision through a program that could be implemented easily and would include
an organizational structure capable of providing clear and consistent guidance,
enhanced training, more timely SUPs case processing, access to usable
management information system data, and one that would also promote
working closely with other law enforcement agencies in eliminating SUPs.
Task Force members were drawn from the FAA’s Aircraft Certification
Service, Flight Standards Service, the Office of Civil Aviation Security
Operations, and the Office of the Chief Counsel. Task Force members were
Subject Matter Experts in the fields of maintenance, engineering,
manufacturing inspection, law enforcement, or administrative law—all
disciplines crucial to understanding the SUPs issue. Additionally, many Task
Force members represented a field perspective as opposed to a headquarters
view since such members would have had the most recent experience with
SUPs case investigations.
The Task Force’s methodology included reviewing SUPs initiatives taken over
the past 5 years, including educational seminars, guidance material, and the
current prototype database being used to track SUPs cases. In particular, the
Task Force focused on existing policy guidance and advisory material, and also
on obtaining a clear understanding of existing pitfalls in the current SUPs
Executive Summary vi
program. Task Force members applied their collective knowledge and
understanding to identify areas for program improvement and enhancement.
As a result, the Task Force proposed a series of recommendations to be
implemented in four stages: immediate action, transition, operational phase,
and sunset, in order to start immediately impacting the problems that were
diagnosed without losing sight of longer-range solutions.
The Task Force recommends the following:
• Clarify the FAA’s Policy on SUPs
• Standardize the Use of SUPs Terminology
• Establish an FAA National SUPs Program Office
• Establish a New Parts Reporting Information System
• Improve Cooperation With Law Enforcement Agencies
• Target Receiving Inspection Procedures for Surveillance and

Enforcement
• Clarify the Responsibility of Persons Performing Maintenance
• Expedite Rulemaking
• Improve SUPs Investigation Training for the FAA Workforce
• Define Procedures to Dispose of Scrap Parts
• Define Procedures to Remove “Unapproved Parts” from

Inventories and Aircraft.
These items are elaborated upon in Section 1.2, “Overview of the Proposed
Program Plan.”
Executive Summary vii

1.0 Introduction
The U.S. Federal Aviation Regulations include a framework of rules governing
the design, manufacture, and use of aviation products and parts. These
regulations, along with Federal Aviation Administration (FAA) surveillance,
inspection, and enforcement activities, are a key element in maintaining the
historically high level of safety in U.S. air transportation.
As part of its activities, the FAA periodically reviews and updates the
regulations, and issues policy guidance to its inspectors and advisory
information to the industry to achieve compliance with the regulations.
Particularly within the past 5 years, the FAA has intensified its efforts to
educate inspectors and the public regarding the potential safety threat posed by
aeronautical parts that do not meet applicable design, manufacture, and
maintenance requirements. The FAA encourages the reporting of parts that
may not meet applicable standards and, in 1993, established the Suspected
Unapproved Part (SUP) Program to coordinate FAA efforts to minimize safety
risks posed by the entry of “unapproved” aircraft parts into the U.S. aviation
inventory and their installation on aircraft.
Nevertheless, there is substantial concern within Congress, the Department of
Transportation Office of the Inspector General (DOT/OIG), the public, and the
FAA itself that the FAA’s approach to regulating and monitoring aviation parts
and enforcing the regulations is not sufficiently comprehensive. The
underlying concern is whether all parts installed on aircraft during preventive
maintenance, maintenance, and alteration meet all FAA requirements.
As a result of these concerns, the FAA Regulation and Certification
Organization (AVR) established a SUPs Task Force to thoroughly review the
issue of SUPs, evaluate the FAA’s related on-going efforts, and to devise a
comprehensive Program Plan to eliminate any potential risk to aviation safety.
The Task Force comprised mostly field-based personnel with technical
expertise in aircraft and engine design, manufacturing, and maintenance, as
well as experience in SUPs investigations. The Task Force was given 60 days
to complete its review and to develop recommendations for a comprehensive
SUPs Program. This document presents the results of the Task Force’s work.
1.0 Introduction 1–1

1.1 Overview of the SUPs Problem
A comprehensive network of controls governs the design and manufacture of
parts. Other checks and inspections occur between the manufacture and the
end use of the aeronautical part by the maintenance technician who purchases
the part or selects it from a stockroom for installation on an aircraft, aircraft
engine, propeller, or component. Nevertheless, parts that are not eligible for
installation do circumvent these controls, whether by inadvertent action or
deliberate action. This section describes existing controls and some ways in
which parts not eligible for installation can circumvent these safeguards and
enter the aviation system.
There are a number of acceptable methods for aeronautical parts to be designed
and produced. Some of these methods require specific FAA approvals. This is
usually the case for major aircraft products, such as airframes, engines, and
propellers, as well as for key components or parts that could significantly affect
the operation of an aircraft. The FAA grants approvals only on the basis of
stringent review of design criteria, facilities, processes, and quality control
systems. FAA Production Approval Holders (PAHs) are subject to continual
FAA surveillance and inspection to verify their compliance with the Federal
Aviation Regulations and the conditions of their approvals.
However, there are a number of sources of acceptable parts that are not
produced under specific FAA approvals. For example, it is permissible for the
owner or operator of an aircraft to produce parts for maintaining or altering that
person’s own product. Manufacturers of products such as airframes and
engines often specify that it is acceptable to use “standard parts,” such as nuts
and bolts, for production and maintenance of those products. Standard parts
production is not specifically monitored by the FAA, but must conform to
specified industry-accepted criteria. Standard parts can be tested for
conformity and may be used in aeronautical products only when specified in
the type design. Other parts not formally approved by the FAA that are
acceptable if used in the proper application are parts “fabricated” by
maintenance personnel in the course of their repair work for the purpose of
returning a product (aircraft, engine, or propeller) to service. Such parts still
are required to meet applicable design criteria.
In addition to regulating the design and manufacture of aeronautical parts, the
FAA regulates the individuals and organizations that use parts. Federal
Aviation Regulations address training and certification of mechanics and
repairmen; certification of repair stations; and certification of air carriers, all of
which may perform maintenance. Regulations specify how preventive
maintenance, maintenance, and/or alterations must be performed and
documented. The regulations also prescribe specific quality control and
inspection procedures for certificate holders such as air carriers and repair
1–2 1.0 Introduction

stations, which include procedures to carefully inspect incoming materials and
parts for authenticity and conformity with applicable standards.
Thus, a series of controls exists at the source of the parts — the manufacturer
— and at the final destination, i.e., the organization and mechanic using the
parts for maintenance and/or alterations. These controls are designed to ensure
that parts that are produced and used meet applicable design requirements, are
eligible for installation, and are appropriate for a given situation.
Quality and reliability programs are an additional safeguard in the system.
Aircraft, engines, propellers, and components are designed to extremely high
standards of safety, with high levels of reliability. Additionally, there are
redundant systems so that the potential for the failure of any individual part to
endanger the operation of an aircraft is minimized.
Nevertheless, there are numerous sources of parts that do not meet applicable
requirements but that do enter the aviation system. Collectively, these parts are
colloquially referred to as “unapproved parts” and, similarly, “approved parts”
is the colloquial term for parts that do meet all applicable requirements. The
commonly used term “approved part” is not synonymous with “a part that has
received a formal FAA approval.” The terms “approved parts” and
“unapproved parts” as used in this report are not legal definitions, but simple a
reflection of the need to have a broad term that identifies parts that should, or
should not, be installed on an aircraft. In this report, parts that should be used
on an aircraft (i.e., “approved parts”) are described as parts “acceptable for
installation” or “eligible for installation.” (These two expressions have the
same meaning in this report.)
Counterfeit parts, a type of “unapproved part,” may be new parts that are
deliberately misrepresented as designed and produced under an approved
system or other acceptable method even though they were not so designed and
produced. Counterfeit parts may also be used parts that, even though they were
produced under an approved system, have reached a design life limit or have
been damaged beyond possible repair for aviation standards, but are altered and
deliberately misrepresented as acceptable, with the intent to mislead or defraud.
If an “unapproved part” is not salvageable, i.e., thought to be worth saving

under controlled conditions for potential future repair, it is “scrap,” and should
be disposed of in such a way that it cannot be returned to aviation service. If a
part is salvageable, it should be documented and controlled so that it is not
returned to aviation service until it meets all requirements. However, both
salvageable and scrap parts are sometimes misrepresented as having useful
time left or as having been repaired in accordance with regulations.

Other examples of parts that are not eligible for use, or “unapproved parts,” as
defined by the Task Force, are parts rejected during the production process
because of defects; parts for which required documentation has been lost; parts
that have been improperly maintained; and parts from military aircraft that have
not been shown to comply with FAA requirements. None of these should be
installed in an aircraft.
“Unapproved parts” also occur when a supplier that produces parts for an
approved manufacturer directly ships to end users without the approved
manufacturer’s authorization or a separate, applicable Parts Manufacturer
Approval (PMA). An example of this is “production overrun” parts. Because
these parts are not authorized by the PAH, one can not assume that they have
met all the requirements of the approval holder’s required quality control
process; therefore, they are in contravention of the regulations and are not
authorized for use on aeronautical products.
Some “unapproved parts” may be made acceptable for use by undergoing
certain testing, inspection, or repair, or if the part’s documentation can be
recovered. Other parts, due to their condition or origin, cannot be rehabilitated
for aviation use.
To help guard against intrusion of parts that do not meet applicable design,
manufacture, or maintenance standards, the FAA has established a program for
the reporting and investigation of suspected “unapproved parts” (FAA Order
8120.10, Suspected Unapproved Part Program, September 28, 1993). The
program supplements other mechanisms for the industry to report problems
found in the field to the FAA, and for the FAA to issue alerts or Airworthiness
Directives (ADs), which are mandatory inspection or maintenance
requirements, to the industry, as well as informational Handbook Bulletins for
the FAA field workforce and Advisory Circulars (ACs) for industry.
As part of its assessment of the SUPs issue, the FAA convened a meeting in
Seattle, Washington, of 47 representatives of various FAA organizations in
April 1995. At that meeting, potential enhancements to the FAA SUPs
program were considered. The meeting identified areas for improvement,
including regulatory changes; the need for a centralized organizational and
management structure; clearer lines of responsibility and objectives for the
SUPs program; improved investigation procedures, processes, training, data
management, and communications between entities involved in SUPs
surveillance and enforcement.
Building on the Seattle meeting’s work, the Task Force reviewed the feasibility
of the proposals and methodologies for putting the proposals into place. They
evaluated where enhancements and new initiatives might be called for, either in
the existing SUPs program or in the system at large. The Task Force was not
confined to working within the existing SUPs program, but considered it as part
of the overall current SUPs picture along with recent SUPs-related initiatives.
Such initiatives include publication of AC 21-29, Detecting and Reporting

Unapproved Parts (revised July 16, 1992), and AC 21-38, Disposition of
Unsalvageable Aircraft Parts and Materials, (July 5, 1994); public education
programs, such as a series of approximately 150 “Approved Parts” Seminars
and a widely-distributed videotape on the subject; a “hotline” to facilitate
reporting SUPs to the FAA by the aviation community; the Parts Approval
Action Team (PAAT), formed to resolve problems associated with parts that
lack proper documentation associated with FAA PMAs; and regulatory projects
that would enhance parts recordkeeping requirements and enhance the FAA’s
ability to pursue SUPs investigations. (Appendix B is a compilation of such
efforts by Flight Standards Service (AFS), Aircraft Certification Service (AIR),
and special teams such as PAAT; and Appendix C contains the Task Force’s
brief review of existing and draft SUPs-related ACs, Orders, and Memoranda.)
1.2 Overview of the Proposed Program Plan

The Task Force has developed a Proposed Program Plan that identifies a
number of areas where FAA SUPs actions can be enhanced to further “choke
off” points at which “unapproved parts” enter the aviation system. The
proposed program plan addresses transitional, phase in, operational, and sunset
phases. Key elements of the plan include the following:
• Clarify the FAA’s Policy on SUPs

A policy statement should be issued, clearly stating that the FAA is
committed to more aggressive and consistent surveillance and enforcement,
adequate guidance to its employees, and a cooperative working relationship
with other government agencies. The Task Force was concerned by the
perception that FAA policy with regard to SUPs may be inconsistent or
insufficiently comprehensive, and believes that a message should be issued
immediately to FAA management, field workforce, and the public affirming
the FAA’s commitment to SUPs surveillance, investigation, and
enforcement as a means of precluding “unapproved parts” from posing a
potential safety threat.
• Standardize the Use of SUPs Terminology

Accept the proposed definitions of key terms by incorporating them into
internal guidance and external advisory material, as well as by establishing
a consistent progression of logic tests by which a part would be found to be
“approved” or “unapproved,” embracing the colloquial understanding of
those words to mean “acceptable for installation” or “not acceptable for
installation” or the equivalent, “eligible for installation” or “ineligible for
installation.” The proposed definition would expand the FAA’s current

concept of what constitutes an “unapproved part” and therefore could lead
to an increase in the number of SUPs reports.
• Establish an FAA National SUPs Program Office

Establish an FAA National SUPs Program Office to encompass SUPs
expertise and processes currently residing in two separate organizational
entities within the FAA, i.e., AIR and AFS. Such a move would ensure a
structure to assist with the development and dissemination of consistent
policy and procedures for both design/manufacturing and maintenance,
especially in the areas of inspector training for SUPs investigation. This
high-level, high-visibility office would report to AVR-2 and provide FAA
personnel as well as industry and law enforcement agencies with a single
source for technical information — a “single voice” and centralized point of
contact on SUPs policy and procedures. Furthermore, the office, which
would focus exclusively on SUPs, would be easily accessed and would
emphasize rapid response to facilitate the SUPs work of field personnel. It
is envisioned that these functions would eventually be taken over by
Regional and Directorate SUPs Coordinators as soon as proposed policy,
guidance, and procedures have become institutionalized in the FAA.
• Establish a New Parts Reporting Information System

The office would also develop and manage an enhanced information
system, the “Parts Reporting System” (PRS), which would be designed to
provide a wide range of information for investigators and FAA managers.
This system would receive reports generated from a range of sources,
including FAA personnel, law enforcement agencies, and the aviation
industry, which would continue to be encouraged, and eventually required,
to report SUPs to the FAA. The PRS would also assist FAA investigators
by providing them with a variety of information, both current and historical,
and would assist FAA management in monitoring trends and allocating
resources. The system would be designed to be linked to other FAA
information systems to provide users with rapid access to such information
as certificate holders, policy and guidance material, and other enforcement
information. The system would distinguish among different types of
“unapproved parts” to help the FAA respond to problems in the most
effective way.
• Improve Cooperation With Law Enforcement Agencies

Standard Operating Procedures should be developed to expedite how the
FAA works with law enforcement agencies that conduct criminal
investigations related to SUPs, because the FAA’s emphasis is on how a
SUP affects safety. To that end, the Task Force recommends that the FAA
disseminate its SUPs case reports simultaneously to the DOT/OIG and to all
interested Federal law enforcement agencies for whatever action they deem

appropriate. The Task Force also recommends that designated “points of
contact” be established in both FAA and law enforcement agencies to
enhance working relationships and increase the flow of information
between the FAA and the law enforcement agencies, facilitating both
criminal investigations and the FAA’s safety responsibilities. The Task
Force held several highly productive meetings with representatives of FAA
Office of Civil Aviation Security (FAA/ACS), the DOT/OIG, the
Department of Justice, the Federal Bureau of Investigation (FBI), the
Defense Criminal Investigative Service (DCIS), and the U.S. Customs
Service (USCS) to discuss how to improve FAA SUPs investigative
procedures and to enhance communications with such organizations and
agencies, which may be conducting parallel investigations. Standard
operating procedures between the FAA and law enforcement agencies on
SUPs matters should be formalized by the new SUPs Program Office as
soon as practicable. These procedures should address how each
organization with interest in a SUPs case would keep the other informed
and how each would determine when to request the involvement of the
others.
• Target Receiving Inspection Procedures for Surveillance and

Enforcement
A special “campaign” of surveillance and enforcement should be outlined

in the National Work Program Guidelines for fiscal year 1996, which would
target airlines’ and repair stations’ parts-receiving and inspection systems.
Similar emphasis should be included in setting work priorities in
surveillance of PAHs. Such an effort would verify that these certificate
holders have procedures in place that permit them to adequately inspect
incoming parts and to screen out “unapproved parts” to prevent their use in
aircraft production, maintenance, and alteration.
• Clarify the Responsibility of Persons Performing Maintenance

Ensure that all FAA inspectors inform certificate holders that aviation
maintenance personnel in the holders respective organizations must
understand their regulatory responsibility to perform work so that the
aircraft or aircraft products on which maintenance is performed are restored
to a state at least equal to their original or properly altered condition. This
means that the parts or materials used must be consistent with this
requirement, as mandated in 14 CFR Part 43.

• Expedite Rulemaking
The FAA should initiate a new rule and expedite the two pending rules that
impact SUPs. The recommended rule would mandate that all persons,
including repair stations, air carriers, mechanics, and others must report
SUPs to the FAA. Currently, SUPs reporting is on a voluntary basis. A
rulemaking project currently under review would upgrade maintenance
recordkeeping requirements and emphasize that persons receiving or
transferring aeronautical products must transfer the corresponding
documentation for those parts. A second rulemaking project currently
under review would prohibit any person from making a fraudulent or
intentionally false statement in any record used to represent the
acceptability of an aircraft product, part, or material used in civil aircraft.
In addition, the Task Force supports a current initiative within the aviation
industry to develop a program under which distributors and dealers would
apply for voluntary accreditation based on independently verified quality
control systems.
• Improve SUPs Investigation Training for the FAA Workforce

Provide the FAA workforce with interim, formal, and reinforcement
training to enhance FAA SUPs investigative actions. This training should
emphasize the cross-disciplinary nature of SUPs investigations by including
both AIR and AFS personnel, and including input from ACS, AGC, and
law enforcement agencies.
• Define Procedures to Dispose of Scrap Parts

The FAA should review measures necessary to ensure that scrap parts are
destroyed so that they cannot be returned to aviation use. This may include
rulemaking requiring owners of aviation parts who determine that those
parts are scrap to destroy the parts prior to disposing of them.
• Define Procedures to Remove “Unapproved Parts” from Inventories and

Aircraft
The FAA and the industry should have as a goal the removal of all
“unapproved parts” from aircraft as soon as practicable, in accordance with
a process similar to the Minimum Equipment List (MEL) procedures for
treatment of inoperative equipment. This will ensure that safety standards
are maintained without causing unwarranted grounding of aircraft.
“Unapproved parts” in inventories should be removed as well, particularly
when they become candidates for installation.

Pending implementation of the Proposed Program Plan, the FAA Task Force
recommends that the FAA take immediate steps to reduce the potential impact
of “unapproved parts,” consistent with the initiatives just described. These
steps are:
1. Initiate a “special emphasis campaign” for surveillance and
enforcement — by creating as a special emphasis item for fiscal
year 1996, the surveillance of receiving inspection control systems of
airlines and repair stations, as well as procedures for supplier
surveillance, and maintain this special emphasis to ensure that changes
are made to any system that fails to ensure that only parts eligible for
installation are installed. Voluntary actions should be encouraged, but
the FAA should mandate changes to certificate holders’ required
procedures or take swift enforcement action, as appropriate.
2. Clarify parts usage — by immediately disseminating to FAA inspectors
and the industry information regarding how maintenance personnel can
comply, in terms of parts usage, with their responsibility to perform
their work such that the aircraft or product is at least equal to its original
or properly altered condition. That is, they must use properly
documented “approved parts,” or make a determination that the part is
eligible for installation using acceptable procedures. Also disseminate
information to the FAA field workforce and the industry regarding the
responsibilities of PAHs with respect to monitoring their suppliers and
ensuring quality control and control over direct shipping and production
overruns.
3. Clarify the FAA’s expectation for Quality Control Systems — by
communicating to the industry and to FAA inspectors that the FAA
expects the quality control systems already required of airlines and
repair stations that are certificate holders under 14 CFR Parts 121, 135,
129, and 145 to ensure that only parts suitable for installation are
purchased and installed on aircraft or other products. Similarly, PAHs
should be reminded of their responsibilities with respect to their
suppliers under 14 CFR Part 21.
4. Develop a sample procedure for receiving inspections — The FAA
should develop a sample parts receiving/incoming inspection procedure
with emphasis on screening incoming parts, which inspectors could use
in evaluating such systems.

The Task Force foresees the following four principal phases to implementation
of the proposed new SUPs program:
Immediate Action: Issue policy statement, appoint interim staff, special
emphasis campaign for surveillance and enforcement, provide technical
assistance to the field and industry, and initiate development of standard
operating procedures with law enforcement.
Transition to National SUPs Program Office: Staffing gradually
accomplished, information system under development; technical support,
policy, guidance and training functions underway.
Operational Phase: National SUPs Program Office fully operational, fully
staffed; information system completed; all organizational elements fully
functional.
Sunset: National SUPs Program Office phased out after SUPs functions
firmly institutionalized at regional, directorate, and local levels; effective
working relationships with law enforcement agencies established, certain
functions continued under a different structure.
1.3 Vision
The Task Force’s objective was to devise a program plan to enable the FAA to
meet its “Vision” for the SUPs program, which is “To promote the highest level
of aviation safety by eliminating the potential safety risk posed by the entry of
‘unapproved parts’ in the U.S. aviation community.”
1.4 Task Force Mission

To fulfill the vision, the Task Force was assigned the mission of developing a
plan that provides for:
• An effectively managed and designed organization
• Pertinent regulations
• Improved processes
• A comprehensive data collection methodology
• Relevant training
• Supportive relationships.

The Task Force determined that to accomplish this mission, the FAA SUPs
program should ensure that “unapproved parts” are prevented from entering the
system, or, if they already have infiltrated the inventories, ensure that they are
prevented from being installed on aircraft in the future and are purged from the
system, including removal from inventories and aircraft, as soon as practicable.
The Task Force does not advocate grounding the air carrier or general aviation
fleets unnecessarily, nor does the Task Force believe that the FAA has the
authority to order removal of any parts from aircraft or inventories. However,
the Task Force does believe that the FAA can suspend or revoke an aircraft’s
airworthiness certificate under certain conditions, and in some cases,
“unapproved parts” may warrant such action. It can similarly take enforcement
action against an air carrier or repair station that does not have an adequate
system for segregating “approved parts” from “unapproved parts” so that the
latter cannot inadvertently be put on aircraft.
Section 6.12 sets forth a proposed methodology for eliminating “unapproved
parts” from the aviation system in a reasonable manner based on the criticality
of the parts and previously proven methods of dealing with inoperative
equipment on board aircraft.
1.5 Task Force Charter

The Task Force’s Charter specifies the group’s tasks:
• To define a uniform system of terminology to be used by all FAA

personnel when dealing with SUPs.
• To develop organizational processes or structure that support

effective surveillance and enforcement of SUPs.
• To suggest rulemaking or policy guidance that would assist in the

surveillance and enforcement process.
• To identify significant technical issues that require resolution which

are currently impacting SUPs.
• To define roles, responsibilities, and working relationships with

other law enforcement.
• To assess data and information needs to support SUPs processes.
• To supplement the current training program with SUPs training for

AIR and AFS inspectors.
• To prioritize all recommendations according to their impact on

reducing the safety impact of SUPs.

1.6 Task Force Composition
The Task Force chairman, who is the FAA Eastern Region Flight Standards
Division Manager, has extensive experience in both FAA management and as
an operations inspector. He also has prior aviation operations and law
enforcement experience. Task Force members were selected from principal
FAA disciplines with SUPs-related duties, and represented two services within
AVR: AFS, responsible for surveillance and inspection related to preventive
maintenance, maintenance, rebuilding and alteration; and AIR, responsible for
surveillance and inspection related to design and production. In addition, the
Task Force members included representatives of the Office of the Chief
Counsel (AGC) and ACS, who brought expertise in administrative law and law
enforcement. Most of the Task Force members also had extensive previous
experience in industry, including airline maintenance and aircraft and engine
design and manufacture. To ensure that policy and guidance took into account
the needs of field inspectors who had the most recent SUPs case experience
and who are responsible for regulatory implementation, a significant number of
team members were from field facilities.
The members, listed in Appendix A, currently work in FAA offices responsible
for overseeing certification of aircraft and engine design and manufacture,
including large transport category airplanes and jet engines; airworthiness and
maintenance of aircraft and engines; continued airworthiness programs; and
administrative law and related enforcement issues.
1.7 Scope of the Task Force’s Work

The Task Force addressed many aspects of the SUPs problem, including how
SUPs affect various segments of the industry such as airlines and general
aviation, sources of “unapproved parts,” how mechanics and FAA field
inspectors currently handle many types of “real world” situations and how they
might react to various types of new measures, and how FAA safety duties
relate to law enforcement agencies’ criminal investigations. SUPs issues
include complex technical issues related to product design, manufacture,
maintenance, and documentation. SUPs also involve regulatory and legal
issues.
The Task Force placed primary emphasis on issues related to air carrier aircraft
and maintenance because this is the area of concern to the majority of the
traveling public. However, issues related to 14 CFR Parts 21, 43, and 91 also
affect the general aviation and air taxi segments of the aviation industry, and
the Task Force’s proposals would address these areas as well.

The management information system proposed by the Task Force would help
provide the needed information to understand the problem and to measure the
effectiveness of the SUPs Program actions. Since adequate historical data do
not exist at this time, the Task Force could not, in this short time period,
attempt to gauge the size of the SUPs problem. The Task Force believes that
the FAA should have a more quantitative understanding of the size of the
“unapproved parts” issue, to determine the portion of resources to be allocated.
One of the principal benefits of the proposed PRS will be the collection and
analysis of information that would help the FAA, industry, and law
enforcement officials to better understand the size and characteristics of all
types of “unapproved parts” problems. This would help the FAA to develop
remedies for problems, set priorities, and measure how effective the remedies
are.
1.8 Task Force Methodology

The Task Force first met on August 7, 1995, and adopted its proposed charter
as well as identified the critical issues to be addressed.
The Task Force reviewed documentation regarding FAA activities related to
SUPs. This included regulations, FAA directives, ACs, and draft copies of
additional regulatory and guidance material currently being developed by the
FAA and its Aviation Rulemaking Advisory Committee (ARAC).
The Task Force then studied current efforts and the pitfalls and key problems
that have surfaced in those efforts. The Task Force held extensive discussions
with representatives of the law enforcement agencies most prominently
involved in “unapproved parts” investigations, i.e., FAA ACS, the DOT/OIG,
the Department of Justice, the FBI, the DCIS, and the USCS. The Task Force
also received briefings from DOT/OIG audit personnel, and from FAA training
specialists and personnel working with the current SUPs prototype database.
The Task Force members then used their collective experience in analyzing and
understanding critical issues in evaluating the potential impact of a range of
possible solutions. The Task Force’s analysis included evaluation of various
program models in the context of the Task Force members’ experience as
Subject Matter Experts. The Task Force proceeded on an issue by issue basis,
considering potential responses of various types, e.g., regulatory, guidance,
training, or process. The Task Force then tested the potential effect of these
possible responses in terms of actual and hypothetical “unapproved parts”
cases. The Task Force sought solutions that would provide creative approaches
for the short term and the long term.

1.9 Organization of This Document
This document presents the results of the Task Force’s deliberations, discusses
its conclusions, and sets forth the group’s recommendations. The document is
organized as follows: Section 1.0 introduces the SUPs issue, and provides an
overview of the recommended program plan, the Task Force vision, mission,
charter, and composition, the scope of the Task Force’s work, and its
methodology; Section 2.0 addresses the issue of standardized SUPs policy;
Section 3.0 addresses issues associated with the need for standard terminology;
Section 4.0 describes the proposed FAA National SUPs Program Office;
Section 5.0 addresses regulatory issues; Section 6.0 addresses a wide range of
related technical issues; Section 7.0 describes the proposed PRS database;
Section 8.0 addresses relationships with law enforcement agencies; Section 9.0
addresses training requirements; and Section 10.0 presents the Task Force’s
suggestions for implementing the plan. A series of appendixes contain
additional details regarding the Task Force and the proposed program plan.

2.0 Policy
Issue: FAA policy should reflect a commitment to eradicating SUPs to
eliminate any potential safety threat.
Recommendation: The FAA should issue a policy statement reaffirming a
clear FAA commitment to eliminating “unapproved parts” from the aviation
system.
Recommendation: Add a “required item” to the AFS National Work Program
(National Program Guidelines) for SUPs surveillance and make SUPs
surveillance a “special emphasis” item for the manufacturing inspection
program. This addition should be made to the fiscal year 1997 program,
although AFS and AIR should direct that SUPs receive equivalent priority in
the fiscal year 1996 programs.
Discussion: SUPs is only one of many priority issues facing FAA policy
makers and inspectors in the field. The Task Force noted that, over time,
differing views have developed regarding the priority to be assigned to SUPs
and how SUPs cases fit in with other competing inspector duties. The matter is
further complicated by the interdisciplinary nature of SUPs, as discussed in
Section 4.0.
The issue crosses the boundary of two services within the Regulation and
Certification Organization, and hence is not the sole responsibility of either of
the services. The Task Force believes that a firm policy statement reaffirming
SUPs as part of AFS inspectors’ mandated work programs and AIR inspectors’
objectives would eliminate confusion as to the priority given to SUPs
surveillance, inspection, and investigation.
Law enforcement representatives with whom the Task Force met requested that
the FAA speak with “one voice,” i.e., that FAA policy and guidance be
standardized and consistent. The representatives requested that the FAA clarify
for its workforce that the FAA’s top management considers the potential safety
risk of SUPs an important issue and that cases should be vigorously pursued.
The Task Force agreed that FAA policy with respect to detection and
enforcement of “unapproved parts” cases is not consistently perceived within
the FAA. The Task Force determined that the first step toward developing an
effective SUPs program would be to issue a clear policy directive from the
Administrator. The Task Force developed a draft policy statement. A key ele-
ment of the policy is that the FAA would enforce current regulations, as well as
implement regulatory changes to strengthen the FAA’s response to the
“unapproved parts” problems.
2.0 Policy 2–1

POLICY STATEMENT
“UNAPPROVED PARTS”
It is the policy of the Federal Aviation Administration to

eliminate the potential safety risk posed by “unapproved
parts” in the U.S. aviation system by:
• Conducting aggressive and consistent

surveillance for suspected “unapproved
parts.”
• Investigating thoroughly and timely when

suspected “unapproved parts” are de tected or
reported.
• Responding with rapid and uniform

enforcement when “unapproved parts” are
found.
• Providing a sound regulatory basis and

associated guidance for FAA personnel and
the public.
• Coordinating FAA efforts with law

enforcement agencies engaged in the
prosecution of criminal activity.
In support of this policy, the Task Force believes that the AFS National
Program Guidelines, which establish the baseline of surveillance priorities for
inspectors, should specifically reflect SUPs as a special emphasis or “required
item.” The Task Force also believes that SUPs surveillance should be a special
emphasis item for Manufacturing Inspection District Office (MIDO) inspectors.
Appropriate workload tracking codes should be reviewed, and expanded or
changed if necessary, within existing programs to adequately identify SUPs
work for both the MIDO and FSDO field workforce.
2–2 2.0 Policy

3.0 Terminology
Issue: The concept of “approved parts” versus “unapproved parts” is not well
understood because there is no single, comprehensive definition of an “ap-
proved part” or other key terms used in the discussion of SUPs issues.
Recommendation: The FAA should adopt definitions of the following main
terms used with regard to parts eligible for installation in type certificated
products to ensure that use of the terminology in government and the public is
consistent and promotes a common understanding and use of the concepts:
“approved part;” “unapproved part;” standard part; and counterfeit part. Such
definitions are intended for the purpose of this Proposed Program Plan as well
as for the purpose of future respective guidance documents and for colloquial
use, as opposed to legal definitions. Hence, the Task Force does not
recommend regulatory changes to adopt the definitions.
Discussion: The regulations do not explicitly state in a single place when a
part is acceptable, or eligible, for installation in terms of its manufacture,
documentation, and maintenance status; however, all of these factors — i.e.,
the part’s origin (be it through an FAA-approval or other acceptable
manufacture), its current condition in terms of maintenance, and the
documentation for its origin and maintenance — are addressed separately in the
regulations and are related to a part’s acceptability, or eligibility, for
installation.
Replacement or modification parts that are acceptable for installation — or
eligible for installation — currently are addressed through two main
perspectives in 14 CFR, the Federal Aviation Regulations — manufacture of
parts and their use in preventive maintenance, maintenance, rebuilding, or
alteration. The regulations specify how parts may be produced pursuant to
FAA approvals, and how parts may be produced outside of the FAA approval
process but in a manner that is nevertheless acceptable to the FAA. The
regulations also address how aircraft should be maintained and how such
maintenance should be documented.
Title 14 CFR Part 21, Certification Procedures for Products and Parts, is the
key regulation addressing requirements for producing modification or replace-
ment parts for sale for installation on aircraft, aircraft engines, or propellers
(these items are “type certificated products”). Section 21.303 states that, with
certain specified exceptions, “No person may produce a modification or re-
placement part for sale for installation on a type certificated product unless it is
produced pursuant to a Parts Manufacturer Approval.”
3.0 Terminology 3–1

The exceptions to this requirement are the following:
1. Parts produced under a type or production certificate.
2. Parts produced by an owner or operator for maintaining or altering
his own product.
3. Parts produced under an FAA Technical Standard Order.
4. Standard parts (such as bolts and nuts) conforming to established
industry or U.S. specifications.
A further exception effectively occurs in 14 CFR Part 43, Maintenance,
Preventive Maintenance, Rebuilding, and Alteration. Here, § 43.13(b) states
that “Each person maintaining or altering, or performing preventive
maintenance, shall do that work in such a manner and use materials of such a
quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or
appliance worked on will be at least equal to its original or properly altered
condition....” (Emphasis added.)
The language of 14 CFR § 43.13 can be construed to give mechanics, repair
stations, and airlines some flexibility in selecting or even fabricating parts if
they can determine that the item being worked on will be at least equal to its
original or “properly altered condition.” Part 43 contains no explicit
requirement that mechanics or repair stations use only “approved parts” or parts
produced in accordance with Part 21.
Clear, consistent use of terminology would help aviation industry
manufacturing and maintenance personnel, and FAA inspectors and
engineering staff determine what parts are eligible for installation on aircraft
and other type certificated aeronautical products. Thus, the discussion, for
purposes of SUPs, should focus on the part’s overall eligibility for installation
rather than addressing only one aspect of a part’s status.
FAA guidance and advisory material for its inspectors and the industry
currently address how to distinguish between parts that are eligible for
installation on aircraft and parts that are not acceptable. However, the Task
Force found certain inconsistencies among some of this guidance and advisory
material. (Appendix C contains a list of Advisory Circulars, Orders, and
Memoranda, and whether the Task Force believes they should be revised or
canceled due to inconsistencies in terminology or other treatment of SUPs
issues.)
Therefore, the Task Force addressed clarification of the following terms as one
of its top priorities:
1. “Approved part”
2. “Unapproved part”
3–2 3.0 Terminology

3. Standard part
4. Counterfeit part.
‘Approved Part’
The underlying question facing maintenance personnel when installing a part
on an aircraft or other type certificated aeronautical product is: “Is the part
eligible for installation?” The Task Force members, based on experience in
design, manufacture, and maintenance as well as in SUPs investigations,
recognize that the widely held perception of “approved parts” encompasses
whether the part was properly manufactured and whether it has been properly
maintained. Therefore, for purposes of future guidance and advisory material
addressing SUPs issues, the Task Force sought to define “approved part” in a
manner that would capture all aspects of a part’s eligibility for installation. The
term “eligibility” is considered synonymous with acceptability, but is preferred
in this context to avoid giving the impression that the part, beyond being
designed, produced, and maintained so that it is acceptable for use in general, is
also acceptable for use in any circumstances. Clearly, whether a part may be
used in a given application depends on the application and is not a matter for
the “approved parts” discussion.
The Task Force considers that an “approved part” should be one that is eligible
to be installed on an aircraft or other type certificated product. (Only an air-
craft, aircraft engine, or propeller receives a type certificate.) This means,
essentially, a part that is designed, produced and maintained in accordance with
the regulations and is in a condition for safe operation. The regulations that
apply to these parts are 14 CFR Part 21; 14 CFR Part 43; and 14 CFR Part 91.
Part 21 addresses design and manufacturing, and Parts 43 and 91 address
maintenance requirements. A part will remain in a condition for safe operation
as long as it is maintained in accordance with Parts 43 and 91.
Thus, the Task Force developed a definition that addresses a part’s
manufacturing origin and its maintenance status. The proposed definition
includes parts designed and produced under FAA approvals as well as parts
designed and manufactured under other systems that the regulations recognize
as acceptable. The definition addresses all aspects of whether a part is eligible
for use, but it does not specify whether the part is acceptable for use in a given
circumstance or application, i.e., whether it is the correct part for a specific
repair.

The Task Force has adopted the following definition of “approved part:”1
A part that has been produced in accordance with the requirements or
exceptions of 14 CFR Part 21, is maintained in accordance with 14 CFR
Parts 43 and 91, and meets applicable design standards. The phrase “in
accordance with the requirements or exceptions of 14 CFR Part 21” means:
a) In accordance with a PMA issued under § 21.303 (14 CFR Part 21,
Subpart K).
b) In accordance with a Technical Standard Order (TSO)
Authorization issued by the Administrator (14 CFR Part 21, Subpart
O).
c) Produced during Type Certificate (TC; 14 CFR Part 21, Subpart B)
or Supplemental Type Certificate (STC; 14 CFR Part 21, Subpart E)
application procedures before the certificate is issued and in
accordance with TC or STC data.
d) Produced under a Type Certificate without a separate production
authorization (14 CFR Part 21, Subpart F).
e) Produced under a Production Certificate, including by a licensee, if
produced under Production Certificate authority (14 CFR Part 21,
Subpart G).
f) Produced in accordance with an approval under a bilateral
airworthiness agreement (14 CFR Part 21, Subpart N).
g) Produced as standard parts (such as bolts and nuts) conforming to
established industry or U.S. specifications, in accordance with
§ 21.303 (14 CFR Part 21, Subpart K).
1“Commercial Part” eventually should also be treated as a type of “approved part.” This Proposed Program
Plan does not contain a suggested draft definition of commercial part, but efforts to develop a definition are
discussed later in this section.
Commercial parts are much like standard parts in terms of their broad availability in industry, and their
applicability in aviation uses. However, the term is not used in the regulations, and is little noticed in the SUPs
discussion.
A proposed definition is being drafted by an ARAC team; however, their work has not been completed. The
Task Force recognizes that a workable definition is not easy to develop and that the ARAC process is a more
appropriate forum than the relatively brief deliberations of the Task Force. A definition for commercial parts
should be adopted because such parts are not recognized in regulatory references to aeronautical parts, despite
the important role they play.
If the definition is ultimately included in the regulations, it would then be another avenue to “approved part”
and would be included in the list of regulatory methods to create “approved parts.”

h) Produced by an owner or operator for maintaining or altering his
own product (14 CFR Part 21, Subpart K).
i) Manufactured by a repair station or other authorized person during
alteration (not repair) under a Supplemental Type Certificate (STC)
or Field Approval. (FAA Order 8000.50 and 14 CFR Part 43).
j) Fabricated by a qualified person in the course of a repair for the
purpose of returning a product (aircraft, engine, or propeller) to
service, and not for sale as a separate part. (14 CFR Part 43).2
k) Produced in any other manner approved by the Administrator
(14 CFR Part 21, Subpart K).
As discussed above, under current regulations, a part does not necessarily have
to be “approved” in the strict sense of the Federal Aviation Regulations to be
eligible for installation on a type certificated product. The part may be
produced in another acceptable manner, such as standard nuts and bolts, or a
product approved for return to service under 14 CFR § 43.13(b). On the other
hand, a part that has been produced pursuant to an FAA approval, as well as
other acceptable manufactured parts, is not necessarily eligible for installation,
because it may be defective, lack required maintenance, or have reached a life
limit or other limit. The Task Force recognizes that use of the term “approved
part” is not entirely consistent with the meaning of approved as defined in 14
CFR Part 1. In Part 1, “approved” means approved by the Administrator
(unless another person is specified), and refers to an overt, explicit action of
consent. This concept is applied widely throughout the Federal Aviation
Regulations. As seen from the definition used in this document, some
“approved parts” would necessarily be produced under a certificate issued by
the FAA and thus would fit the current regulatory meaning of “approved.”
Other aviation parts, such as standard parts, are not produced under such
approvals, nor are parts fabricated as part of a repair process. (The fabrication
of parts in the repair process, in accordance with 14 CFR § 43.13(b), is
discussed in further detail in Section 6.0 of this Proposed Program Plan.) Such
parts may be acceptable to the FAA, but are not “approved” in the current
regulatory sense. Furthermore, all aviation parts, regardless of their origin,
would have to be maintained according to the regulations, and this too may fall
outside the current regulatory concept of “approved.”
2While it may be technically possible to comply with 14 CFR § 43.13(b) without using a part listed in this
definition, it is the Task Force’s position that use of such parts should not be standard practice because
installers are not usually in a position to determine a part’s conformity to type design. Therefore, acceptability
of a part should be determined prior to its installation using the above definition of “approved.” Until there is a
determination that a part’s installation would meet the requirements of 14 CFR § 43.13(b), it should not be
installed, and it should be reported as a SUP.

Nevertheless, while the limited meaning of the term “approved” is widespread
throughout the Federal Aviation Regulations, the broader use of the term
“approved part” — although now often misunderstood — is in widespread use
among the public, the aviation industry, Congress, law enforcement agencies,
the courts, and the FAA itself. The Task Force believes that the concept of
“approved parts” can be discussed in a broader sense than the stricter
regulatory definition of “approved” to provide the aviation industry and
government officials with a common understanding of what “approved parts”
are. However, this document uses the terms “approved parts” and “unapproved
parts” in quotation marks (except when citing the title of another document) to
denote use of the terms in the colloquial, rather than the regulatory, sense.
‘Unapproved Part’
AC 21-29A, Detecting and Reporting Suspected Unapproved Parts
(July 16, 1992), defines “unapproved part” as “A part, component, or material
that has not been manufactured in accordance with the approval procedures in
14 CFR § 21.305 or repaired in accordance with 14 CFR Part 43; that may not
conform to an approved type design; or may not conform to established
industry or U.S. specifications (standard parts). Such “unapproved parts” may
not be installed on a type certificated product.” The AC provides as examples
of “unapproved parts” the following:
1. “Counterfeit” or fraudulently marked parts, components, or
materials;
2. Parts shipped directly to users by a manufacturer, supplier, or
distributor who does not hold, or operate under the authority of, a
production approval for the part (e.g., production overruns); and
3. Parts that have been maintained or repaired and returned to service
by persons or facilities not authorized under 14 CFR Part 43 or 145.
This definition addresses important issues that also are covered in the Task
Force’s proposed definition of “approved part.” The three examples of
“unapproved parts” would all fail to meet the criteria of “approved part” as
defined by the Task Force. However, the Task Force has chosen a different
approach in that it seeks to set forth a list of criteria to help maintenance
personnel decide if they have a part that is eligible for installation. Hence, the
Task Force proposes a detailed definition of “approved part” as discussed
above, and the following definition of “unapproved part:”
A part that does not meet the requirements of an “approved part.”
The Task Force believes that “approved part” and “unapproved part” should be
antonyms, with no potential inconsistencies. The definition would be most
useful to the aviation community if it is expressed in terms of what is
acceptable for installation. Guidance and advisory material can and should

continue to provide examples of scenarios under which parts are not “approved
parts.”
It is evident that the concept of “unapproved part” is wide ranging,
encompassing everything from parts that are improperly maintained, to parts
produced under an FAA approval but shipped without proper authorization, to
parts deliberately and criminally misrepresented as “approved parts.” The
proper response by government officials, including the FAA and law
enforcement authorities, varies according to the kind of “unapproved part”
involved. Therefore, it is not useful to discuss “unapproved (or suspected
“unapproved) parts” indiscriminately; careful consideration should be given to
why a part may be “unapproved,” as this would help dictate the most
appropriate response.
FAA investigative and, when warranted, enforcement response to “unapproved
parts” cases, would continue to be handled with current mechanisms. That is,
cases involving used parts would be assigned to FSDOs, and cases involving
new parts and part design and production would be assigned to MIDOs, all for
disposition based on existing investigative and enforcement mechanisms, FAA
Order 2150.3A, and the proposed additional procedures in this document.
Nevertheless, the proposed expanded concept of “approved parts” and
“unapproved parts” did receive strong opposition from one of the Task Force
members. The opposition is based on the significant broadening of the
population of parts that would be reported and investigated under the SUPs
process, with, in the member’s opinion, little, if any, benefit to safety. This
member stated that the purpose of the current SUPs program is to identify and
take appropriate action against persons who produce, maintain, or alter type
certificated products, or parts thereof, without appropriate FAA authority. It is
the opinion of this member that this should remain the purpose of the SUPs
program, because this is where the greatest potential for safety concern lies.
The member points out that the FAA already requires authorized manufacturers
to have a quality program to prevent nonconforming parts from escaping their
system. Even the best quality system will occasionally allow a nonconforming
part to escape the process and be shipped to a user such as an air carrier or
repair station. If the users of these parts have an adequate quality program,
they should be performing incoming inspections to ensure that the parts they
buy and receive conform to the type design and are in condition for safe
operation. Further, the FAA’s continuous surveillance process should be
ensuring that these quality programs are in place and working properly.
Under the current system, these nonconforming parts would be returned to the
manufacturer through its established customer complaint program, without the
need for expending FAA resources. The PAH and the FAA should be
monitoring the manufacturer’s customer complaint system as a measure of the
quality of the products being shipped. If the established quality systems are not
working as intended, and the FAA’s surveillance reveals this, the established

systems should be adjusted. However, as pointed out by the Task Force
member with this differing view, under the Task Force’s proposed program,
nonconforming parts found at an incoming inspection would be reportable as
SUPs (Section 5.1 addresses the Task Force’s proposal for mandatory
reporting of SUPs). Once these nonconforming parts are reported as SUPs, this
Task Force member believes that a separate mechanism for SUPs investigation
and case resolution would trigger a process that duplicates one that is in
existence and is working, resulting in an unnecessary expenditure of FAA
resources and skewing the database in which SUPs are recorded and
monitored, without any added safety benefit.
The Task Force notes the disagreement concerning the definitions of “approved
part” and “unapproved part” and with the inclusion of nonconforming parts in
the database. However, the Task Force takes a broader view of the purpose of
the SUPs program and believes it is intended to identify and eliminate any parts
that are not eligible for installation on type-certificated products, and this would
include nonconforming new parts that inadvertently pass through PAH’s
quality control systems. The Task Force does not anticipate that significant
new FAA resources would be expended to address problems for which
satisfactory mechanisms already exist.
Standard Part
Currently, 14 CFR Part 21 does not define standard part, but it does list such
examples as nuts and bolts. The lack of a definition has caused some confusion
in public discussion of SUPs issues, and the Task Force considers it necessary
to define this term for purposes of advisory and guidance material and general
discussion of SUPs. The issue is under consideration by the ARAC and has
been the subject of interim guidance by AIR. The Task Force’s recommended
definition takes into account the previous work, but is primarily based on a
definition currently contained in FAA Order 8110.42, Parts Manufacturer
Approval Procedures, August 4, 1995.
The Task Force proposes the following definition of standard part:
A part included in the type design and manufactured in complete compliance
with an established U.S. government or industry-accepted specification that
includes design, manufacturing, and uniform identification requirements. The
specification must include all information necessary to produce and conform
the part. The specification must be published so that any person may
manufacture the part. Examples include, but are not limited to, National
Aerospace Standards (NAS), Army-Navy Aeronautical Standard (AN), Society
of Automotive Engineers (SAE), SAE Aerospace Standard (AS), Military
Standard (MS), and others.
The Task Force’s proposed definition emphasizes a key aspect of the use of
standard parts, which is that they may only be used when the product’s type
design calls for use of a standard part. The Task Force’s proposed definition

also differs in one respect from the definition that has been proposed by
ARAC. The proposed ARAC definition would permit a holder of an FAA
Type Certificate to establish a specification for a standard part. The Task Force
is uncomfortable with this provision, and considers that only industry-accepted
standards should be included. This would generally mean that the estab-
lishment and maintenance of industry standards would be left to recognized
standards organizations such as those cited above. A type certificate holder
could unilaterally change the standard, whereas a standards organization would
be subject to oversight from its broader constituency. Furthermore, the idea of
a “standard” established by one company is inconsistent with the FAA’s
interpretation of 14 CFR § 21.303(b)(4), as well as with the commonly held
understanding of a “standard” as being established by an authority or
organization rather than by an individual or single entity.
Counterfeit Part
A key term mentioned in the discussion of “unapproved parts” is “counterfeit
part.” This term often has connotations of criminal conduct, an issue much
different than parts lacking certain documentation. While neither of the parts in
this example are eligible for installation, the appropriate response to the
discovery of each is very different. Therefore, when discussing SUPs, it is
important to understand the distinction between counterfeit parts and other
types of “unapproved parts.” The Task Force’s concept of “counterfeit part” is
the following:
A part made or altered so as to imitate or resemble an “approved part”
without authority or right, and with the intent to mislead or defraud by passing
the imitation as original or genuine.
Counterfeit is a key term used in law enforcement, and specifically connotes
deliberate behavior. The Task Force recommends use of this definition in
guidance and training material.

This Page Intentionally Left Blank.

4.0 SUPs Program Organization
Issue: SUPs issues cross traditional organizational boundaries within the FAA,
mainly between the Aircraft Certification Service (AIR), which oversees the
designing and manufacturing of parts, and the Flight Standards Service (AFS),
which oversees the use of those parts in aviation maintenance.
Recommendation: The FAA should take immediate steps to establish a
National SUPs Program Office to develop, coordinate, and disseminate SUPs
policy, and to provide technical support related to SUPs. This office also
would maintain an information management and analysis system for the SUPs
program.
Discussion: The current FAA organization is oriented toward regulating: 1)

the design and manufacture of aircraft and aircraft parts; and 2) the use of air-
craft and aircraft parts, i.e., aircraft operations and maintenance. AIR is
assigned duties relating to designing and manufacturing, and AFS is assigned
duties relating to operations and maintenance. The two services share SUPs
responsibilities. For example, AIR monitors manufacturing facilities that apply
for and obtain FAA production approvals. AFS inspectors conduct
surveillance and inspections of certificated air carriers, repair stations, and the
activities of individual certificated mechanics. AFS inspectors’ main concern
is the quality of the maintenance; investigating the manufacturing history of
parts is not one of their primary considerations. Instead, inspectors tend to
concentrate on facilities, process, and records of maintenance activities.
The Task Force analyzed the FAA response to SUPs from an organizational
point of view in order to determine whether the current structure is adequate to
address SUPs. In considering the current FAA processes to address SUPs, the
Task Force concluded that SUPs require a uniform and integrated response
mechanism capable of addressing technical issues such as design, manufacture,
and maintenance, as well as criminal law issues that require a distinct
investigative process and coordination with law enforcement agencies.
As the Task Force began to analyze the SUPs program process and identify
changes that would improve that process, it became evident that the underlying
organization should also be considered. One option would be to maintain the
current organizational structure, based around the SUPs coordinators in the
FAA’s nine regional offices and four directorates, but increase guidance and
training. A second option would be to create a new national office to focus on
the SUPs issue and work in conjunction with the Regional/Directorate SUPs
Coordinators and with local offices. A third option would be to eliminate the
4.0 SUPs Program Organization 4–1

Regional/Directorate Coordinators, establish the national office, and have all
SUPs field activity in FAA local offices.
The Task Force concluded that the second option would be the most
appropriate to facilitate the processes needed to address SUPs. This national
office, working with the existing regional, directorate, and local offices, would
ensure a consistent approach to dealing with SUPs at all levels of the FAA.
When this is accomplished, the national office can be eliminated, except for
certain functions that are best handled at a national level, such as centralized
data collection.
The Task Force chose not to recommend retaining the current system with only
the addition of guidance and training, because it deemed that such an option
would not sufficiently enhance current processes. The Task Force, however,
does agree with the current FAA emphasis on regional/directorate focus and
analysis and management of SUPs issues. The Task Force also noted that law
enforcement agencies usually prefer to establish contacts for investigative
purposes at the field office level, which supports the retention of a
regional/directorate and local office structure for SUPs cases. Therefore, the
Task Force did not choose to recommend the option of eliminating the
regional/directorate SUPs coordination structure. However, improved
standardization and integration of policy, training, and technical information is
best accomplished at the national level. A centralized program to oversee
standardization of SUPs policy, training, and investigative procedures
throughout the FAA would result in placing greater emphasis on SUPs
reporting, tracking, investigation, and, where warranted, enforcement as inte-
grated parts of FAA inspectors’ duties, along with enforcement of other
applicable regulations.
The Task Force designed the proposed National SUPs Program Office to help
the FAA focus and standardize its policy and enforcement activities in this area
(see Figure 4-1 below). The Task Force envisions this Program Office as an
interim or transitional measure, recognizing that “interim” could mean a period
of years. The purpose of this Program Office would be to promote a cohesive,
consistent, aggressive approach to SUPs throughout the FAA, and solidify the
FAA’s working relationships with law enforcement agencies, including the
DOT/OIG. When the Program Office accomplishes its mission of ensuring that
thorough training and procedures for SUPs enforcement have been established
throughout the FAA, ensuring continued effectiveness of the program at all lev-
els of the FAA, the special Program Office can be disbanded. One of the
Program Office’s tasks would be to conduct periodic reviews of how well
SUPs policy is being implemented throughout the FAA; in essence, monitoring
the Program Office’s need for its own continued existence. Nevertheless, at
least two functions — data and information management, and a centralized
point of contact for certain duties within the FAA and externally — may need
to be retained at the national level permanently.
4–2 4.0 SUPs Program Organization

SUPs PROGRAM OFFICE
AGC and ACS Support

AVR-1
AVR-2 SUPs PROGRAM Advisory Council

MANAGER (SUPs Task Force)
AIRCRAFT FLIGHT
CERTIFICATION STANDARDS Policy
(AIR) (AFS) Information
Systems Technical
Guidance
Support
Analysis
Training
REGIONAL
OFFICE
(SUPs Coordinator)
LOCAL OFFICE
(FSDO)
DIRECTORATE
(SUPs Coordinator)
LOCAL OFFICE
(MIDO)
NOTE: Dashed lines indicate lines of communication,
not authority or direction.
Figure 4-1. SUPs Program Office Organizational Relationships

The SUPs Program Manager would report to the Deputy Associate
Administrator for Regulation and Certification (AVR-2). This would provide
the Program Office with the required standing to ensure a high degree of
visibility within the FAA, and allow the office to work closely with and
facilitate coordination of SUPs activities between AIR and AFS. The SUPs
Program Manager would essentially function as the FAA’s focal point for data
and information, for managing the development of SUPs policy and guidance,
and for disseminating the guidance and technical information to the field,
industry, and the public. The SUPs office would develop SUPs Program policy
and guidance in coordination with AIR and AFS, such as the basic SUPs Order
and the SUPs Advisory Circular. It would coordinate all other policy and
guidance developed by AIR and AFS that relates to SUPs. The SUPs office
would also recommend development of any SUPs policy or guidance, based on
the analysis of information collected in the new PRS.
There would be informal lines of communication between the SUPs National
Program Office and the four certification directorate and nine regional SUPs
coordinators of AIR and AFS, respectively, and with all of the AFS and AIR
local offices. The direct line authority to AIR’s directorates and MIDOs, and
AFS’s regions, FSDOs, and International Field Offices (IFOs) would not be
changed. It would continue to flow through AIR and AFS, as shown in Figure
4-1. The SUPs Program Office would not have line authority over any AIR or
AFS personnel, or their work program.
The personnel assigned to the National SUPs Program Office should be
multidisciplined, drawn from AFS and AIR, and established in one location in
order to coordinate the FAA groups and disciplines involved in SUPs. This
location should be at the FAA field offices at Dulles International Airport. The
Task Force selected Dulles because the prototype database already is located
there, facilities are available for the integrated staffing and operation that the
Task Force envisions, and because the location is conducive to recruiting
appropriately qualified staff.
The National SUPs Program Office would have the following basic functions
and responsibilities:
1. Provide the FAA’s “one voice” and primary point of external
contact on SUPs issues.
2. Provide technical support to FAA offices and industry.
3. Develop basic SUPs program policy and guidance material.
4. Develop and maintain a parts reporting information system and
analyze data in that system.
5. Provide program oversight, including the review of SUPs-related
enforcement actions, program audits, and accountability.

6. Accomplish National SUPs Program Office resource planning.
7. Participate in other activities, such as SUPs-related policy and
guidance development and ARAC activities as they relate to SUPs
(the National SUPs Program Office would not establish ARAC
projects or otherwise control or affect ARAC, other than to provide
input as appropriate regarding SUPs issues).
8. Disseminate SUPs information to FAA offices, to other government
agencies, and to industry.
9. Identify SUP-related training requirements, oversee training
program development, and evaluate training.
10. Report SUPs information to FAA management and other interested
parties, such as the aviation industry and Congress.
There would be three major functional areas, discussed here as “organizational
elements,” within the National SUPs Program Office to carry out these
functions and responsibilities, as discussed below.
4.1 Technical Support Organizational Element

The Technical Support organizational element would provide, for the interim
period of the National SUPs Program Office duration, a single source of
consistent, informed technical advice and assistance to the FAA workforce,
industry, and law enforcement agencies nationwide who encounter or think
they have encountered SUPs and need guidance on policy, regulations, or
technical information. The Office would be responsible for:
• Providing a single point of contact for FAA, industry, and law

enforcement agencies for current guidance on SUPs issues.
• Ensuring that part criticality is determined. This determination

would be accomplished by the Aircraft Certification Office (ACO)
responsible for the design approval of that part.
• Providing information on policy, and directing case routing and

priority, based on given circumstances and applicable regulations.
• Contacting and determining how to work with law enforcement

agencies, and gathering evidence.
• Keeping informed of FAA guidance and policy for dissemination to

the field.

• Keeping informed regarding relevant law enforcement, military, and
industry activity that might affect the SUPs program, including
resolving differences between the inspector and industry on techni-
cal issues.
• Disseminating policy. Although the Technical Support element

would not be responsible for policy development, it would be a
central element for responding to questions concerning SUPs policy,
and other FAA offices would typically defer to the Technical
Support element for this purpose so that policy explanations are
consistent.
The office would emphasize easy access, with extended hours (12 hours per
day in two overlapping shifts), 5 days per week, and/or paging capability to
offer a prompt response to inspectors during their surveillance and inspection
activity. As a single-source office with a relatively small staff, the Technical
Support organizational element would provide more consistent policy direction
and information in the field regarding SUPs. Over the long term, improved
training, SUPs policy dissemination, and database support should allow these
functions to be handled at the Regional/Directorate level.
The Technical Support element would operate in a fashion similar to the
Maintenance Control function of a major airline. That is, a group of technical
experts would be readily accessible to answer questions quickly and help field
personnel troubleshoot problems. The office would be staffed by six
AVR inspectors, three drawn from AIR and three from AFS, and one full-time
person assigned from ACS. To emphasize cohesion, the staff, although drawn
from AIR, AFS, and ACS, would work in a single office as a unit. Inspectors
staffing this office would receive special training from ACS, AGC, the
DOT/OIG, and the DCIS, in both interim and long term training, as discussed
in Section 9.0 of this Proposed Program Plan.
The Task Force arrived at the proposed staffing level after analyzing the
minimum number of inspectors required to provide expertise from the two
major services, AFS and AIR, in overlapping shifts serving multiple time
zones, and accounting for sick leave and vacations. ACS would not provide
such extensive shift coverage, but the Task Force believes that the expertise of
one full-time security/law enforcement expert and ready availability of
additional support as required would provide a valuable asset to supplement the
inspectors’ technical expertise. Similarly, the Task Force believes AGC should
work closely with the Technical Support element of the National SUPs
Program Office, including ready availability for consultation as required. The
Task Force considered but decided against recommending that staff from AGC
be assigned full-time to the Technical Support element; however, this office
(and others, if necessary) may designate specific contacts for Technical Sup-
port.

Technical Support resources would include an in-house reference library,
access to all relevant FAA databases, and a special telephone line for access
from the field and from industry. Access to the same authoritative response
would help industry get rapid, consistent guidance and would also prevent the
practice of “shopping” around FAA offices for the most favorable answer.
4.2 Data and Analysis Organizational Element

The National Program Office Data and Analysis organizational element would
perform the critical function of developing and maintaining the FAA PRS
database, which is discussed in greater detail in Section 7.0 of this Program
Plan. The Data and Analysis organizational element must study the FAA
prototype SUPs database and build on that experience. A requirements
analysis would help this organizational element build a more effective database
that would function foremost as a tool for inspectors in their research for
investigations.
The database also would be used for management analysis to monitor the size
and characteristics of the “unapproved parts” problem, to identify trends, to
quantify case processing time frames, and to measure the effectiveness of the
FAA’s SUPs program. Outside law enforcement agencies would have access
to the database, and should be consulted during the requirements analysis.
Management analysis would include a review of FAA enforcement actions for
consistency in final actions and to report back to the field what the final actions
are. The Data and Analysis element also would conduct audits to determine if
the database is current and accurate, training is effective, guidance is adequate,
and the SUPs program is standardized.
The Task Force proposes a staff of two persons for the Data and Analysis
organizational element. The personnel selected for this function would be
required to have both a knowledge of aviation practices and skills in database
management and use of analytical tools.
4.3 Policy, Guidance, and Training

Organizational Element
The Policy, Guidance, and Training organizational element would be a focal
point for FAA policy on SUPs, as expressed in FAA orders, and guidance,
advisory, and training material. This organizational element would be
responsible for developing the SUPs Order and Advisory Circular and for
coordinating these with AIR, AFS, and other appropriate FAA organizations.

It would also coordinate other policy and guidance material that impacts SUPs.
It would be responsible for understanding other policy as developed and issued
by AIR and/or AFS that relates to or impacts SUPs, and responding to
questions about the policy from FAA personnel, industry, or other government
agencies in support of the SUPs program. This organizational element,
working closely with the Data and Analysis organizational element, would also
identify any potential needs for new SUPs policy or problems with current
policy. Although the workload is still difficult to predict, the Task Force
foresees a minimum staffing level of two persons.
The Policy, Guidance, and Training organizational element would be
responsible for identifying SUPs training needs and overseeing the training
program development. It would also evaluate the effectiveness of SUPs
training by working closely with the Data and Analysis element.
The Policy element also would identify the need for regulatory changes, and be
the focal point for the National SUPs Program Office comments to other FAA
documents and activity related to SUPs.
4.4 National SUPs Program Office Staffing

The tentative staffing level proposed here by the Task Force, in summary, is
13 full-time staff members: 1 manager, 1 administrative person, 7 persons in
Technical Support, 2 in Data and Analysis, and 2 in Policy, Guidance, and
Training. The Task Force believes that the FAA should be prepared to be
flexible regarding the proposed staffing levels, particularly the Technical Sup-
port and Data and Analysis functions, and to consider ways to use staff from
other FAA organizations for specific problem resolution or to temporarily
supplement the National SUPs Program Office resources. There currently are
no data available to predict the workload. However, based on the experience of
1991–92, when SUPs case reports increased significantly after the FAA imple-
mented another series of SUPs initiatives including publication of AC 21-29,
Reporting Suspected Unapproved Parts, the Task Force expects that
SUPs-related queries and cases probably would increase in response to the
additional focus and emphasis from FAA headquarters.
Furthermore, the Task Force proposal would broaden the traditional concept of
“unapproved parts” to include parts that have been improperly maintained or
that have manufacturing defects, and this too would increase the number of
SUPs reports. Parts such as maintenance errors and defective new parts would
be included because, as discussed in Section 6.1, they are not eligible for
installation on type certificated products. However, the PRS database would
clearly distinguish the circumstances of these parts, rather than applying just
the broad term “unapproved part,” which would not contribute to identifying
and correcting the underlying problem.

4.5 Regional/Directorate SUPs Coordinators
and Local Offices
The FAA currently has SUPs coordinators in each of the nine FAA
geographical flight standards regions and four certification directorates. The
Task Force discussed the role of the Regional/Directorate SUPs Coordinator
within the context of the proposed National SUPs Program Office. The Task
Force envisions that the National SUPs Program Office would not have direct
line authority over the Regional/Directorate Coordinator or inspectors within
AFS or AIR. The post of Regional/Directorate Coordinator would not change
structurally, although it would be necessary to coordinate it with the National
SUPs Program Office. The Region/Directorate Coordinator would not
necessarily be a full-time position; workload would determine the full-time
equivalent level of the coordinator position. It may be a shared responsibility
or a part-time activity. The coordinator would provide the links between
inspectors and AGC and ACS.
Under the proposed system, including the National SUPs Program Office, the
Regional/Directorate SUPs Coordinators roles would include:
• Liaison with the Assistant Chief Counsel for the region
• Liaison with the Regional Civil Aviation Security Office
• Analysis of Regional/Directorate SUPs data and development of

reports
• Coordination with the field on assignment or reassignment of cases
• Support of the implementation of SUPs policy.

Local office inspector and manager roles would not significantly be affected by
the proposed organizational plan. One new requirement would be that the
office manager appoint a contact for external communications, including law
enforcement agencies. The point of contact would facilitate communications
and cooperation with outside agencies, particularly law enforcement agencies.
Law enforcement agencies envision that this local point of contact would
consist of an inspector interested in assisting in those agencies’ SUPs
investigations — which would require additional skills and approaches to
normal surveillance and inspection skills — who would tend to work with them
on a repeated basis. However, the Task Force expects such relationships to
develop on a case-by-case basis, with the FAA-designated point of contact, be
it the office manager or the manager’s designee, facilitating such cooperation
with law enforcement agencies. SUPs investigations based on cases initiated
through the FAA would continue to be assigned similar to the way in which
they currently are. Any local inspector could perform SUPs investigations, and
inspectors’ duties would include accomplishing SUPs surveillance; initiating

SUPs reports as SUPs are found; and alerting the Regional/Directorate SUPs
Coordinator of all significant developments in an investigation, until the PRS
database performs many of these alerting functions automatically.3
3In addition to the reporting process established within the FAA, industry reporting of SUPs would continue to
be a key source of SUPs case reports.

5.0 Regulatory Issues
This section addresses principal regulatory issues identified by the Task Force
in its deliberations and in discussions with representatives of law enforcement
agencies.
5.1 Reporting SUPs

Issue: Because there is currently no requirement that SUPs be reported to the
FAA, persons who discover SUPs may not report them.
Recommendation: The Federal Aviation Regulations should be amended to
require any person (including organizations and individuals such as mechanics)
who discovers suspected or known “unapproved parts” to report such parts to
the FAA. An exception to this requirement should be made for properly
documented parts that lack required maintenance but are controlled in such a
way as to ensure that the necessary maintenance or other appropriate steps are
accomplished before the parts are placed in service.
Discussion: The Task Force noted that, based on members’ experience, part of
the difficulty of determining the scope of the “unapproved parts” problem is
that such parts may go unreported if they are discovered by persons in the
industry rather than by FAA personnel. Recipients of “unapproved parts” may
prefer to return the items for refunds rather than report the parts and possibly
face the economic loss associated with giving them to the FAA or to law
enforcement agencies, or having them seized as evidence in criminal investiga-
tions. These recipients either prefer to exchange the parts, get refunds, or avoid
the cost and delays they may incur if they do report the parts.
The Task Force determined that the safety importance of eliminating
“unapproved parts” from the inventory warrants a mandatory reporting
requirement, similar to that for service difficulty reports. It is imperative that
certificated air agencies with potentially important knowledge of unapproved
and potentially unsafe aircraft parts share that information with the FAA and
with industry.
The Task Force recognizes, however, that its proposed definition of
“unapproved parts” is fairly broad and includes parts that would not present
any hazard to the industry. For example, parts that are overdue for
maintenance and are on a repair station’s shelf would qualify as “unapproved
parts” under the Task Force’s proposed definition. Yet if such parts were
5.0 Regulatory Issues 5–1

properly documented and were certain to be appropriately maintained prior to
being approved for use or return to service, they clearly present no hazard,
either within that repair station or in the industry at large. Mandating reporting
of such parts would clog the system, providing no safety benefit.
On the other hand, if a repair station’s receiving inspection detected that a new
part produced under an FAA-approved system had somehow escaped the
quality control system and was defective, that would be a matter of potential
interest to others in the industry. These parts might be representative of a
group of parts that inadvertently passed through a quality control system and
might be circulating in the industry. Even though such parts have been
produced under an approved system, they should be captured in the PRS
database, just as certain problems found during maintenance are currently
reported. In addition, such information should be disseminated expeditiously
so that other repair stations are alert for other potentially defective parts.
There are parts that may meet the definition of “unapproved part” that would
not require reporting. Parts contained within the quality system (i.e., did not
“escape”) of the certificate holder would not be reported as SUPs. Parts that
meet the definition of FAA Order 2150.3A, Appendix 1
(Compliance/Enforcement Bulletin 90-6, Reporting and correction policy and
implementing guidance) would not be reported as SUPs by the certificate
holder submitting the voluntary disclosure. However, if some of the parts
subject to the voluntary disclosure are identified by another person (outside the
certificate holder’s organization) and reported as SUPs, they would be
dispositioned in the PRS as a “Non-SUPs Issue” upon confirmation of their
status as part of the voluntary disclosure population.
The reporting requirement would not affect the investigative process. Case
assignment would continue to be made through the National SUPs Program
Office to the appropriate Region/FSDO, if the part were a used part, or to the
appropriate Directorate/MIDO, if a newly manufactured part were involved. It
cannot be assumed that manufacturers know the whereabouts of the parts they
produce, because parts are often sold through third parties and change hands
through various mechanisms in the industry. Thus, no new investigation or
enforcement mechanisms would be created to address the SUPs cases. The
reporting requirement would simply ensure that more cases could be
investigated, as warranted. Further, the requirement should be structured and
followed in a reasonable manner. For example, a mechanic who is unsure as to
whether a part should be reported as a SUP should take reasonable steps, such
as consulting with a supervisor, to verify that a part is suspect before reporting
it. A new part that is defective, but caught by the PAH’s or certificate holder’s
quality control system before being released, would not need to be reported.
The Task Force recognizes that some segments of the industry feel that there
may be a potential adverse impact in having their products associated with
“unapproved parts.” However, the proposed Part Reporting System database
would avoid indiscriminately grouping parts produced by PAHs but that may
5–2 5.0 Regulatory Issues

have inadvertently been released with defects, for example, with parts that are
unapproved because they were deliberately misrepresented. Such
indiscriminate grouping would serve no safety purpose. But monitoring and
tracking all potentially “unapproved parts” that may pose potential safety
problems in the industry would be a safety benefit. The recommendation is
thus worded to seek the broadest possible coverage, external to the FAA as
well as internal.
The Task Force has taken a completely technical approach to this issue, view-
ing “unapproved parts” as parts that, based on a set of technical criteria, should
not be installed on type certificated aeronautical products because of regulatory
and potential safety problems. Deliberate falsification of records, counterfeit-
ing of parts, and other fraudulent activities may be involved and, understand-
ably, legitimate companies do not want to have their names associated with
such behavior. However, the other element of the “unapproved parts” picture
is improper maintenance, inadvertent slips in quality control, or other mistakes
that also result in potentially unsafe aeronautical parts. The Task Force is
concerned about the safety aspect of “unapproved parts,” and therefore con-
siders the current and proposed PRS database essentially a technical database
of service to the FAA and industry that also serves law enforcement agencies,
because a portion of the SUPs cases do entail criminal activities. The reporting
requirement would not affect investigative or enforcement procedures, other
than to provide inspectors and the FAA with more information of potential use
in the process. This could permit better tracking of SUPs issues that could help
the FAA distribute timely alerts or ADs.
5.2 Records
Issue: Regulations concerning records associated with aircraft, aircraft
engines, propellers, components, parts, or materials may require updating or
clarification to help determine the items’ status as “approved parts” or
“unapproved parts.”
Recommendation: The FAA should expedite implementation of, and then
vigorously enforce:
• The draft regulatory project that would prohibit any person from
making fraudulent or intentionally false statements involving a
record that represents the acceptability of any aircraft product, part,
or material for use in civil aircraft; and
• The draft regulation that would address maintenance recordkeeping

requirements.
5.0 Regulatory Issues 5–3

Discussion: The FAA has two ongoing rulemaking initiatives that would
address many concerns regarding documentation of the acceptability of parts
for use in aviation. These initiatives are:
• A Notice of Proposed Rulemaking (NPRM), under development by the

FAA ARAC, would clarify records that should be maintained and
transferred in connection with the manufacture and maintenance of
aeronautical products. A key change under review in this proposed
regulation would be to require transfer of proper records by both the
party transferring a part and the party receiving the part. This would
make it very difficult for any person, including persons not certificated
by the FAA, such as distributors, to sell parts with inadequate docu-
mentation. That is because end-users, who are certificated and
regulated by the FAA, would not be permitted to accept such parts for
use in aviation without proper documentation.
• A rulemaking under consideration by the FAA would subject to civil

penalties any person who misrepresents the acceptability of any aircraft
product, part, or material for use in civil aircraft through fraudulent or
intentionally false statement in any record used to represent the
acceptability of any aircraft product, part, or material for use in civil
aircraft. Currently, 14 CFR §§ 21.2 and 43.12 address fraudulent or
intentionally false statements and records, specifically with regard to
those certification and maintenance regulations. FAA regulatory
authority currently focuses on producers of parts and users of parts
because they are the key players in aviation safety. The new regulation,
if adopted, would cover all persons, including persons not certificated
by the FAA, such as distributors and brokers of aircraft parts.
The two rulemaking initiatives under review would enhance the system in
terms of more than just distributors and brokers, because both initiatives would
apply to virtually all persons that handle aeronautical parts.
5–4 5.0 Regulatory Issues

6.0 Technical Issues
6.1 Responsibility for Parts Installation

Issue: Uncertainty may exist within segments of the aviation industry
regarding the responsibilities of mechanics, repair stations, and other persons
performing maintenance in accordance with 14 CFR Part 43, Maintenance,
Preventive Maintenance, Rebuilding, and Alteration. This uncertainty may
involve the quality of parts installed or produced for installation in connection
with work performed, and the limitations on maintenance personnel’s privilege
of fabrication of certain parts in connection with repair or alterations on type
certificated products.
Recommendation: Issue an AC or revise an existing AC explaining how
mechanics, airlines, and repair stations may comply with the requirements of
14 CFR § 43.13(b). Also, consider a legal interpretation or, if necessary,
additional rulemaking to further clarify the FAA’s belief that the person
responsible for installing a part must be able to show how that person
determined that the part was eligible for installation and that it was the correct
part for that application.
Discussion: Federal Aviation Regulations closely regulate the production of
aeronautical parts and their use. However, the regulations do not explicitly
require maintenance personnel to ensure that the parts they install meet the
specific criteria included in the concept of “approved part” to be eligible for use
on type certificated products. In certain situations, maintenance personnel may
fabricate parts required for the performance of their work. However, 14 CFR
§ 43.13(b) requires that, “Each person maintaining or altering, or performing
preventive maintenance, shall do that work in such a manner and use materials
of such a quality, that the condition of the aircraft, airframe, aircraft engine,
propeller, or appliance worked on will be at least equal to its original or
properly altered condition (with regard to aerodynamic function, structural
strength, resistance to vibration and deterioration, and other qualities affecting
aiworthiness).” This regulation assigns maintenance personnel with the
responsibility of ensuring the quality and acceptability of the parts they install,
and the FAA expects these personnel to be able to demonstrate their
compliance with the regulation.
6.0 Technical Issues 6–1

Maintenance personnel may comply with § 43.13(b) by using “approved
parts.” Maintenance personnel may also comply with the regulation if they
fabricate and install certain types of parts, as long as production and installation
of these parts is incidental to the maintenance at hand and the product worked
on is at least equal to its original or properly altered condition. The regulation
is intended to permit mechanics, repair stations, or other organizations, such as
air carriers, performing preventive maintenance, maintenance, or alteration,
sufficient flexibility to perform their work. (Section 6.2 contains further
discussion of this issue.)
The FAA expects the mechanic or organization performing the maintenance to
be able to demonstrate compliance with these requirements. The Task Force
believes that it would be appropriate for the FAA to issue an AC setting forth
its expectations of how a mechanic would comply with 14 CFR § 43.13. Such
compliance can be demonstrated through maintenance records, parts
documentation, appropriate tests, or the mechanic’s or maintenance
organization’s records of work performed.
If, after a reasonable period of time, the FAA finds that mechanics are not
following the guidelines of the recommended AC, the FAA may wish to
consider a legal interpretation to clarify the requirements under the regulations
for persons performing work in accordance with 14 CFR Part 43 to
demonstrate compliance with the requirements of that Part. A change to the
regulations should not be necessary, but if inspectors, based upon normal
surveillance and inspection and their increased emphasis on SUPs, find that
compliance with § 43.13(b) is lacking, a regulatory amendment may be in
order. Such an amendment might, for example, more directly address the types
of parts that should be used by mechanics or organizations, such as airlines and
repair stations, that perform maintenance under 14 CFR Part 43.
One form of parts documentation that should be addressed in the AC is
Certificates of Conformance (COCs), sometimes referred to as certifications.
COCs are commonly used throughout the industry, but are frequently accepted
at face value, even if they provide insufficient information. When properly
executed, COCs provide a reasonable degree of assurance as to the accuracy of
the data associated with the parts. Unfortunately, the Task Force believes there
may be many COCs that are not properly executed. These COCs may pose a
serious threat to the system when accepted by certificate holders without
knowledge of the COC’s potential accuracy.
The certificate holder must have knowledge of the system that generates the
COC to the extent that the certificate holder is convinced that the creator of the
COC is capable of assuring the data presented on the COC is complete and
accurate. Methods to reach this required level of knowledge include: 1) on-
site visit and assessment of the supplier’s quality system; 2) independent
verification of COC data and; 3) periodically requiring the issuer of the COC to
provide data to support the accuracy of the COC.
6–2 6.0 Technical Issues

6.2 Limitations on Parts Fabrication for
Repairs
Issue: Parts are being produced for use during repairs; however, parts in
addition to those required for such repairs are being produced for sale without
proper production approval.
Recommendation: The FAA should issue or revise advisory material to
clarify for industry the conditions under which maintenance personnel may
fabricate parts for repairs or alterations, and the conditions in which they must
apply for a PMA for parts production. If a person produces parts for sale
without a required PMA, the FAA should take appropriate enforcement action.
Discussion: Maintenance personnel are permitted, as discussed above, to
fabricate certain types of parts in connection with their work. However, 14
CFR § 43.13(b) is not intended to permit production of parts for sale in
circumvention of the requirements of 14 CFR Part 21, Certification Procedures
for Products and Parts.
This has been clarified in FAA Order 8000.50, Repair Station Production of
Replacement or Modification Parts (1981), which addresses part manufacture
during alteration (not repair) under a Supplemental Type Certificate (STC) or
field approval. The Order states that replacement or modification parts may be
produced only for installation on aircraft either brought to the repair station for
the work or at other locations under the repair station’s direct authority, unless
the repair station obtains a PMA that meets the provisions of 14 CFR § 21.303.
If the repair station obtains the PMA, the parts may be installed by other
persons.
The Task Force believes that these provisions for fabricating parts for
maintenance activities are being misused in the industry as a basis for
fabrication of parts for sale, rather than for use on an aircraft, engine, or
propeller undergoing repair or alteration. Advisory material for maintenance
personnel, such as AC 43.13-1A, Acceptable Methods, Techniques, and
Practices – Aircraft Inspection and Repair, and AC 43.13-2A, Acceptable
Methods, Techniques, and Practices – Aircraft Alterations, should be reviewed,
and guidance should be clarified to emphasize that parts may only be
manufactured for use during maintenance or alteration of products, and that the
production of parts for subsequent sale is not permitted without appropriate
production approvals. Training for FAA personnel and the advisory material
for the industry about the fabrication of parts during repair should be improved.

6.3 Parts Distributors and Brokers
Issue: The FAA does not certificate or monitor distributors and brokers of
aeronautical parts. The DOT/OIG has advocated, and Congress has requested
that the FAA explore, regulation of distributors and brokers.
Recommendation: The FAA should continue its support for the development
of an effective Aerospace Industry Regulation of Distributors (AIR-DU)
program of voluntary accreditation for distributors.
Discussion: During Senate hearings on the DOT fiscal year 1994 appro-
priation, the FAA was asked to report on the potential of regulating and
licensing brokers, distributors, and other parties engaged in the sale of parts for
aeronautical products. The House of Representatives also has discussed the
potential need for licensing and regulating distributors and brokers as a result
of concern expressed by the DOT/OIG regarding “unscrupulous brokers who
introduce many of the unapproved or bogus parts into the market” (House
Report 103-190, July 27, 1993). The issue also was discussed during the
Senate Governmental Affairs Committee hearing on unapproved airplane parts,
held by Senator Cohen on May 24, 1995.
The DOT/OIG recommended in 1993 that FAA regulatory authority be ex-
panded to include surveillance of aircraft parts distributors or brokers, and to
require distributors or brokers to maintain documentation for the traceability of
all parts sold or traded, and provide to purchasers documentation supporting the
FAA approval status and manufacturing origin of all such aircraft parts. (Draft
Report on Audit of the Certification and Surveillance of Domestic and Foreign
Repair Stations, December 17, 1993, DOT/OIG. Final Report No. R4-FA-4-
009, March 7, 1994.)
On June 10, 1994, the Air Transport Association of America (ATA) submitted
a petition for rulemaking to the FAA, in which the ATA requests that the FAA
establish Federal Aviation Regulations requiring quality inspection systems for
all aircraft parts distributors, suppliers, sellers, brokers, and surplus dealers.
ATA specified that the regulation should pertain to activities related to
commercial aircraft only.
The FAA investigated the issue and concluded that regulating and licensing
those entities would not enhance safety because a distributor willing to risk
penalties to sell counterfeit or fraudulently documented parts knowingly, in
violation of criminal fraud statutes, was unlikely to be dissuaded by ad-
ministrative FAA licensing requirements. The FAA was concerned that
devoting significant resources to regulating a large, new segment of the
industry without discernible safety benefits might detract from other priority
safety programs. The FAA has recognized the role that distributors and brokers
play in providing parts, and supports initiatives to enhance the quality of their
participation in the system. The FAA supports the development of an industry-

run, voluntary distributor/dealer accreditation program. Based on work on the
program by the AIR-DU Task Force, the FAA made available for public
comment, on July 7, 1995, AC No. 20-AIR-DU, a proposed AC on the
Voluntary Industry Distributor Dealer Accreditation Program. The FAA also is
reviewing a possible new regulation that would prohibit any person from false-
ly representing the status of an aviation part, as well as possible additional
documentation requirements for parts.
The Task Force re-examined the proposal to regulate distributors and brokers
of aviation parts and materials. However, the Task Force had two major
concerns about this proposal. First, the Task Force did not want the FAA to
take any action that would imply that users of parts — i.e., owner/operators
such as airlines, repair stations, and mechanics — would have less
responsibility for ensuring that parts meet all requirements before installing
them.
Second, the Task Force believes that regulating distributors is not practical
because of the potential size of the group, estimated at several thousand
entities, and the FAA’s limited resources to conduct oversight. Some parts can
have both aviation and nonaviation use, and the distributor may not know the
intended use. Also, the Task Force noted that distributors of standard and
commercial parts are so numerous that they could not realistically be regulated.
The Task Force considered the option of regulating only distributors of a
limited class of aviation part. This limited class would include parts that are
typically used in critical applications. This would reduce the scope of the over-
sight to a more manageable level; however, after further review, it was decided
that most distributors sell a wide range of parts. Consequently, the surveillance
problem would not be substantially simplified.
Another option considered was the addition of a requirement for a
manufacturer to conduct surveillance of any organization that the manufacturer
has designated as an authorized distributor of its parts. After discussion, it was
decided that this would cover only a small part of the distributor population,
because relatively few distributors are designated by manufacturers as
“authorized.” Furthermore, there would be a problem if a manufacturer ceased
operations, or in the case of an aircraft no longer in production, did not have
the information or personnel with the knowledge to conduct such surveillance.
The Task Force believes that while directly certificating and regulating
distributors and brokers of aeronautical parts is impractical, they would be
effectively regulated, in terms of SUPs issues and investigations, by the two
rulemaking initiatives already underway, as discussed in Section 5.2. The
maintenance recordkeeping regulatory proposal would essentially force
purchasers of aeronautical parts to demand proper documentation, as would be
outlined in the regulation. The regulation to prohibit any person from making
fraudulent or deliberately misleading statements regarding aeronautical parts

and materials would apply to certificated and noncertificated persons alike, thus
facilitating SUPs investigations and enforcement.
Even without directly regulating them, the FAA does have some avenues that it
can pursue if it finds an “unapproved parts” problem in connection with
distributors or brokers. By issuing an administrative subpoena in the context of
an FAA formal fact-finding investigation (14 CFR § 13.111), the Presiding
Officer may order the production of physical evidence. Under 14 CFR § 13.20,
the Administrator can issue a cease and desist order. The FAA can seek a
Federal District Court order enjoining the sale of “unapproved parts.”
Although the FAA lacks statutory authority to summarily seize “unapproved
parts,” the FAA does not need to certificate and regulate distributors and
brokers to have some control over their actions.
In addition, the AIR-DU distributor/dealer voluntary accreditation program, if it
is appropriately implemented, would assist the aviation industry in identifying
distributors with adequate quality control systems and those that pay careful
attention to required documentation. The Task Force endorses the concept of
this project, as outlined in a draft AC issued by the FAA for public comment,
because it would provide distributors with a strong incentive to establish and
maintain quality control systems. It also contains an incentive to parts
purchasers to use accredited distributors. In the event that a purchaser’s use of
a part resulted in an incident of noncompliance with the regulations, the FAA
might consider the purchaser’s use of accredited distributors as a mitigating
factor during any enforcement action, if that purchaser also has procedures for
routinely reporting any problems with such distributors.
Nevertheless, as would be the case with regulating distributors, the Task Force
believes that the accreditation program should not be seen as relieving users of
aviation parts and materials from their responsibilities for ensuring that such
items meet applicable quality and documentation requirements.
6.4 SUPs Investigations and Penalties
Investigation Process
Issue: FAA procedures, reflected in training and guidance, should specifically
support an Aviation Safety Inspector’s investigation of suspected “unapproved
parts” cases and the discovery of such cases in the course of routine surveil-
lance and inspection duties. This is particularly true when criminal activities
are involved.

Recommendation: FAA procedures and related guidance and training should
be upgraded to emphasize the importance of thorough SUPs investigations,
with attention to the potential scope of the problem, collection of evidence,
indicators of fraud or other criminal activity, and adequate documentation.
Investigative procedures followed by FAA inspectors should be revised to en-
sure that all necessary steps are taken to address SUPs on a system-wide basis,
with proper coordination between local, Regional/Directorate, and national
offices, as well as with the DOT/OIG and other law enforcement authorities, if
appropriate.
Discussion: FAA inspectors’ duties include routine surveillance and in-
spection of entities certificated by the FAA for compliance with regulations.
Although not typically a part of surveillance, inspecting for deliberately hidden
violations of the regulations or statutes should not be overlooked. Inspectors
also should have the guidance and training in procedures to thoroughly
investigate a SUP once it is initially identified.
The Task Force recognizes that procedures should be established and
inspectors’ training and guidance broadened to enhance inspectors’ ability to
look beyond traditional surveillance and inspection checklist items such as
quality of processes, equipment, facilities, recordkeeping, training, and
certification of personnel. Guidance and procedures should help inspectors
focus and investigate to determine the extent of the problem. In a related issue,
discussed above in Section 6.3, there is some confusion over the jurisdiction
and authority of an FAA inspector when a nonregulated person, such as a
distributor or broker, appears to be the source or intermediary of a SUP. (Other
noncertificate holders such as persons producing parts in violation of 14 CFR §
21.303 clearly are covered by the regulation.) Finally, procedures regarding
FAA inspectors’ contacts with law enforcement agencies require clarification
and streamlining to ensure that FAA technical expertise and information are
readily available for prosecution of criminal cases, and that law enforcement
agencies appropriately recognize the FAA safety responsibilities.
The Task Force sought to identify issues unique to SUPs investigations and
thereby develop SUPs investigative procedures that would aid inspectors’
investigations as well as help the FAA work more cooperatively with law
enforcement agencies. A more detailed discussion of this analysis is contained
in Appendix D of this Program Plan. The discussion is not intended to be a
step-by-step guide to a complete SUPs investigation, but a description of
considerations in addition to a non-SUPs enforcement investigation that future
guidance and training should address. Guidance on these SUPs-unique
investigative steps and considerations should be integrated into existing
Aviation Safety Inspector (ASI) guidance material, as well as presented in spe-
cial guidance documents and, especially, training. More detailed information
about the presentation of this SUPs-specific material is contained in Section 9.0
of this Program Plan entitled Training.

The Task Force discussed current policy regarding maximum allowable time
limits for responding to SUPs reports. Once detailed SUPs investigation
procedures are refined or developed, the Task Force believes suspense times
also should be reviewed.
One criticism of the current FAA SUPs investigative techniques has been that
inspectors may not always look beyond the immediate situation. That is, some
inspectors may investigate only within the limits of the information in the initial
SUPs report. The Task Force believes that inspectors should receive additional
guidance and training on the need to be aware of the potential size and scope of
a SUPs case, beyond what is immediately obvious. For example, if a part is
found at one facility, the inspector may need to look for the same part at other
facilities, or check to see if the organization involved has other parts that may
also be SUPs. Such measures may help the inspector assess the potential scope
of the SUPs case and the potential safety impact.
Seizure of Parts
Issue: The FAA does not have clear authority to seize and destroy parts that
are being misrepresented as “approved parts” when they do not conform to an
approved type design or do not meet other requirements.
Recommendation: The FAA should encourage legislative action to obtain
authority to seize and destroy counterfeit parts, apart from any criminal
proceedings.
Discussion: Absent a criminal investigation, the FAA has limited power to
prevent the entry into the aviation system of counterfeit parts immediately upon
their discovery. By contrast, the FAA has been granted statutory authority to
summarily seize aircraft involved in a violation for which a civil penalty may
be imposed. Thus far, all confiscations of parts have been carried out by the
FBI. However, if the FBI and Department of Justice chose not to participate in
a SUPs investigation, the FAA would not be able to avail itself of the
confiscation powers of the FBI and the Department of Justice.
As examples, the USCS and the Food and Drug Administration have the
statutory authority to seize and destroy, through judicial proceedings,
counterfeit or misbranded items that they discover, before those items proceed
further in the stream of commerce. A similar mechanism is desirable to ensure
aviation safety when counterfeit parts, intended for aviation use, are
discovered.

Civil Penalties
Issue: Current maximum civil penalties authorized by law for violations of the
Federal Aviation Regulations are insufficient to dissuade some persons from
selling or using “unapproved parts.”
Recommendation: The FAA should encourage legislative action to increase
the maximum civil penalty for persons other than air carriers, to which the
higher maximums already apply, to $10,000 per violation.
Discussion: As noted in FAA Order 2150.3A, Compliance and Enforcement
Program, Appendix 4, the maximum civil penalty for violations committed by
air carriers was increased by law from $1,000 to $10,000 per violation on
December 30, 1987. However, maximum civil penalties for other types of
entities, such as mechanics, agencies, noncertificated persons, repair stations,
and others, remain at $1,000 per violation.
The Task Force believes that current civil penalties available in connection
with SUPs-related enforcement actions are insufficient to deter certain persons
from selling or using “unapproved parts,” including deliberately
misrepresenting the acceptability of those parts for use on aircraft, aircraft
engines, or propellers. The Task Force concluded that an increase in maximum
allowable civil penalties would serve as a further deterrent to “unapproved
parts.” The Task Force believes that this should also be increased to $10,000.
6.5 Instructions for Continued Airworthiness

Issue: One of the factors that contributes to SUPs that are not maintained in
accordance with 14 CFR Part 43 is the lack of Instructions for Continued
Airworthiness (IFCA), as required by certification regulations. Although there
are existing requirements for IFCA, the Task Force does not believe the
industry always complies with them.
Recommendation: The FAA should review the application of and enforce
requirements for inclusion of IFCA in type certification regulations. The FAA
should revise advisory material to clarify that 14 CFR §§ 21.303(d) and
21.50(b) require holders of PMAs to furnish IFCA.
Discussion: Type Certificate holders are required by 14 CFR § 21.50 to
provide IFCA. Some type certificated products have entered service without
such IFCA being available to the operator. Furthermore, replacement TSO or
PMA parts often do not have approved IFCA. Many manufacturer’s
maintenance manual instructions for continued airworthiness apply only to
those parts installed as original equipment. Moreover, some manufacturers
have included in their manuals language that states the IFCA provided by the
manufacturer only apply to their products, which results in a lack of IFCA for

like products produced under a PMA. The lack of such instructions may result
in the absence of a program to ensure continued airworthiness. The FAA
currently has a team working on the issue of IFCA.
It is important for the appropriate FAA offices to ensure that complete IFCA
are published in those manuals referenced in the applicable appendixes of the
certification regulations. Complying with such instructions enhances detection
of parts that do not perform as intended, whether or not they were originally
produced under an approved manufacturing process. The Task Force believes
that the lack of IFCA could aggravate the “unapproved parts” problem and is
basically an issue of the industry not meeting the intent of the current
regulations. The Task Force also believes that 14 CFR Part 21 does require
PMA holders to include IFCA in their manuals. That is because 14 CFR
§ 21.50(b) requires that the holder of a design approval, including either the
type certificate or supplemental type certificate for an aircraft, aircraft engine,
or propeller, must furnish IFCA to the owner. The Task Force does not believe
this regulation was intended to be limited to, but rather should include, holders
of type certificates or supplemental type certificate approvals. Section
21.303(d) indicates that a PMA is also an approved design, and therefore
holders of PMAs should include IFCA in their manuals. Advisory material
should be revised to clarify this.
6.6 Use of Joint Aviation Authorities (JAA)

Form 1 and FAA Form 8130-3
Issue: JAA Form 1 is considered more limited than FAA Form 8130-3
(Airworthiness Approval Tag) because it does not provide complete
information about a part’s approval for installation (i.e., that it is both an
approved part and an airworthy part). Specifically, Form 1 does not carry the
14 CFR § 43.9 approval for return-to-service information required by the FAA.
Recommendation: The Task Force supports efforts to develop harmonized
forms and recommends that AVR instruct FAA members of the FAA-JAA
Working Group to seek to have the harmonized JAA Form 1 the same as the
FAA Form 8130-3.
Discussion: The FAA and the JAA have a number of programs underway to
harmonize the Federal Aviation Regulations and the Joint Aviation
Requirements. One of these initiatives relates to maintenance requirements and
records. Agreement has been reached about the need for a standard form (or
tag) that provides the status of a part. The JAA Form 1 is designed for that
purpose. The FAA has developed a revised Form 8130-3 for that purpose.
The harmonization work continues through a special Working Group that
includes FAA and JAA personnel. This Working Group should ensure that, at

the very least, procedures are developed to provide for an appropriate
return-to-service document attached to the part’s documentation, even if this
requires attaching an additional document to the JAA Form 1. (If the JAA
Form 1 is modified to include all the information on the revised FAA Form
8130-3, this would not be necessary.) The Task Force believes that the revised
Form 8130-3 is complete and is the preferred method for documenting the
status of a part.
6.7 Required Documentation

Issue: In the event that a part lacks complete documentation (which might
include a data plate), what does it take to determine the part to be “approved?”
Existing or draft guidance material that addresses this issue is not adequate.
Recommendation: The Task Force endorses the objectives and concepts
embodied in the draft AC that address methods for determining the
acceptability of parts that have insufficient documentation (AC 20.XX,
Determining Disposition of Undocumented Parts); however, it believes that the
definition of Group A parts could be problematic. Consequently, the FAA
Working Group developing this AC should reconsider its method for grouping
parts.
Discussion: Currently, there are no recognized provisions for evaluating and
approving for return to service aircraft parts that have become separated from
documentation that attests to their acceptability. The required documentation
may consist of data plates that have become detached from components, or
could be as extensive as aircraft or engine logbooks that have been lost or
destroyed. Certain types of parts may be particularly susceptible to missing
documentation, and, under certain circumstances, vendors may attempt to
supply sketchy, insufficient, or misleading documentation to facilitate the sale
of such parts. Just as there are no provisions in place for addressing missing
documentation, there are also no provisions for identifying fraudulently
represented parts.
Examples of the types of parts that may have inadequate or misleading
documentation are:
• Parts manufactured by a supplier and shipped directly to a user

without complying with § 21.303 or direct-ship authority;
• Salvaged parts;
• Parts manufactured for use by the military;
• Parts that have exceeded established life limits;
• Owner-produced parts;

• Parts manufactured without any production approval authority; or
• Parts that have undergone maintenance, repair, alteration, or

overhaul without compliance with the Federal Aviation Regulations.
The ARAC created a working group to address this issue; however, this group
was unable to reach consensus on the draft AC that it developed and turned the
project over to the FAA for completion. The FAA Working Group’s draft AC
provides guidance and information for persons to use in developing a system or
plan for evaluating parts without documentation and either approving or not
approving them for return to service. The draft AC also provides instructions
for segregating parts for which no acceptability determination can be made.
Task Force members reviewed draft AC 20-XX and generally agree with its
objectives and proposed processes. However, the group disagrees with the
AC’s classification of parts: the AC categorizes Group A parts as those whose
failure, malfunction, or absence could cause an uncommanded engine shut
down or other failure resulting in loss or serious damage to the aircraft, or an
unsafe condition. Group B parts are described as those parts not identified as
Group A parts.
The Task Force members concluded that the proposed AC’s definition of
Group A parts is too broad. Members of the Task Force also expressed
concern that certain portions of the draft AC conflict with the Task Force’s
current efforts, and should be revised before final publication of the AC.
6.8 Part Criticality

Issue: Determining the “criticality” of a part identified in a SUPs investigation
should be made according to consistently applied technical criteria. This would
help the FAA and law enforcement agencies determine the case priority and
potential safety implication.
Recommendation: Revise Order 8120.10, Suspected Unapproved Part
Program, with particular attention to the definition of part criticality, and adopt
procedures under which the National SUPs Program Office will coordinate
with the appropriate ACO for the purpose of determining “part criticality.”
Discussion: A technically accurate determination of part criticality is
necessary to help the FAA establish the priority assigned to SUPs case
investigations. This information also would permit the proposed FAA National
SUPs Program Office to focus the investigation and determine the potential
scope. Law enforcement agents also emphasized to the Task Force the need for
such information to help prioritize their investigative work. They stated that
investigators need a yardstick by which to measure relative importance of parts
in order to target their investigations and determine which parts to focus on.

Under current procedure, specified in FAA Order 8120.10, Suspected
Unapproved Part Program (September 28,1993), AIR-300 is charged with
assessing “Initial Priority Category” to establish the investigation priority. The
same guidelines apply to determining “Final Safety Category.” Part criticality
is one of the factors that is considered when cases are assigned a category. The
problem with this system is that “part criticality” is not treated in a consistent
manner. Order 8120.10 establishes six case priority categories that relate
directly to the part in question. Four of these categories apply to the potential
effect of the part on safe operation of the aircraft, and two of the categories
address whether the case actually involved SUPs (Order 8120.10, Appendix 5,
pages 1-2). The current procedure also permits AIR-300 to change the priority
category in the database upon receiving substantiating information from the
investigating office.
The FAA already is moving to refine the criteria used for determining priority.
Instead of the current six priority categories, three are being considered, and
they apply only to part criticality rather than to a mix of part criticality and case
status (i.e., whether or not it is a substantiated SUPs case). The new categories
would consider the most critical part (Category 1) as one whose intended use
indicates that the consequences of its failure could, considered separately and
in relation to other systems, reduce safety margins, degrade performance, or
cause loss of capability to conduct certain flight operations so as to prevent the
continued safe flight and landing of the aircraft. Such conditions may require
the use of the “Emergency Procedures” portion of the flight manual, aircraft
placards, or type certificate data sheets, as applicable. A Category 2 critical
part would be one, essentially, whose failure would not prevent continued safe
flight and landing of the aircraft, but that may reduce the capability of the
aircraft or the ability of the crew, by increasing the workload, for example, to
cope with adverse operating conditions or subsequent failures. Failure of a
Category 3 part would not cause a departure from “Normal Operating
Procedures,” according to the revised definitions under study. If a part can be
used in more that one application and the criticality would be different in
different applications, the application that results in the greatest safety risk is
the one that governs part criticality determination.
Identifying part application criticality is considered a complex process because
of aircraft system reliability and redundancy. The Task Force therefore found
that determination of part criticality should be a task assigned to the appropriate
Certificate Management ACO, rather than the investigating office. The Task
Force also stresses the distinction between the concept of “part criticality” and
“case priority.” Case priority may be based on numerous factors in addition to
the part criticality. For example, other factors would include the number of
parts involved and whether they have been installed on aircraft. (Appendix D,
SUPs Investigation Procedures, contains a discussion of case prioritization.)

The Task Force developed recommended procedures in connection with
establishing part criticality. When part numbers cited in the SUPs report are
determined to be correct by the investigator, the Certificate Management ACO
would be requested by the Technical Services organizational element of the
National SUPs Program Office to determine part criticality based on the
guidelines of the draft revision of Order 8120.10.
Over time, part criticality information for specific parts would be found in the
PRS database and thus more readily available in establishing, with greater
authority, initial case priority. This is because as part criticality is determined
by ACOs on a case-by-case basis, the information is entered into the current
SUPs prototype database. This practice would continue with the successor
PRS database. Thus, when a new case involves a part number already in the
database, part criticality would be automatically assigned. The Task Force en-
visions that the ACO eventually would have the capability to enter its part
criticality determination directly into the database, rather than having to route it
through the National SUPs Program Office. This determination by the ACO
could be changed only in the relatively rare event that the ACO determined that
a change was needed. This part criticality information would be made
available to the case investigator by the PRS database with no further need to
go through the ACO.
The Task Force considered not using the ACO to establish the part criticality,
but determined that this option could contribute to inconsistency in the
determinations. The ACOs are most intimately familiar with this issue, and are
the most appropriate offices to make this highly technical determination.
6.9 Surplus Military Parts

Issue: Aviation parts that had been produced for military applications, or
produced for FAA-certificated products but subsequently operated in a military
environment, may not have been produced, operated, or maintained in
accordance with the Federal Aviation Regulations. Their use may pose a risk
to safety. This problem is compounded because commercial and military
products often share identical part numbers. Furthermore, the recent disclosure
that the military intends to dispose of significant quantities of surplus aviation
equipment is expected to create a potential threat to the commercial system.
Recommendation: The Task Force believes that the Department of Defense
(DoD)-planned steps and the procedures in draft AC 20-XX adequately address
the SUPs problem, and recommends that the National SUPs Program Office
monitor the DoD/FAA Program to ensure that it is compatible with the FAA
SUPs Program. If the program is not implemented on time or consistent with
the current plan, the Task Force recommends that the FAA develop specific
policy and procedures to minimize the threat posed by surplus military parts.

Discussion: The DoD is required by the Surplus Property Act of 1944 to
dispose of its surplus property; however, it is prevented from destroying
property with any economic value. Consequently, certain aviation parts that
are considered surplus by the military are sold. Some of these may be unfit for
any aviation application, some may not be appropriate for use on a civil
aircraft, and others may be acceptable for use on civil aircraft. One of the
important questions is whether or not there is sufficient documentation or other
identifying information associated with a given part to determine which of
these three possibilities is the case.
On September 13, 1994, the Deputy Under Secretary of Defense (Logistics)
convened a meeting hosted by the Defense Logistics Agency, in part, as a
result of FAA concerns over military surplus parts entering into the civil market
place. At that meeting, a Process Action Team (PAT) was established, which
produced a set of five recommendations related to the identification,
disposition, and control of a flight safety critical aircraft part (FSCAP).
Subsequently, the DoD and the FAA accepted the recommendations and
developed an implementation plan. The plan, documented in a July 6, 1995,
memorandum signed by the DoD and AVR-1, identified the following actions:
1. Process for Identification of Dual-Use FSCAPs
a) The DoD and the FAA will publish in their respective regulations,
advisory material, and other appropriate documents the definition of
FSCAP developed by the PAT.
b) The DoD will assess the systems and regulatory changes necessary
to identify current and future FSCAPs in its provisioning and
cataloging records, distinguishing between military and dual use
applications, and initiate action to implement the appropriate
changes.
c) The DoD (for the military services) and the FAA (for the Coast
Guard and public sector aircraft) will initiate action to require the
tracking of FSCAP usage. To the extent possible, tracking
procedures (including deficiency reporting), currently in place by
the various organizations, will be used, modified only as necessary.
d) The DoD and the FAA will initiate action jointly to ensure that
manufacturers provide to DoD the FAA Form 8130-3,
Airworthiness Approval Tag, when FSCAPs are delivered. The
DoD will develop procedures to provide the Tag to the Defense
Reutilization and Marketing Offices (DRMOs) when the FSCAPs
are being disposed of.
e) The DoD will assess the feasibility of using Designated
Airworthiness Representatives or Designated Manufacturing
Inspection Representatives to determine the eligibility of FSCAP for
dual-use designation and certification.

2. Identification of Appropriate Documentation to Accompany all FSCAPs
at Time of Disposal from DoD Inventory
a) The DoD will apply serial number controls and track the usage
history of FSCAPs, where practicable. Relevant documentation will
be provided to the DRMOs when the FSCAPs are being disposed of.
b) The DoD and the FAA jointly will assess the feasibility of adopting
common procedures for documenting FSCAPs and attempt to
minimize the amount of documentation necessary.
3. Process and Coding Structure to Ensure that FSCAPs Lacking
Documentation are Mutilated
The DoD will initiate action to establish a coding structure that
identifies FSCAPs and, in conjunction with the condition of the
FSCAPs, enables the military services to determine if the FSCAPs must
be mutilated by the services or can be sold by the DRMOs.
4. Ensure Inter-Service/Agency Sharing of Information
a) The DoD and the FAA jointly will review how technical and other
information is shared within and between the involved
organizations, with a view toward improving the information flow.
b) The DoD will assess the feasibility of returning a portion of the
disposal sales proceeds to the military services to reimburse their
processing expenses.
5. Develop a Process to Ensure That Non-DoD Organizations Track and
Control FSCAPs Appropriately
The DoD and the FAA jointly will initiate action to ensure that the
public sector or other organizations obtaining FSCAPs track and control
them to equivalent standards of the DoD.
The Task Force reviewed the planned steps for implementation of the
DoD/FAA program with respect to surplus military parts and concluded that
this program adequately addresses their concerns relating to SUPs, and that the
planned steps are compatible with the recommendation of the Task Force, as
found in this document. It will be important for the proposed National SUPs
Program Office to maintain an understanding of the surplus military parts
program and its implementation progress to provide information to
Regional/Directorate SUPs Coordinators as well as field offices involved in
SUPs investigations.
FAA guidance for undocumented parts is applicable to surplus military parts as
well as parts from other sources. If surplus military parts have a dual use but
the documentation is not complete, certificate holders under 14 CFR Parts 121,
125, 127, 129, 135, and 145 may use the procedures outlined in draft AC 20-

XX to develop a system/plan for making a determination of conformity or
acceptability for aircraft parts at receiving inspection and for current
inventories when parts documentation is not sufficient to establish that the parts
were manufactured in compliance with Part 21 or previously determined to
meet the requirements of Part 43 by an appropriately rated certificate holder.
These may include parts manufactured for and used by the DoD.
The Task Force is concerned that the planned program may not be
implemented; however, it did not develop a specific alternative. If the DoD
program is not implemented, the FAA should develop its own program.
6.10 SUPs Case Files/Records

Issue: SUPs case files are retained in multiple locations, making it difficult to
review technical information or analyze historical cases.
Recommendation: The SUPs investigation process should explicitly require
that all field office case files be transmitted to the Regional/Directorate SUPs
Coordinator for consolidation (if necessary) and then transmitted to the Data
and Analysis organizational element of the National SUPs Program Office.
Appropriate guidance material and training should reflect this procedure.
Discussion: One of the problems encountered by the FAA with investigation
and analysis of SUPs is that critical technical information is maintained in a
number of field and headquarters offices. Even after the field investigation
portion of the SUPs case is completed, the records related to the case are not
consolidated and maintained in one location. This situation is particularly
troublesome when the FAA is responding to a request made under the Freedom
of Information Act (FOIA).
In most cases, a SUPs investigation is performed by one field office; however,
there may be instances where several field offices within one region are
involved in an investigation, and cases where more than one region participates
in the case. Consequently, it is possible to have important investigation
information in several locations. The proposed organization and process for
SUPs investigations would involve a national office, a Regional/Directorate
coordinator, and at least one field office. Case files at these various locations
would contain duplicate materials, and it is likely that no file would contain a
comprehensive set of information during the FAA investigation phase.
The Task Force considered the experience gained in managing the current
SUPs case files and the advantage of having a centralized records system for
subsequent analysis. With the added incentive of simplifying the response to
an FOIA request, the Task Force concluded that all case files should be
consolidated and stored in the national office once the field office(s) concluded
its responsibilities with a SUPs investigation. The case may or may not be

closed, depending on what follow-up actions by the FAA or another agency are
pending. Related information, such as enforcement files, would be handled as
it is today and not included in the SUPs file.
Responses to FOIA requests related to a SUPs investigation would be handled
in the same manner as any other FOIA request; however, the proposed process
would ensure that once records are accessible through a FOIA request, they
would be relatively easy to assemble and copy.
6.11 Salvageable and Scrap Parts

Issue: When an aviation part is no longer eligible for installation on an
aircraft, and the owner wishes to dispose of it, the part may be: 1) salvageable
as an aviation part, 2) useful only in a nonaviation application, or 3) of no value
except for its base material. In any case, there are economic considerations that
must be weighed against potential aviation safety impacts if parts of this type
are not carefully identified and controlled. This issue is complicated by the use
of terms such as “scrap” and “unsalvageable,” which do not have a consistent
meaning to all who use them.
Recommendation: The FAA should take necessary steps to ensure that once
aviation parts are classified as “salvageable,” they are properly controlled, and
that “scrap” parts are destroyed to prevent their re-entry into the aviation
system.
Discussion: There have been a number of examples of parts that were
discarded by the owner, marked as scrap, and disposed of through a junk dealer
that were subsequently found back in the aviation system, having been
“restored” using unacceptable methods or by unqualified people. Concerns
over the use of scrap parts have been highlighted in recent congressional
hearings and news media reports. The Task Force recognizes potential current
legal obstacles to mandatory destruction of property that is aviation scrap
material, but considers it vital that such material be stopped from returning to
aviation use, either inadvertently or through deliberate action by unscrupulous
persons in the industry. This may require rulemaking action. While
recognizing ownership prerogatives, the FAA should immediately encourage,
through advisory material, all who possess scrap parts to destroy those parts
before releasing them into commerce.
AC 21-38, Disposition of Unsalvageable Parts and Materials (July 5, 1994),
describes “unsalvageable” parts in terms of criteria very similar to those
associated with the term “scrap” in these public discussions. The terms “scrap”
and “unsalvageable” do not have the same connotations to everyone;
consequently, the following discussion focuses on the concepts of parts that:
1) may have future aviation value, 2) may have value in only a nonaviation
application, and 3) should be altered in such a way that they cannot practically

be reused in aviation, either inadvertently or through deliberate
misrepresentation.
Salvageable aviation parts are unserviceable (or of unknown status) but, from
an economic point of view, have potential value in an aviation use.
Consequently, they may be worth storing until restored to an airworthy
condition (i.e., in conformity with the type design and in a safe condition for
operation), or until they are shown to be airworthy with adequate
documentation and/or testing. A second type of salvageable part would be one
that cannot be made airworthy at the time it is stored; however, there is reason
to believe that it is likely to have future aviation value. For example, a part that
has reached a life limit may be stored in anticipation of an increase in that limit
based upon in-service experience and analysis, or a part that requires repair for
which there is currently no approved process may be stored in anticipation of a
new approved process. As found in AC 21-38, reasons why a part may be
unsalvageable include:
• The part has nonrepairable defects (whether visible to the naked eye
or not).
• The part is not within the specifications set forth by the approved
design and cannot be brought into conformance with applicable
specifications.
• Further processing or rework cannot make the part eligible for

certification under a recognized certificate holder’s system.
• The part has undergone unacceptable modification or rework that is

irreversible.
• The part has a life limit that has been reached, or has missing or
incomplete records.
• The part is a primary structural element (or similarly, structurally
significant item) removed from a high-cycle aircraft for which
conformity cannot be accomplished by complying with the
applicable aging aircraft ADs.
No matter what type of salvageable part is being considered, it is clear that it
must be completely identified, its status well documented, and any disposal or
storage controlled.
The concept of scrap parts, in the opinion of the Task Force, is only slightly
different from that of salvageable parts in that the owner has decided to dispose
of them for whatever reason, and in most cases the owner believes they have
relatively little value. Scrap parts may also be considered in different
categories: 1) parts that have no value except for the base material, 2) parts that
are typically used in safety critical aviation applications and may have future
use in a nonaviation application, 3) parts that are typically used in aviation

applications that have relatively low safety impacts if they fail, and 4) parts
whose misuse in aviation poses an insignificant safety risk. Consideration
should be given to requiring that parts in the first two categories be mutilated or
altered so that it is not feasible or economically reasonable to return them to
aviation use or even represent them to be appropriate for aviation use.
The Task Force recognizes there is a significant potential problem with such a
requirement to destroy property, but believes that the potential safety benefits
are such that this option, nevertheless, should be considered. Although scrap
parts may lack aviation value, they still may be considered useful for other
purposes, such as for ground power stations. Given that they are private
property, it may be difficult to mandate that scrap parts be destroyed if their
owners deem them to have value beyond their basic material content. The Task
Force considered the possibility of requiring only that scrap parts be indelibly
marked as scrap; however, it concluded that such measures could be inadequate
if unscrupulous dealers sought to disguise and misrepresent the parts and sell
them for use in aviation. The Task Force believes that, in many cases, the
safety needs outweigh private property interests. However, study of the
potential impacts of mandating destruction of private property in terms of any
required legislation or regulatory changes was beyond the scope of the Task
Force effort.
Parts that fall into the latter categories 3) and 4) listed above need not be
destroyed. However, it continues to be very important to completely document
such parts to minimize the risk of inadvertent misuse.
6.12 Removal of “Unapproved Parts” From the

System
Issue: The Task Force believes all “unapproved parts” should be removed
from aircraft as soon as practicable. A removal process must recognize that not
all “unapproved parts” pose the same risk to safety. Furthermore, the Task
Force believes that the FAA and the industry should have a goal of removing
all “unapproved parts” from the aviation system, whether they are installed on
an aircraft or not.
Recommendation: Establish a procedure for removal of “unapproved parts”
from aircraft parallel to the current MEL process for parts with a criticality
level of 1 or 2 that are listed on the current MEL for a specific aircraft. For
parts with a criticality level of 3, establish an Administrative Control Item, as
defined in the preamble and definitions in existing MEL documents.
“Unapproved parts” that may be in the inventory and not on aircraft should be
removed from the inventory and segregated to preclude access by personnel
that may inadvertently install an “unapproved part.” These new processes
should be formally incorporated into operators’ maintenance manuals.

Guidance should be developed for distribution to the industry and FAA field
offices that defines the details of this process as well as the level of acceptance
required by the FAA.
Discussion: The recommendation of the Task Force is predicated on the
acceptance of certain “unapproved parts” being treated in the same manner as
inoperative “approved parts.” Today, an inoperative “approved part” can
remain in service for a predetermined amount of time if the part is listed in the
MEL for the aircraft. By extending the process to “unapproved parts,” if listed
in the MEL, the unnecessary grounding of the aircraft could be averted with no
impact on the safety of the operation. The MEL procedures and philosophy are
proven and well understood by the industry and the FAA. The Task Force
believes that using the MEL process for controlling and ultimately removing
“unapproved parts” is appropriate, reasonable, and provides an equivalent level
of safety.
Once a part that may be installed on aircraft is identified as an “unapproved
part,” the aircraft operator must:
1. Locate every such part through a review of records or other
verification procedures that might include physical inspection of the
aircraft.
2. If the “unapproved part” has a part criticality of Category 1 or 2, a
process parallel to the MEL procedures should be followed if that
part is currently listed in the MEL for the aircraft. (See Section 6.8
of this report for a discussion of part criticality categories.) This
would include complying with any maintenance or operational
procedures and/or limitations that would be required by the current
MEL. The time limitations specified in the MEL for removal of the
part in question must also be complied with. Any Category 1 or 2
“unapproved part” not listed in the current MEL must be removed
and replaced since no MEL exists that authorizes the part to remain
installed for any period of time.
Note that the FAA, after its review of part criticality and the potential impact
on safety, may issue an AD for removal of the part. This option is always
available and would be exercised as it is today for any safety critical
problem, whether related to a part or not. Also, as is the policy today, an AD
would override any MEL process for an unapproved part.
It is also important to note that, through the normal process of engineering
analysis and test (if necessary), there are methods whereby a technically
“unapproved part” could be found to be in compliance with the Type Design
of the aircraft. One such method would be the issuance of a Supplemental
Type Certificate by the FAA, which would include the part in the modified
type design and therefore make it “approved.” The STC process also
demonstrates that an equivalent level of safety is maintained.

3. If the part has a part criticality of Category 3 and qualifies as a part
that could be controlled using the Administrative Control Item
process as described in the MEL, the operator must use that process
to schedule the removal and replacement of the part in a manner that
would be appropriate and provide for an equivalent level of safety.
In no case should the “unapproved part” be allowed to remain
installed beyond a scheduled maintenance inspection interval where
the part could be removed and replaced without incurring a
substantial adverse operational impact.
4. For “unapproved parts” that may be in the inventory but not on
aircraft, the operator must have a process in place, acceptable to the
FAA, that would segregate these parts, when identifiable, from that
inventory that is accessible to personnel who might install the part
on a aircraft. In all instances where “unapproved parts” can be
identified and located, they must be purged from the system.

7.0 Information Systems Strategy
Issue: An improved, more comprehensive information system is required to
adequately support the SUPs Program.
Recommendation: Immediately initiate an abbreviated user requirements
study and functional systems requirements analysis so as to more fully develop
user and functional requirements for a PRS. Proceed with system design,
development, and implementation. Explore the feasibility of sharing
cost/design functions with other agencies with a critical interest in a national
PRS and define the requirements for and establish a bulletin board system for
public access.
Discussion: A prototype SUPs database system was implemented after final
programming changes were made in September 1994. The purpose of the
system is to provide a facility capable of storing and retrieving SUPs case
information. The system was designed to respond to management requirements
for SUPs information. The system does not adequately support the field
investigators, nor is it designed to facilitate case and data analysis. Repeated
audits of the SUPs database reveal that, although the system is useful in
tracking SUPs investigations, there continue to be flaws in the data, the sys-
tem’s capabilities to track certain data, and the ability to generate certain
management reports from the system.
A particular weakness in the prototype system are the limitations regarding
tracking multiple status, such as if more than one company is involved in the
investigation or if more than one office or agency is conducting simultaneous
investigations. Additionally, there are few data edits and a weak quality control
process to ensure that information forwarded for data entry is accurate and
complete.
The DOT/OIG has underscored the importance of the SUPs database in
obtaining statistical information and aiding investigations. The OIG’s main
findings were:
• SUPs case investigations are not consistent and complete.
• Not all SUPs notifications submitted to the FAA are recorded in the
database and processed as SUPs cases.
• SUPs program management controls do not ensure that the database

accounts for additional SUPs found as a result of SUPs
investigations.
7.0 Information Systems Strategy 7–1

• FAA field offices did not update FAA headquarters on results of
investigations on a timely basis.
• Key data elements of the SUPs database are incorrect.

In June 1995, an internal assessment of the SUPs prototype database revealed
that, although a prototype, the database is being used as an operational system
for tracking SUPs investigations for the field and as a management information
system to answer questions asked at FAA headquarters. The quality of the data
and other system inconsistencies require extreme caution in the use of the
information provided from the prototype system. The database limitations
include: the ability to report on a company only if it is the primary focus of the
investigation; the lack of connecting data between related cases; and the
inability to track individuals as opposed to companies. The new SUP Status
Report (FAA Form 8120-12) is designed to report the progress or closure of a
SUPs case. It provides management with a snapshot of a case by providing
instant information on the case status and provides final investigation results.
However, the SUPs Status Report, as designed, is cumbersome when dealing
with subsequent parts and requires a relatively high data-entry workload to
enter multiple parts.
Basic Requirements
The SUPs Task Force identified that the quality and availability of SUPs data is
a key issue. This includes data being made available to the public. Public data
could be available on a bulletin board system (BBS) and could include
information about companies that are PAHs as well as information regarding
results of investigations that may be pertinent to aviation safety or the industry
at large. FAA data issues include categorizing SUPs cases, determining case
priority, tracking SUPs, and producing information regarding persons that hold
a PMA.
The SUPs Task Force identified information requirements (discussed in
Appendix E regarding the PRS) that the National SUPs Program Office must
address, and found that the information needs to go beyond the current SUPs
prototype database, because the new system should capture and clearly
distinguish the types of suspected “unapproved parts.” The Task Force
considers it vital to distinguish between different types of SUPs because the
appropriate response differs — both at the local level, where investigations are
conducted, and at the regional and national levels, where trends are monitored.
Furthermore, because the information needs addressed in the new system
would contain numerous types of information designed to help investigators
and policy makers, including links to other information systems, the proposed
information system would be much broader than the current prototype SUPs
database. Thus, a new information system should be considered a PRS.
The improvement of the data system, the need to standardize and stabilize the
data, and the capability to track and cross-reference all required information is
7–2 7.0 Information Systems Strategy

critical to the success of the SUPs program. An abbreviated user requirements
study and functional systems requirements analysis should be conducted by
personnel knowledgeable in both disciplines, automation and aviation, so as to
more fully develop user and functional requirements.
System Requirements
The FAA must review the current prototype system, identify transition
strategies, and develop the requirements for a national parts information
system. The need to interface with other government and commercial agencies
led the Task Force to the recommendation of exploring the feasibility of
sharing cost/design with other agencies involved, such as the DOT/OIG, DCIS,
and other law enforcement agencies, especially the Department of Justice. The
FAA would volunteer to be the lead agency in such a multi-agency initiative.
Generally, the system must be designed to operate in concert with existing
technology and communications (such as the AVR data warehouse concept).
System access must include all offices and agencies involved in SUPs reporting
and investigation, and read-only or bulletin board access to industry and
commercial activities.
The need to limit certain access to all SUPs activities would require system
security capable of providing only the access required by or permitted to each
user of the system while protecting certain information from unauthorized
access. The security system would also control data entry, modification, and
deletion. The Task Force believes that the Database Administrator (DBA)
functions should be assigned to the FAA National SUPs Program Office Data
and Analysis organizational element.
The system must be designed with point-and-click, mouse- and Windows-type
user interface. The system environment must include on-line tutorials, on-line
content-sensitive help functions, and pop-up windows with input selections
readily available. Links into other systems (such as Vital Information System),
the use of look-up tables, and data-entry interactive edits would be used to
ensure, to the maximum extent possible, that the data entry is standardized and
complete. Links to other systems, such as the Program Tracking and Reporting
System (PTRS), the Enforcement Information System (EIS), and the Safety
Performance Analysis System (SPAS), must be established. Links into other
systems would eliminate redundant data entry and provide key information,
such as “red flags” in SPAS, to alert FAA organizations of problems that are
developing. Field data entry must be developed so that it ensures timely entry
of new reports of cases and current updates of status reporting. The system
must capture determinations made during the course of an investigation (such
as the criticality of a specific part) so that information is immediately available
to subsequent investigation relating to the same or similar parts. The data
quality must be maintained at a high level through these various system design
features if the PRS is to be effective.
7.0 Information Systems Strategy 7–3

Information Requirements
The Task Force developed a list of basic information needs for the PRS. This
analysis of information requirements was accomplished using the Task Force’s
own views of required outputs, based on field experience as well as SUPs
database experience. The Task Force also reviewed requirements information
previously developed to ensure completeness. The review included the results
of the FAA SUPs Program Planning Meeting held in Seattle April 11–13,
1995; lessons learned from the current prototype SUPs database system; and
considerations addressed in draft Form “8120.XX,” which is a proposed
revision of Form 8120.12, now under review.
PRS requirements were worked from the lowest level, i.e., the SUPs
investigator level, because the Task Force believes that if the detailed
information requirements of the investigator can be satisfied, then the majority
of requirements at the management levels would also be satisfied.
The Task Force first developed information requirements for reporting SUPs
cases. All of the information may not be available on the initial contact, but the
system should be capable of capturing all of the information, and there should
be some tools (automated or desktop aids) to assist the persons receiving an
initial report to ask all necessary questions to ensure complete data entry. The
Task Force identified the information needed for an investigator to begin the
case investigation (see Appendix E). Then, the requirements for
Region/Directorate and national headquarters were identified. Generally, the
most important requirement was the ability to summarize data that already
existed within the system. The requirements of the National SUPs Program
Office differed from the inspector’s needs in that this office would be
responsible for analysis, information dissemination, and inter/intra-agency
coordination. The program office would also most likely coordinate FOIA re-
quests, congressional inquiries, and other governmental inquiries.
7–4 7.0 Information Systems Strategy

8.0 Relationships With Law
Enforcement Agencies
Issue: Policies on the FAA’s working relationships with government agencies
investigating criminal cases related to “unapproved parts” need review and
clarification. Major issues include identifying points of contact, notification of
cases, information sharing, and, as addressed in Section 9.0, improved training
of the FAA workforce on criminal aspects of SUPs investigations.
Recommendation: The FAA should clarify its intended working relationships
with law enforcement agencies, and facilitate these agencies’ access to the
FAA, as well as FAA access to law enforcement agencies, while maintaining
appropriate coordination with the FAA Office of Civil Aviation Security and
the DOT/OIG.
Recommendation: The FAA should work with law enforcement agencies to
develop and maintain standard operating procedures that would facilitate work-
ing relationships between FAA inspectors and those agencies, recognizing the
importance of both law enforcement and aviation safety protection.
Recommendation: The FAA should provide timely, simultaneous notification
of SUPs cases to all interested law enforcement agencies, and the memoranda
of understanding with those agencies should address when law enforcement
agencies should notify the FAA of SUPs cases they are pursuing in recognition
of the FAA’s safety responsibilities.
Discussion: Some of the most serious threats to safety related to unapproved
aeronautical parts involve criminal offenses, such as counterfeit parts and
fraud. The FAA can provide substantial technical expertise to assist law
enforcement agencies in their investigative work on unapproved aeronautical
parts. It is important that the FAA, in carrying out its safety responsibilities,
work cooperatively with law enforcement agencies through improved
communication and understanding of each others’ functions.
The Task Force held several productive meetings with law enforcement offi-
cials of the primary agencies that conduct “unapproved parts” investigations.
These officials represented the FAA Office of Civil Aviation Security, the
DOT/OIG, the Department of Justice, the FBI, the DCIS, and the USCS. The
Task Force and the law enforcement agencies exchanged information on how
the FAA could better cooperate with the law enforcement agencies. The agen-
cies responded with candid and detailed observations, offered to assist the FAA
8.0 Relationships With Law Enforcement Agencies 8–1

in inspector training, and expressed an interest in a comprehensive database
that would be helpful to all law enforcement agencies.
The law enforcement representatives described a history of inconsistent
working relationships with the FAA. At the local level, they stated that they
often enjoyed extremely close working relationships with FAA inspectors, but
not in all areas.
The key policy question that law enforcement officials recommended the Task
Force address was clarification of the FAA’s position with respect to SUPs cas-
es in general, and consequent standardization of investigation procedures for all
FAA personnel. The officials requested that the FAA speak with “one voice”
in regard to SUPs policy and technical issues. This issue is being addressed
directly through the reaffirmation of FAA SUPs policy in the statement in
Section 2.0, and through the formation of the National SUPs Program Office
proposed in Section 4.0 of this Program Plan.
Secondly, the law enforcement officials sought clarification and change with
regard to their working relationships with the FAA. Essentially, they sought
more flexibility for direct contact with FAA inspectors at the local level, as well
as a centralized point of contact at the national level. Currently, FAA policy is
to direct all FAA external law enforcement contacts through the FAA Office of
Civil Aviation Security, which in turn is required by a policy agreement to
exclusively contact the DOT/OIG as its intermediary to outside law enforce-
ment agencies. Certain law enforcement agencies have found that these strict
channels inhibit their ability to develop long-term working relationships with
FAA inspectors at the local level.
Law enforcement agencies tend to prefer to work with the same FSDO- or
MIDO-level inspectors over time. This permits the inspectors to gain experi-
ence and training in the criminal investigation process, develop a level of confi-
dence with the law enforcement agencies, and improve efficiency in the pro-
cess. The agencies prefer to work with fewer inspectors to enhance this
specialization and long-term working relationship, and to minimize concerns
regarding confidentiality of investigation information.
Creation of the National SUPs Program Office would address the issue of a
centralized point of contact. The Task Force also agrees that direct contact
between law enforcement agencies and FAA local offices should be facilitated.
A point of contact should be established for law enforcement agencies in the
local office, and this should start as the office manager. The office manager
would have the option of delegating this responsibility. Contacts with law
enforcement agencies initiated by inspectors should be coordinated initially
through the Regional/Directorate SUPs Coordinator; which might change
during the course of an investigation, when a working relationship could
develop between the law enforcement investigators and the local office. The
Task Force believes that ACS should continue to receive prompt notification of
law enforcement-related contacts by FAA inspectors. ACS should be ready to
8–2 Relationships With Law Enforcement Agencies

support and assist in any way possible when requested. The FAA must
maintain clear procedures for determining which law enforcement agency to
call under given circumstances. Although the FAA may continue to contact the
DOT/OIG initially, this would not preclude directly contacting other law
enforcement agencies as well, when it is deemed necessary.
In a related issue, the law enforcement agencies also requested that the FAA
provide them with prompt notifications of new SUPs investigations. The Task
Force believes that the FAA should simultaneously provide SUPs case
information to all interested law enforcement agencies as rapidly as possible.
All law enforcement participants meeting with the Task Force appeared to find
such a procedure acceptable. The Task Force envisions that the database dis-
cussed in Section 7.0 of this Program Plan would have the capability of sharing
such information almost instantaneously.
The law enforcement officials also pointed out that normal FAA inspection and
surveillance techniques are not appropriate in cases of fraud or other criminal
activity. They pointed out that FAA inspectors typically provide advance
notice of their inspections to operators. This may not be a problem in the case
of operators not engaged in criminal activity, but those who often use the
advance notice to move their counterfeit parts, fabricate records, or otherwise
conceal their activities. This issue is addressed through the training proposals
contained in Section 9.0 of this Program Plan.
The Task Force recognizes the need for developing standard operating
procedures and/or additional training to help inspectors perform investigations
in conjunction with law enforcement agencies. Procedures would address such
issues as when the FAA should notify a law enforcement agency and which
one, when law enforcement agencies should notify the FAA of SUPs cases,
how to handle sensitive information, and others. The Task Force has initiated
meetings with representatives of law enforcement agencies to develop these
procedures, and the Task Force recommends that the National SUPs Program
Office continue these meetings and formalize and refine the procedures as
required. It may be advisable to capture these procedures in a memorandum of
understanding. These procedures should reflect a recognition that the FAA’s
first priority is aviation safety, and law enforcement agents should have an
understanding of when to notify the FAA of cases they are pursuing, in the
interests of protecting aviation safety.
8.0 Relationships With Law Enforcement Agencies 8–3

8–4 Relationships With Law Enforcement Agencies

9.0 Training
Issue: Inspector training must help inspectors identify suspected “unapproved
parts,” conduct investigations that satisfy FAA safety and enforcement
responsibilities, and work with law enforcement agencies.
Recommendation: Provide interim SUPs policy and procedures training to
AIR and AFS maintenance inspectors and other personnel. Deliver this
training via electronic means to ensure rapid delivery and supplement it with
publication of a comprehensive “Inspector’s Guide to Suspected Unapproved
Parts.”
Recommendation: Begin immediately to develop the formal, more detailed
training element of SUPs policy and procedures for implementation
concurrently with the establishment of the National SUPs Program Office, and
follow up with the DOT/OIG, DCIS, and the FBI to obtain training offered by
those agencies for FAA inspectors.
Recommendation: Based on formal training courses, develop computer-based
instructional programs and make them available to inspectors at their local
offices for use in reinforcement training.
Discussion: Currently, inspector training is geared toward surveillance,
inspection, and enforcement actions in connection with producers of aviation
parts and users of aviation parts. Inspector activity primarily addresses
production systems and processes, quality control, repair facilities and
processes, and recordkeeping. Inspector training is similarly oriented.
Relatively limited specialized SUPs training is conducted and only limited
training has been offered to help inspectors recognize indications of fraudulent
activity with regard to parts’ status and documentation. In the short term,
inspectors also need assistance in sorting out potentially inconsistent guidance
material.
The Task Force considered the training necessary for managers and inspectors
on the various aspects of FAA SUPs investigation, which also must be
provided to current and future inspectors as well as managers. These aspects
include emphasis on the proposed SUPs policy; changes to routine inspection
and surveillance procedures to detect SUPs; improved training on indicators of
fraud or other criminal activity; training on the FAA’s role in SUPs in relation
to other agencies, particularly law enforcement agencies, in coordination with
the national office and Regional and Directorate SUPs coordinators; and gen-
eral training on procedures for investigating SUPs during and after the es-
tablishment of the National SUPs Program Office.
9.0 Training 9–1

To meet these training requirements, the Task Force developed a recommended
three-pronged approach to SUPs training:
1. Interim training
2. Formal training
3. Reinforcement training.
Interim training would commence throughout the FAA as soon as possible after
acceptance of the Task Force’s proposals by the Regulation and Certification
Organization. This training would address the policy statement, which the
Task Force believes should be posted conspicuously throughout FAA offices
just as other high profile policy statements are emphasized. Interim training
also would address current FAA SUPs policy, guidance, and regulations as
they continue to affect how investigations are conducted. This training should
address critical definitions, and the roles of MIDO, FSDO, engineering, and
other FAA personnel in the SUPs investigation process. The interim training
should also inform FAA personnel about the new National SUPs Program Of-
fice, how it would function, and the planned reporting relationships between
the field and the national office. The training would emphasize the technical
support and policy guidance capabilities planned for the Technical Support
organizational element of the National SUPs Program Office.
The interim training program would be directed at all AFS maintenance
inspection personnel, all AIR personnel, and supervisory and management
personnel. Training also should be available to AGC and ACS personnel. This
training could be delivered during a 1-hour video presentation, possibly via
interactive video teleconferencing (IVT), to ensure rapid communication
throughout the agency. In addition, the Task Force recommends that the FAA
produce immediately an “Inspector Guide to Suspected Unapproved Parts.”
This Guide should address FAA policy, provide clear definitions and
explanations of terms and concepts involved, explain the FAA SUPs program
as described in FAA Order 8120.10, and delineate steps to follow when
“unapproved parts” are discovered to ensure that the parts are not used and that
enforcement action is taken when appropriate. This Guide should assemble in
a single document copies of applicable portions of current ACs, Orders,
Notices, and other relevant guidance material, and a list of the most relevant
regulations. The Guide should also provide telephone numbers of offices that
can provide further assistance until establishment of the National SUPs
Program Office.
Formal training on FAA SUPs policy and procedures would provide inspectors
with far greater detail than the interim training element. Formal training would
be implemented when the National SUPs Program Office has been established
and details of new procedures have been determined. The training would be
provided to classes that include both AIR and AFS personnel. This joint
training approach would emphasize the cross-disciplinary nature of SUPs
9–2 9.0 Training

investigations and standardize the two services’ procedures, methods, and prac-
tices. The training would address at least the following issues:
• Parts approval processes (including material from current AIR

training programs)
• Options permitted by the regulations for owner-produced parts or

fabrication of parts for repairs
• The limits of field approval authority as related to parts approval;

i.e., reinforcement of information already provided in training, but
with a SUPs perspective
• Definitions
• Roles and responsibilities of inspectors, the Regional/Directorate

SUPs Coordinators, and the National SUPs Program Office
• Roles and responsibilities of law enforcement agencies, and policies

and procedures for FAA inspectors to interact with those agencies
• Indicators of fraud or other criminal activity
• Interview techniques
• Considerations in obtaining parts evidence in FAA enforcement

actions and related law enforcement requirements
• Sensitivity and confidentiality of information, conflict of interest,

and the legal process
• Other aspects of FAA investigation and enforcement procedures,

including proper interaction with FAA enforcement attorneys and
other offices, and when to request assistance of other offices or law
enforcement agencies
• Development and approval of manuals that contain procedures for

identifying SUPs during receiving inspections for certificate holders
• The utility and limitations of the Illustrated Parts Catalog (IPC) or

similar parts manuals in determining whether parts are “approved
parts”
• Undocumented parts substantiation procedures for both the operator

and the FAA, as outlined in the Parts Approval Action Team
(PAAT-III) procedure (proposed AC 20.XX)
• Procedures for disposing of scrap parts
9.0 Training 9–3

• Processing procedures for SUPs cases, including use of the
database, and initial and continuing information requirements
• Policies and procedures for responding to requests under the FOIA.

Curricula should emphasize use of examples and actual closed cases to help
inspectors form a base upon which to make decisions. Classroom groups
would conduct case studies and determine the appropriate classification of each
SUPs example. The FAA should accept offers the Task Force received from
the DOT/OIG, DCIS, and the FBI to assist in providing training blocks to
inspectors. Guidance and training should note that inspectors should contact
FAA enforcement attorneys early in the process rather than wait until the
investigation is completed. (FAA Order 2150.3A, Compliance and
Enforcement Program, should be reviewed to provide more complete
guidance).
The formal SUPs training modules could be added to existing courses such as
Aircraft Certification Indoctrination and Airworthiness Inspection,
Certification, and Surveillance of Foreign and Domestic Repair Stations. Costs
to develop a SUPs module that would be included in the current formal training
courses would be approximately $250,000. An alternative delivery process
would be to have a training team travel to various field sites presenting the
material included in the SUPs training module, instead of having all trainees
travel to one location.
The third element of the training approach would be reinforcement training.
The Task Force considered describing this as recurrent training, but did not
want to impose a regularly-scheduled training requirement. Rather, the rein-
forcement training envisioned would be interactive computer-based instruction
that would be used on an as-needed basis at the field office level. The
reinforcement training would summarize formal training course information
and would also be useful to inspectors researching policy or procedures during
an investigation. The Task Force estimates that a SUPs CBI module would
cost approximately $30,000 to $50,000 to develop and disseminate.
The Task Force considered videotaped instructional materials for the formal
and reinforcement training elements, but concluded that tapes do not require
sufficient student participation. The reinforcement training is considered as
much a research tool as training, and therefore should be more “user friendly”
and capable of meeting the needs of the inspector.
9–4 9.0 Training

10.0 Implementation
10.1 Transition Issues

This section outlines the basic steps the Task Force believes the FAA should
take to begin implementing critical aspects of the SUPs Program Plan. Some
of these can be taken even before the proposed National SUPs Program Office
is established. The goal should be to have a National SUPs Program Office
established and staffed within 90 days of the start of the transition process. The
Task Force believes that the transition can begin almost immediately and could
be governed by the following:
1. Issue Policy Statement — The SUPs Policy Statement should be issued
as soon a possible and should be posted conspicuously throughout FAA
offices just as other high profile policy statements are emphasized.
2. Explain Transition — A memorandum should be sent to all AFS and
AIR field offices, all Regional Flight Standards and Directorate
management, all Regional/Directorate SUPs Coordinators, all Assistant
Chief Counsels for Regions, and all ACS regional offices explaining the
transition plans.
3. Establish Transition Staff — Within 60 days, AIR and AFS staff (at
least two from each service) should be “detailed” to an office at Dulles
Airport, which would be designated as the SUPs Office. This office
would develop the structure of the new Program Office based on this
Program Plan and would evolve into the organization that is described
in Section 4.0 of this document. The core transition team detailed to the
Dulles office would be augmented with temporarily assigned personnel
to provide additional technical assistance. These additional resources
need not be located at Dulles and they need not be full time; however,
they and their managers should agree to assign a high priority to
assisting the National SUPs Program Office development. Given the
communications systems available, it is feasible to make use of
resources anywhere in the FAA system and begin the transition process
as soon as the core group is in place at Dulles.
4. Task Force Support — Guidance for developing the national office
throughout the process would come from the Task Force that produced
this Plan. This would ensure consistency and continuity with the Task
Force vision for the office. It would also ensure that the analysis
10.0 Implementation 10–1

underlying the Task Force recommendations is available to the new
office staff. Even after a SUPs Program Manager is in place, the Task
Force members would continue to provide guidance and assistance as
needed. Task Force members may also work directly with the initial
staff of the Technical Support organizational element for a brief period
to help implement that function quickly.
5. Transition Team Immediate Actions — The interim office would
immediately begin the following tasks:
• Provide a single voice on SUPs policy;
• Function as a central source to explain terminology and procedures,

provide technical assistance to the field, the industry, and law
enforcement agencies; and
• Oversee the upgrades of the existing SUPs database and the

development of the new PRS.
• Along with AGC, develop an appropriate surveillance and

enforcement strategy within the framework of existing regulations
and guidance, and determine the best way to convey this strategy to
field offices.
The personnel in this interim office would have two top priorities:
1) ensure that the FAA policy of uniform and vigorous SUPs
enforcement is clearly understood within the FAA and externally, and
2) establish the national office under the direction of the Program
Manager as soon as that position is filled.
6. Law Enforcement Relationships — Initiate meetings with law
enforcement agencies to formalize standard operating procedures and
draft Memoranda of Understanding, if appropriate.
7. Interim Training — Initiate the interim training program as described
in Section 9.0 of this Plan. This would include obtaining training
materials and assistance from law enforcement agencies. The interim
training should address:
• SUPs policy, related regulations, and investigation procedures
• Roles and reporting relationships of the MIDOs, FSDOs,

engineering, SUPs Coordinators, and the National Program office
personnel
• Terminology
• The Technical Support function of supporting field inspectors by

providing consistent quick responses to technical questions
10–2 10.0 Implementation

• How to use the existing guidance material and sort out the
conflicting information with regard to SUPs
• Requirements to train the ACO personnel in the revised process that

would be used to determine part criticality and how the classification
of part criticality would be used.
Interim training would be directed at all AFS maintenance inspection
personnel, all AIR personnel, and supervisory and management
personnel. Training also should be available to AGC and ACS
personnel.
Some of the transition training can be delivered through a video
presentation to ensure a quick dissemination of information required at
the beginning of the transition period. In addition, the Task Force
recommends that the FAA immediately produce an “Inspector Guide to
Suspected Unapproved Parts.”
As part of an orientation program, Regional and Directorate SUPs
Coordinators should be detailed for a brief period to work in the new
SUPs Program Office after it is established. This would provide an
immediate understanding of the new office functions by the
coordinators and encourage teamwork between the field offices and the
national office.
8. Information Systems — Until the new PRS is implemented, the current
SUPs database should be maintained and improved as planned. Some
improvements have been completed, including adding new fields and
updating the data entry screens. Also, approximately 80 percent of the
redesign of the SUPs form has been accomplished. These
enhancements to the current system should be completed during the
transition phase, since they can be directly used in the new system.
Also, as soon as possible, the FAA should initiate a user requirements
study to define the data and system requirements for the new PRS as the
first step in implementing the new information system. The user
requirements analysis should include consideration of the needs of law
enforcement agencies and the aviation industry.
10.2 Implementing the Principal

Recommendations
The Task Force reviewed the recommendations and consolidated them into a
set that represents its principal subjects of concern. The Task Force then
developed a collective opinion as to the relative priorities and the office that
would be primarily responsible for ensuring that the tasks associated with each

recommendation are completed on schedule, and what priorities that office
should have. There may be one or several other offices involved in the
implementation; however, only the office of primary responsibility was
identified.
The task force also estimated time periods and/or key milestones for the
principal recommendations. In some cases, such as rulemaking, a realistic
timetable is measured in years; however, it is important to note that the
estimated end date may or may not be a reflection of priority. Priority is a
measure of relative importance rather than a measure of how quickly a
recommendation can be implemented.
The results of the Task Force’s analysis of the recommendations is shown in the following figure.

Figure 10-1 IMPLEMENTATION SCHEDULE FOR PRINCIPAL SUPs TASK FORCE RECOMMENDATIONS
FY 1996 FY 1997
Office Relative
Recommended Action 1st 2nd 3rd
3rd 4th 1st 2nd 3rd 4th
Responsibility Priority
Immediate Steps:
Receiving Inspection AVR 1
Campaign, Information
Issue a SUPs Policy
AOA-1 1
Statement
ASAP
Establish a National Office AVR 1
Develop SUPs with Law

AVR-20 1
Enforcement Agencies
Issue Guidance Re:
AVR-20 1
Terminology
Expedite Rulemaking Re:
AGC-200 1
Fraud (Final Rule)
Expedite Rulemaking Re:
AFS-300 1
Recordkeeping (Final Rule)
Notify Law Enforcement
AVR-20 1 On Going
Agencies of SUPs
Training for Inspectors (In
AVR-20 1
Conjunction with Guidance)
Transition Training Formal Training
Set SUPs as Priority (AIR &
AFS-1, AIR-1 1
AFS) Then Add "R" Item
Implemented FY 1996, On Going "R" Items FY 1997
Amend FAR to Require
AVR-20 1 Q1 FY 1999
SUPs Reports
Parts Reporting System AVR-20 1
Requirements Analysis System Development & Implementation
Establish Procedure to
Remove "Unapproved AVR-20 1
Parts"
Revise Guidance Material AGC-200,
2
Re: § 43.13, Use of Parts AFS-300
Revise Draft AC Re: AFS-300,
2
Undocumented Parts AIR-200
Revise Guidance Material
Re: § 43.13, Fabrication of AFS-300 2
Parts
Procedure to Centralize
AVR-20 2 On Going
Records
Revise Advisory Material AIR-100,
3
Re: IFCA AFS-300
Review Scrap Parts Issue AIR-200 3
Increase Maximum AGC/AVR 3

Penalties Q1 FY 1999
Legislation on Parts AGC/AVR 3
Seizure
Q1 FY 1999


APPENDIX A — FAA SUPs Task Force
Members
Team Leader:
Nicholas A. Sabatini, FAA Eastern Region Flight Standards Division Manager
(AEA-200)
Team Members:
Loretta Alkalay, Assistant Chief Counsel-Eastern Region (AEA-7)
Kirk Gustafson, Manager, Engine Certification Branch, Engine Certification
Directorate (ANE-141)
Steve Keenley, Manager, Criminal Investigations Division, Office of Civil
Aviation Security Operations (ACO-300)
Glenn A. Lanter, Assistant Manager, System Surveillance and Analysis
Division, Aircraft Certification Service (AIR-300)
Lawrence C. Lee, Manager, Teterboro Flight Standards District Office
(TEB FSDO)
William A. Machado, Manager, Aircraft Evaluation Group (BOS-AEG)
Thomas Martin, Airworthiness Unit Supervisor, Philadelphia Flight Standards
District Office (AEA FSDO-17)
David A. Nott, Aviation Safety Inspector, Production and Airworthiness
Certification Division, Aircraft Certification Service (AIR-230)
Earl Seabrooks, Manager, Manufacturing Inspection District Office,
New Cumberland, Pennsylvania (ANE MIDO-44)
Support Staff:
Chuck Antku, AEA-200X
Lester Bragin, AEA-FRG FSDO-11
Stephen Brice, AEA-7
Jan Henock, AEA-230C
Appendix A A–1
A–2 Appendix A
APPENDIX B — Selected Recent Initiatives
Suspected “Unapproved Parts”
(Note: Certain items described in this appendix also appear in Appendix C of
this Program Plan, which analyzes the potential need for revisions or
cancellations of Federal Aviation Administration (FAA) guidance and advisory
material.)
• Advisory Circular (AC) 21-29, Detecting and Reporting Suspected

Unapproved Parts, (issued August 1991; revised July 1992 to introduce
FAA Form 8120-11, Suspected Unapproved Parts Notification). (Draft
revision under review.)
• FAA Order 8000.74, Approved Parts Seminars, 1993-1994 (150

conducted), to increase awareness in the public and industry of the need to
ensure that only FAA-approved parts are installed on type certificated
products. Other educational programs include a brochure, a decal with the
Aviation Safety Hotline telephone number, and a widely-distributed 20-
minute videotape.
• FAA Order 8120.10, Suspected Unapproved Part Program

(September 28, 1993). Provides additional guidance to all FAA personnel
in processing and investigating Suspected Unapproved Parts (SUPs)
notifications.
• FAA Order 8130-21A, Procedures for Completion and Use of FAA

Form 8130-3, Airworthiness Approval Tag (revised January 3, 1994). This
Order provides guidance concerning the use of the revised Form 8130-3 for
export approval, identification, and conformity determinations of products
or parts thereof for production approval holders.
• AC 21-38, Disposition of Unsalvageable Aircraft Parts and Materials

(July 5, 1994). Provides information to persons involved with the sale,
maintenance, or disposal of aircraft parts, and provides guidance to help
prevent unsalvageable parts and materials from being sold as serviceable
parts.
• AC 21-20A, Supplier Surveillance Procedures, July 25, 1994. This AC

addresses acceptable methods for Production Approval Holders to monitor
their suppliers, and covers direct shipment procedures.
Appendix B B–1
• Prototype SUPs database management system initiated in 1992, including
data for 1989 forward, and final programming changes implemented in
September 1994.
• AC 20-62C, Eligibility, Quality, and Identification of Approved

Aeronautical Replacement Parts; (August 26, 1976); proposed draft
AC 20-62D, August 1, 1995. The AC provides guidance for the installation
of such parts on type certificated products, and information to enable
compliance with applicable regulations.
• FAA Order 8120.XX, Disposition of Unsalvageable Aircraft Parts and

Materials, currently in draft form, would provide information to FAA
personnel who deal with industry persons involved with the distribution,
sale, maintenance, or disposal of aircraft parts and materials. This guidance
would assist FAA personnel in preventing unsalvageable aircraft parts and
materials from being distributed and sold as serviceable parts and materials.
The draft also contains guidance for actions to be taken if unsalvageable
parts or materials are found in parts inventories.
• Parts Approval Action Team (PAAT) established under Notice N8110.44,

September 25, 1992 (also Notices 8110.45, Parts Manufacturer Approval
Under Evidence of Licensing Agreement, and 8110.51,
September 25, 1992; Parts Manufacturer Approval by Identicality, May 13,
1994) to conduct a three-phase program to develop policy and procedures
to expedite approval of Parts Manufacturer Approval (PMA) applications;
address problems with manufacturers unable to show evidence of a
licensing agreement but whose parts were identical to “approved parts;” and
develop policy for evaluating the acceptability of aircraft parts existing
within civil inventories that lack acceptable documentation. Draft
AC 20.XX, under development, would address acceptable methods for air
carriers and repair stations to develop systems for making a determination
of conformity or acceptability of aircraft parts at a receiving inspection and
for current inventories when parts documentation is insufficient to establish
that the parts were manufactured in compliance with Title 14 Code of
Federal Regulations (14 CFR) Part 21, or were previously determined to be
airworthy in accordance with 14 CFR Part 43.
• Federal Register Notice, February 27, 1995, 14 CFR Part 21, Replacement
and Modification Parts, Enhanced Enforcement. FAA Notice 8120.17,
Procedures for processing applications for parts for a PMA as a result of
Federal Register Notice of February 27, 1995.
• Department of Defense/FAA Joint Process Action Team (PAT), plan

adopted July 1995 to address the identification, disposition, and control of
flight safety critical aircraft parts in connection with surplus military parts.
• Maintenance Recordkeeping Requirements Notice of Proposed Rulemaking

(NPRM), under development by the FAA Aviation Rulemaking Advisory
B–2 Appendix B
Committee (ARAC). This proposal would standardize maintenance
recordkeeping requirements and facilitate the transfer of aircraft, airframes,
aircraft engines, propellers, appliances, components, and parts among
owners, operators, manufacturers, and maintenance facilities, by requiring
manufacturers to provide initial certification records, and by ensuring that
standardized data sufficient to document maintenance, preventive
maintenance, rebuilding, or alteration are retained and transferred.
• FAA Part 145 Review: Repair Stations NPRM. This NPRM, currently
under development by the FAA, would propose revisions to 14 CFR Part
145 and reorganize and update the repair station rules. The proposal also
would establish new requirements for repair stations, including manual
requirements, recordkeeping, and personnel. The proposal would add a new
requirement that repair stations’ incoming inspection systems provide for
inspection of raw materials and articles to ensure acceptable quality and,
where applicable, conformity with type design data.
• False and misleading statements regarding aircraft parts: FAA rulemaking

project to prohibit any person from misrepresenting the acceptability of a
part for use in a civil aircraft. The rule would extend the prohibition on
fraudulent or intentionally false statements beyond those now covered by
14 CFR Parts 21 and 43.
• ARAC Parts Working Group. This group will provide definitions for
standard part and commercial part, and develop guidance for third-party
accreditation of production systems for producers of such parts (draft
documents under development).
• FAA Notice 8120.XX, Revised FAA Form 8120-12, Suspected

Unapproved Parts (SUP) Status Report, and Additional
Investigation/Enforcement Guidance. The Notice, currently in draft form,
would introduce the new SUP reporting form and instructions for
completing the form. The Notice also would provide guidance to FAA
personnel for investigating SUP allegations at entities that do not hold FAA
manufacturing or maintenance authority, and for removing unsafe parts
from service. The revision of the SUP reporting form would simplify SUP
reporting, improve the usefulness of collected data, and discontinue the
collection of data that add no value to the SUPs program.
• Draft AC 20-AIR-DU, Voluntary Industry Distributor/Dealer Accreditation

Program, notice of availability of proposed AC published in the Federal
Register July 7, 1995. This draft AC describes an industry-administered
system for voluntary accreditation of parts distributors to improve quality
controls and part traceability in that sector of the aviation industry.
• FAA Suspected Unapproved Parts Policy Planning Meeting, Seattle,

Washington, April 13-15, 1995, to discuss policy concerns and suggest
ways of improving the SUPs program. The meeting was attended by
Appendix B B–3
47 representatives of the Aircraft Certification Service, Flight Standards
Service, Civil Aviation Security, and Office of the Chief Counsel.
Recommendations addressed regulations, policy, management and
organization, training, process, communications, and data.
• FAA Suspected “Unapproved Parts” Task Force Program Plan: Report due
October 1995. Special Task Force assembled to thoroughly review the
issue of unapproved aircraft parts and to submit a report evaluating the
agency’s efforts to prevent any potential risk to aviation safety, and make
recommendations to further improve the program’s efficiency.
B–4 Appendix B
APPENDIX C — Related ACs, Orders, and
Memoranda
RECOMMENDED ACTION
TYPE OF REFERENC TITLE OR SUBJECT NO REVISE CANCEL
DOCUMENT E CHANGE
Existing AC 21-29A Detecting and reporting SUPs X

21-19A X
Draft AC 21-29B Draft Revision to AC 21-29A X
Revision
Existing AC 20-62C Eligibility , Quality, and Identification of X
Approved Aeronautical Replacement Parts
Draft AC 20-62D Draft Revision to AC 20-62C X
Revision
Existing AC 21-38 Disposition of Unsalvageable Parts X
Draft AC 20-XX Disposition of “unapproved parts” (PAAT- X
III)
Proposed AC 20-DU Distributor Accreditation Program X
Existing AC 21-20A Supplier Surveillance Procedures X
Draft AC 21-20B Supplier Surveillance Procedures (Ref: AC X
Revision 21-20A)
Existing AC 21-303.1A Certification Procedures for Products & X
Parts
Existing AC 21-41A Substitute Technical Standard Order (TSO) X
Existing AC 20-114 Manufacturer’s Service Documents X
Existing AC 21-13 Standard A/W Cert. of Surplus Military X
Aircraft & Aircraft Built from Surplus Parts
Existing AC 21-303.2H PMA (Update) X
Existing AC 43-9B Maintenance Records X
Existing AC 43-9.1E Instructions for Completion of FAA X
Form 337
Existing AC 43-17 Practices Governing Identification Data X
and Data Plates
Memorandum AIR-200 Guidance Memo #95-3 Re: SUPs, 3/1/95 X
Memorandum AGC-200 Definition of “owner-produced” part, X
8/5/95
Memorandum AIR 100/200 Definitions- Standard/Commercial Part, X
1995
Memorandum AFS-300 Part Manufacturing, 5/15/95 X
Handbook Order 8300.10 Maintenance versus Manufacturing, 1/3/95 X
Revision (Draft) AFS-300
Existing AC 21-303 Replacement and Modification of Parts X
(FSAW 95-07), 6/2/95
Appendix C 1
Appendix C — SUP-Related ACs, Orders, and Memoranda (Continued)
RECOMMENDED ACTION
TYPE OF REFERENC TITLE OR SUBJECT NO REVISE CANCEL
DOCUMENT E CHANGE
Memorandum AIR-1 Enforcement of 21-303, 3/30/95 X

Existing Order 8120.10 Suspected Unapproved Part Program X
Existing Notice 8110.54 PMA Under Licensing Agreement X
Existing Notice 8110.55 PMA by Identicality (PAAT-III) X
Existing Order 8110.42 Parts Manufacturer Approval Procedures X
Draft Order 8120.XX How to meet the intent of AC 21-38 X
Existing Notice 8120.17 Procedures for Processing Application for X
PMA (Ref: Orders 8110.42 & 8110.55)
Order 8130.21A Procedures for Completion and Use of X
8130-3 Approval Tag
Draft Order 8130.21B Procedures for Completion and Use of X
8130-3 Approval Tag
Draft Notice 8120.XX Revised FAA Form 8120.12 SUP Status X
Report
Order 8000.50 Repair Station Production of Replacement X
or Modification Parts
Note: Specific recommendations for how to revise the documents listed above would be developed by the
policy organizational element of the new National SUPs Program Office
2 Appendix C
APPENDIX D — SUPs Investigation Procedures
This appendix enumerates steps in conducting suspected “unapproved parts”
investigations. The Suspected “Unapproved Parts” (SUPs) investigation
procedures outlined here are not intended to be an exhaustive procedures
manual, but they may serve as a basis for later development of inspector
guidance and training.
The initial steps of an Federal Aviation Administration (FAA) SUPs
investigation depend on the source of the initial report. If a SUP is discovered
as part of surveillance activity by an inspector, the following would be the first
two steps taken:
1. Provided that sufficient information exists, initiate a SUPs report
through the Parts Reporting System database and information
system.
2. Contact the Regional/Directorate SUPs Coordinator and obtain
assistance in determining if there is an ongoing law enforcement or
FAA-related activity that the inspector should be aware of before an
investigation proceeds.
If the SUP is reported to the FAA, the FAA National SUPs Program Office
would coordinate assignment of the case to the appropriate local office through
the regional/directorate SUPs coordinator. When the responsibility for an
investigation is assigned to an office, the following information would also be
sent to that office:
• Basic SUPs identifying information

• Whether there is related FAA activity, and if so, what are the
pertinent details
• Law enforcement interest and/or related activities
• Other FAA offices that should be involved
• Initial case priority
• Part criticality, if known.

In determining how to initially assign a case or, if necessary, transfer
responsibility for a case, the National SUPs Program Office would consider the
nature of the part. If the part is new and does not appear to be damaged or
altered, the case investigation would be assigned to an inspector of the ap-
propriate local Manufacturing Inspection District Office (MIDO). If the part is
in service, has been in service, or has been repaired or altered, the case
Appendix D D–1
investigation would be assigned to an inspector of the appropriate local Flight
Standards District Office (FSDO).
Case Priority
To conduct investigations in a timely manner, have a clear understanding of the
implications of the investigation results, and provide answers to management
questions, the proposed FAA National SUPs Program Office should
1) prioritize initial work effort to get the investigation off to the correct start,
and 2) establish case significance upon completion of the investigation.
The FAA Task Force developed recommended procedures in connection with
establishing case priority. Using the definitions in Appendix 5 of Order
8120.10 (until the proposed National SUPs Program Office defines other guid-
ance), the Program Office would establish the initial case investigation priority.
Thus, this determination would be made at a national level rather than at the
local level. Part criticality would not specifically be determined at this stage
unless that information already is contained in the Parts Reporting System
database; however, the Program Office would establish the initial case
investigation priority based on all applicable criteria in Order 8120.10.
The National SUPs Program Office would use part criticality, as determined by
the appropriate Aircraft Certification Office, along with other information
available at the end of the investigation, to determine the SUP case
significance. This case significance would essentially be a final determination,
useful for management and trend analysis. In some cases, the ACO
determination of part criticality may also reveal that the initial case
investigation priority was inappropriate. In such cases, the Task Force
considers that another designation, current case status/priority, would be
necessary to reflect the current and best estimate of the case’s priority. It is
important that the FAA have the flexibility to designate the case priority based
on available information, as long as such decisions are based upon consistent,
clear, technical criteria. Information available at the beginning of a case may
be quite limited. Confining such decisions to the purview of a national level
office should help ensure that such decisions are based on consistent use of
applicable guidelines. Furthermore, the initial case priority would never be
change; it would remain in the database as the case’s initial priority, even
though the current priority might be different as a result of further information.
Conducting the Investigation

Once the initial SUPs report is filed, the case is assigned, and appropriate
interested parties are notified through the SUPs management information
system (or, through any interim established by the National SUPs Program
Office), the inspector would conduct the investigation as follows:
D–2 Appendix D
1. Conduct the preliminary investigation to verify as much of the initial
information as possible. Based on guidance material that would
include indicators of fraudulent activity (material to be supplied by
the DOT/OIG and other law enforcement agencies), the inspector
would seek to determine whether criminal activity may be involved.
Emphasis also would be given to identifying the part or parts
involved in as much detail as possible.
2. Provide information, such as a verified part number, to the Technical
Support element of the National SUPs Program Office to help the
Program Office facilitate having the appropriate ACO determine or
update part criticality. The Technical Support element would
contact the appropriate engineering staff for this step. Any
information provided to the inspector also should be sent to the
Regional/Directorate SUPs Coordinator.
3. Develop an initial assessment of the safety impact to determine if the
case priority should be modified. All initial determinations of safety
impact, or updates and revisions, are made by the Technical Support
organizational element. (At this point, however, only very limited
investigations would have taken place and it may not be feasible to
effectively assess the potential safety impact.)
4. If the inspector believes criminal activity may be involved or if there
are any doubts as to how to proceed, the local investigating office
would initiate a meeting, to include the Regional/Directorate SUPs
coordinator, the Regional Office, the Technical Support element of
the National SUPs Program Office, and others as required, to obtain
clarification. The meeting may occur in person, via telephone, or
via other means. Examples of questions that might be addressed
through such communication include whether an administrative
subpoena is appropriate and whether the inspector should seek to
obtain the suspect parts. This would also be an appropriate forum to
review the potential impact of the inspector’s investigation on
possible law enforcement actions in the case, or to decide whether to
notify law enforcement.
Investigation Techniques
The initial question the inspector seeks to answer in a SUPs investigation is
whether the part is approved or unapproved. If it is unapproved, the inspector
will document how that determination was made. The objective then becomes
identifying the source and tracking down the “unapproved parts” to eliminate
the potential safety risk and to initiate enforcement action, if appropriate.
Appendix D D–3
One of the first steps should be to review the suspect part’s documentation. If
this documentation is inadequate, the part should be treated as unapproved until
shown otherwise. In addition to normally required documents and records, the
following documents may help inspectors obtain necessary information to
determine the status of a part or the extent of the problem, or they may be an
indicator of attempts to misrepresent information:
• FAA Form 8130-3, Airworthiness Approval Tag
• An invoice or purchase order (this may provide insight into whether

the price is reasonable relative to the typical market value)
• Maintenance records as required by 14 CFR Part 43, Part 145, or

Part 91, or other operating regulations
• Conformity certifications (these are often provided by suppliers and

generally are extremely vague and not a useful certification)
• Service Difficulty Report information and airline reliability program

reports (these may be indicators of parts that are substandard).
Also of potential value is the known qualification of the person providing any
certifications. A parts tag per se is not an acceptable document; the
information on the tag must be sufficient. The inspector should also determine
appropriate reference data (e.g., the related page of the Illustrated Parts
Catalog) that should be copied.
The inspector must obtain precise information as to the identification of the
part: the name of the manufacturer and the production authorization, if
applicable; the part number; the serial number; modification status, and other
descriptive information.
Inspectors should also be alert to the need to identify evidence that might be
needed for subsequent enforcement action, and the options available for
collection of that evidence. In many cases, the inspector may be able to obtain
suspect parts simply by asking for them — the operator holding the parts may
voluntary hand them over. In other cases, an administrative subpoena can be
obtained from the FAA Regional Counsel’s Office to acquire the parts. It is
important to pursue this issue early in the investigation so that parts that might
be important to the case and subsequent enforcement action do not disappear.
Inspectors should also bear in mind the need to keep photocopies of all
potentially pertinent documents available.
If at this point in the FAA investigation the inspector knows that a concurrent
law enforcement investigation is taking place or suspects criminal activity, the
inspector should contact the appropriate law enforcement agency through the
Regional/Directorate SUPs coordinator to inquire if that agency can assist the
FAA in obtaining parts.
D–4 Appendix D
To ascertain how many parts of the suspect type are in the system, the inspector
should check for the number of serviceable and unserviceable parts in invento-
ry at the operator facility, and should check on aircraft in the operator’s fleet
for suspect parts that may have been installed. With assistance from other
inspectors, the inspector should also check the immediate geographical area
(e.g., other repair stations at the same airport). The Regional/Directorate SUPs
Coordinator and the Technical Support organizational element of the National
SUPs Program Office can help check other geographical areas.
To determine the whereabouts of the parts, it may also help to identify their
source. Potential sources include PAHs; distributors or brokers; other operators
including parts pools; maintenance organizations; owners who have produced
parts for their own aircraft; nonaviation producers or suppliers; foreign sources;
leasing companies; military surplus vendors; or vendors of parts from public-
use aircraft not maintained in accordance with the Federal Aviation
Regulations.
The Task Force found that, because SUPs cases so often cross disciplinary and
geographic boundaries, constant communication is essential. The SUPs
investigator should maintain regular communications with the local office
management, the Regional/Directorate SUPs Coordinator, and the Technical
Support element of the National SUPs Program Office, as the investigation
proceeds. Specific reports to update the status of the investigation should be
made under the following circumstances:
• Whenever there is a formal contact by a law enforcement agency,

other than follow-up contacts after a cooperative relationship is es-
tablished on a specific case. (This is not required for informal con-
tacts; for example, for the purpose of addressing routine technical
questions.)
• Whenever there is a significant change to the scope of the investiga-

tion (e.g., a new organization must be investigated).
• When the geographical boundaries of the investigated activity ex-

pand significantly.
• Whenever a significant event occurs that affects the case status.

Updating the database should be considered regularly; however, the Task Force
decided against recommending a rigid requirement to update the database on a
specific schedule. During the transition period, prior to full implementation of
the proposed information system, this reporting should be accomplished via
direct communication (telephone, electronic mail) with the
Regional/Directorate SUPs Coordinator. Significant decisions regarding case
assignment and priority should be made at the National SUPs Program Office
level.
Appendix D D–5
Final Report
The final SUPs investigation report, in addition to the information normally
contained in an inspector’s report of any alleged violation, should include or
emphasize the following information:
• The traceability of a part from the original manufacturer through

distributors (if any) or other users, to the final user
• The location and disposition of parts that were found to be

unapproved
• Suggested additional related areas that should be investigated
• A record of internal and external coordination
• Any safety issues that might not be fully resolved
• A summary of communications with or notifications to industry
• Recommendations for follow-up actions (e.g., ADs and alerts).
D–6 Appendix D
APPENDIX E — Parts Reporting System
Database
The SUPs Task Force identified the following list of items that the Parts
Reporting System (PRS) must address:
• The part’s level of criticality
• Any other SUPs history related to the part or organization (related

SUPs case, Enforcement Investigative Report, etc.)
• Reference to information in the FAA policy system
• Manufacturer/repair authorization (e.g., PMA, TSO, direct ship

authority)
• Distributor accreditation, in accordance with the AIR-DU initiative

for voluntary distributor/dealer accreditation and quality control
• FAA responsible office
• Geographic history
• Related cases
• SUP case identification number
• SUP case investigation priority
• Status, suspense dates, and information regarding case schedules
• Alerts for messages to offices involved or that may be involved in

the case.
Information requirements for reporting SUPs cases includes:
• Reporter Information: The name of the reporting individual (or

anonymous) and whether or not confidentiality was requested. The
telephone number where the reporting party can be reached, where
they are employed, the person’s position within the company, the
company name and address, and whether or not the company is
certificated.
• Allegation Information: The type of company (e.g. operator,

manufacturer, distributor, broker, producer, repair station) and the
nature of the allegation to include specific details on the part(s)
name, part number, serial number, quantity, the application of the
part (airframe, engine, propeller, appliance), the assembly and
Appendix E E–1
subassembly, the Illustrated Parts Catalog reference, any other
persons involved (names, key individuals), and any other companies
(related or affected) involved.
• Administrative Information: This would include the date/time of the

contact or call, any remarks, information on the person receiving the
report, such as name, office, and telephone number.
Information needed for an investigator to begin the case investigation includes
all information from initial report, plus:
• The tracking number (SUPs Investigation Case Number) for the

case
• Any hotline cross-reference number (if applicable)
• Initial and current investigation priority levels (priority, normal)
• Any related information and cases (such as EIRs, other SUPs cases,
accidents or incidents, SDRs, ADs, service bulletins, PTRS)
• Law enforcement interests (such as restrictions, limitations, and

points of contact)
• Assignment of action office
• Information regarding the investigating official (such as name,

office, and telephone number)
• The part criticality (as determined by the applicable ACO after the
part number has been confirmed)
• The applicable offices of interest (such as the ACO, directorate,

region) and any required tracking or suspense dates.
The information an investigator should submit regarding the investigation
includes the information required to initiate the investigation, plus:
• A record tracing each part (by such items as the purchase order,
buyer/seller, the invoice number, the price, quantity, and life limit
status)
• A determination of approval status of each part
• The disposition of the parts
• Information regarding the tracking of each part through the system

to its current location
• Any additional areas identified for investigation
E–2 Appendix E
• Any notifications (such as to operators, owners, certificate holding
district offices)
• Any action(s) taken
• Any corrective action follow-up
• Whether or not there were any safety issues (by specifically

answering “Did a potential safety problem exist?” and “Does a
potential safety problem remain?”)
• A record of the chronology of all key events
• Any authorizations involved (such as

PMA/PAH/manufacturer/Repair Station)
• The industry segment affected by Federal Aviation Regulation Part
• The current status of the investigation
• When the investigation is complete as far as this office is concerned.

The requirements for region/directorate and national headquarters include all of
the information reported by the investigating official, plus:
• Summary data (such as open vs. closed cases, geographical

distribution of cases, distribution by notification sources, cases
sorted by the companies or persons involved)
• Suspenses (case milestones)
• Compliance or safety issues
• The current case status

• Part criticality determination
• The amount of resources expended
• The ability to conduct analysis (including development of automated

analytical tools)
• Any follow-up notifications (such as to the reporter, if requested)
• Any sanctions as a result of enforcement actions
• Information or maintenance follow-up to industry resulting in

Service Bulletins or their equivalent
• Airworthiness Directives
• Alert bulletins
Appendix E E–3
• Action notices
• Referrals to criminal investigative or law enforcement agencies
• Public access to closed cases
• Outside agency interfaces
• Status and requests
• Any reassignment of cases to include multiple offices involved
• The disposition of any “unapproved parts”
• FAA case completion
• Case closure.
E–4 Appendix E
APPENDIX F — Parts Receiving Policy
The FAA Suspected “Unapproved Parts” Task Force reviewed guidance
material pertinent to development of a parts receiving policy. The Task Force
reviewed FAA Order 8300.10, Airworthiness Inspector’s Handbook, regarding
parts receiving and incoming inspections for air carriers operating under 14
CFR Parts 121 and 135, and for repair stations operating under 14 CFR Part
145.
Guidance material was found for air carriers operating under Part 121, and for
air carriers operating aircraft with 10 or more passenger seats under Part 135, in
Chapter 63 of the Handbook, “Evaluate FAR Part 121/135.411(a)(2) Company
Manual/Revision” (page 63-6). Chapter 164, “Evaluate FAR Part 145
Inspection Procedures Manual/Revision” discusses a Part 145 repair station
manual and incoming inspections in considerably more detail. The Chapter
164 discussion references AC 145-3, Guide for Developing and Evaluating
Repair Station Inspection Procedures Manuals (February 13, 1981). The Task
Force recommends that the information contained in Chapter 164 and AC 145-
3 be combined and added to the guidance of Chapter 63 for air carriers to also
include operations manuals for air carriers operating under Part 135 with nine
passenger seats or less.
The following items should be considered:
1. The manual (General Maintenance Manual or Inspection Procedures
Manual) should explain how the incoming inspections are recorded.
2. The manual should indicate by title the person responsible to perform this
inspection.
3. A detailed description of acceptable documentation should be included in
the manual. (An effective way to present this information is through a
discussion of what would or would not constitute adequate documentation
in different cases.)
4. The manual should describe the action to be taken when materials/parts
received do not meet specifications, how they are identified, controlled,
and, when applicable, reported to the SUPs national database or its
proposed successor Parts Reporting System.
5. The manual should include a system or method for the following types of
incoming inspections of articles and/or materials:
(a) New items from the manufacturer, for —
• Shipping damage
Appendix F F–1
• Traceability of life limits, if applicable
• Identification and tagging of parts to manufacturer’s invoice.

(b) Overhauled or repaired parts from an approved agency for —
• Shipping damage
• Traceability of life limits, if applicable
• Traceability of overhauled recorded and/or maintenance

release tag.
(c) Items sent out for contracted maintenance functions for —
• Shipping damage
• Conformity to specifications (FAA and manufacturer’s), to

include type of material and state of preservation
• Airworthiness status including ADs and traceability of life

limits, if applicable
• Functional test, if applicable.
NOTE: If there are indications that a part was involved in an aircraft accident, special
incoming inspections will be required in conjunction.
F–2 Appendix F
APPENDIX G — List of Recommendations
The following is a list of recommendations contained in this SUPs Task Force’s
Proposed Program Plan. The recommendations in this list are numbered in the
order in which they appear in the document.
1. Pending implementation of the Proposed Program Plan, the FAA should
take immediate steps to target receiving inspection control systems of
airlines and repair stations, and PAH supplier surveillance in a special
emphasis campaign for surveillance and enforcement, as well as provide
immediate dissemination of information regarding parts usage and the role
of quality control systems and receiving inspections in screening out SUPs.
2. The FAA should issue a policy statement reaffirming a clear FAA
commitment to eliminate “unapproved parts” from the aviation system.
3. Add a “required item” to the AFS National Work Program (National
Program Guidelines) for SUPs surveillance and make SUPs surveillance a
“special emphasis” item for the manufacturing inspection program. This
addition should be made to the fiscal year 1997 program, although AFS
and AIR should direct that SUPs receive equivalent priority in the fiscal
year 1996 programs.
4. The FAA should adopt definitions of the following main terms used with
regard to parts eligible for installation in type certificated products to
ensure that use of the terminology in government and the public is
consistent and promotes a common understanding and use of the concepts:
“approved part;” “unapproved part;” standard part; and counterfeit part.
Such definitions are intended for the purpose of this Proposed Program
Plan as well as for the purpose of future respective guidance documents
and for colloquial use, as opposed to legal definitions. Hence, the Task
Force does not recommend regulatory changes to adopt the definitions.
5. The FAA should take immediate steps to establish a National SUPs
Program Office to develop, coordinate, and disseminate SUPs policy, and
to provide technical support related to SUPs. This office also would
maintain an information management and analysis system for the SUPs
program.
6. The Federal Aviation Regulations should be amended to require any
person (including organizations and individuals such as mechanics) who
discovers suspected or known “unapproved parts” to report such parts to
the FAA. An exception to this requirement should be made for properly
documented parts that lack required maintenance but are controlled in such
a way as to ensure that the necessary maintenance or other appropriate
steps are accomplished before the parts are placed in service.
Appendix G G–1
7. The FAA should expedite implementation of, and then vigorously enforce
the draft regulatory project that would prohibit any person from making
fraudulent or intentionally false statements involving a record that
represents the acceptability of any aircraft product, part, or material for use
in civil aircraft.
8. The FAA should expedite implementation of, and then vigorously enforce
the draft regulation that would address maintenance recordkeeping
requirements.
9. Issue an AC or revise an existing AC explaining how mechanics, airlines,
and repair stations may comply with the requirements of 14 CFR
§ 43.13(b). Also, consider a legal interpretation or, if necessary, additional
rulemaking to further clarify the FAA’s belief that the person responsible
for installing a part must be able to show how that person determined that
the part was eligible for installation and that it was the correct part for that
application.
10. The FAA should issue or revise advisory material to clarify for industry the
conditions under which maintenance personnel may fabricate parts for
repairs or alterations, and the conditions in which they must apply for a
PMA for parts production. If a person produces parts for sale without a
required PMA, the FAA should take appropriate enforcement action.
11. The FAA should continue its support for the development of an effective
Aerospace Industry Regulation of Distributors (AIR-DU) program of
voluntary accreditation for distributors.
12. FAA procedures and related guidance and training should be upgraded to
emphasize the importance of thorough SUPs investigations, with attention
to the potential scope of the problem, collection of evidence, indicators of
fraud or other criminal activity, and adequate documentation.
13. Investigative procedures followed by FAA inspectors should be revised to
ensure that all necessary steps are taken to address SUPs on a system-wide
basis, with proper coordination between local, Regional/Directorate, and
national offices, as well as with the DOT/OIG and other law enforcement
authorities, if appropriate.
14. The FAA should encourage legislative action to obtain authority to seize
and destroy counterfeit parts, apart from any criminal proceedings.
15. The FAA should encourage legislative action to increase the maximum
civil penalty for persons other than air carriers, to which the higher
maximums already apply, to $10,000 per violation.
16. The FAA should review the application of and enforce requirements for
inclusion of IFCA in type certification regulations. The FAA should revise
G–2 Appendix G
advisory material to clarify that 14 CFR §§ 21.303(d) and 21.50(b) require
holders of PMAs to furnish IFCA.
17. The Task Force supports efforts to develop harmonized forms and
recommends that AVR instruct FAA members of the FAA-JAA Working
Group to seek to have the harmonized JAA Form 1 the same as the FAA
Form 8130-3.
18. The Task Force endorses the objectives and concepts embodied in the draft
AC that address methods for determining the acceptability of parts that
have insufficient documentation (AC 20.XX, Determining Disposition of
Undocumented Parts); however, it believes that the definition of Group A
parts could be problematic. Consequently, the FAA Working Group
developing this AC should reconsider its method for grouping parts.
19. Revise Order 8120.10, Suspected Unapproved Part Program, with
particular attention to the definition of part criticality, and adopt procedures
under which the National SUPs Program Office will coordinate with the
appropriate ACO for the purpose of determining “part criticality.”
20. The Task Force believes that the Department of Defense (DoD)-planned
steps and the procedures contained in draft AC 20-XX adequately address
the SUPs problem, and recommends that the National SUPs Program
Office monitor the DoD/FAA Program to ensure that it is compatible with
the FAA SUPs Program. If the program is not implemented in a timely
manner or consistent with the current plan, the Task Force recommends
that the FAA develop specific policy and procedures to minimize the threat
posed by surplus military parts.
21. The SUPs investigation process should explicitly require that all field
office case files be transmitted to the Regional/Directorate SUPs
Coordinator for consolidation (if necessary) and then transmitted to the
Data and Analysis organizational element of the National SUPs Program
Office. Appropriate guidance material and training should reflect this
procedure.
22. The FAA should take necessary steps to ensure that once aviation parts are
classified as “salvageable,” they are properly controlled, and that “scrap”
parts are destroyed to prevent their re-entry into the aviation system.
23. Establish a procedure for removal of “unapproved parts” from aircraft
parallel to the current MEL process for parts with a criticality level of 1 or
2 that are listed on the current MEL for a specific aircraft. For parts with
criticality level of 3, establish an Administrative Control Item, as defined in
the preamble and definitions in existing MEL documents. “Unapproved
parts” that may be in the inventory and not on aircraft should be removed
from the inventory and segregated to preclude access by personnel that
may inadvertently install an “unapproved part.” These new processes
should be formally incorporated into operators’ maintenance manuals.
Appendix G G–3
Guidance should be developed for distribution to the industry and FAA
field offices that defines the details of this process as well as the level of
acceptance required by the FAA.
24. Immediately initiate an abbreviated user requirements study and functional
systems requirements analysis so as to more fully develop user and
functional requirements for a Parts Reporting System (PRS). Proceed with
system design, development, and implementation. Explore the feasibility
of sharing cost/design functions with other agencies with a critical interest
in a national PRS and define the requirements for and establish a bulletin
board system for public access.
25. The FAA should clarify their intended working relationships with law
enforcement agencies, and facilitate these agencies’ access to the FAA, as
well as FAA access to law enforcement agencies, while maintaining
appropriate coordination with the FAA Office of Civil Aviation Security
and the DOT/OIG.
26. The FAA should work with law enforcement agencies to develop and
maintain standard operating procedures that would facilitate working
relationships between FAA inspectors and those agencies, recognizing the
importance of both law enforcement and aviation safety protection.
27. The FAA should provide timely, simultaneous notification of SUPs cases
to all interested law enforcement agencies, and the memoranda of
understanding with those agencies should address when law enforcement
agencies should notify the FAA of SUPs cases they are pursuing in
recognition of the FAA’s safety responsibilities.
28. Provide interim SUPs policy and procedures training to AIR and AFS
maintenance inspectors and other personnel. Deliver this training via
electronic means to ensure rapid delivery and supplement it with
publication of a comprehensive “Inspector’s Guide to Suspected
Unapproved Parts.”
29. Begin immediately to develop the formal, more detailed training element
of SUPs policy and procedures for implementation concurrently with the
establishment of the National SUPs Program Office, and follow up with
the DOT/OIG, DCIS, and the FBI to obtain training offered by those
agencies for FAA inspectors.
30. Based on formal training courses, develop computer-based instructional
programs and make them available to inspectors at their local offices for
use in reinforcement training.
G–4 Appendix G
APPENDIX H — Task Force Charter Items
Program Plan Cross-Reference
Guide
The Task Force’s Charter items are addressed in the Program Plan document as
follows:
To define a uniform system of Section 3.0

terminology to be used by all FAA
personnel when dealing with
SUPs.
To develop organizational Section 4.0
processes or structure that support
effective surveillance and
enforcement of SUPs.
To suggest rulemaking or policy Section 2.0, Section
guidance that would assist in the 5.0
surveillance and enforcement
process.
To identify significant technical Section 6.0
issues that require resolution
which are currently impacting
SUPs.
To define roles, responsibilities, Section 8.0
and working relationships with
other law enforcement.
To assess data and information Section 7.0
needs to support SUPs processes.
To supplement the current training Section 9.0
program with SUP training for
AIR and AFS inspectors.
Prioritize all recommendations Section 10.0
according to their impact on
reducing the safety impact of
SUPs.
Appendix H H–1
H–2 Appendix H
Appendix H H–3

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U.S.

Suspected ‘Unapproved Parts’

List of Acronyms ......................................................................................................................iv

APPENDIX A — FAA SUPs Task Force Members

Table of Contents iii

The Task Force recommends the following:

• Clarify the FAA’s Policy on SUPs

• Standardize the Use of SUPs Terminology

• Establish an FAA National SUPs Program Office

• Establish a New Parts Reporting Information System

• Improve Cooperation With Law Enforcement Agencies

• Target Receiving Inspection Procedures for Surveillance and

• Clarify the Responsibility of Persons Performing Maintenance

• Improve SUPs Investigation Training for the FAA Workforce

• Define Procedures to Dispose of Scrap Parts

• Define Procedures to Remove “Unapproved Parts” from

Executive Summary vii

1.0 Introduction 1–1

1–2 1.0 Introduction

If an “unapproved part” is not salvageable, i.e., thought to be worth saving

1.0 Introduction 1–3

1–4 1.0 Introduction

1.2 Overview of the Proposed Program Plan

• Clarify the FAA’s Policy on SUPs

• Standardize the Use of SUPs Terminology

1.0 Introduction 1–5

• Establish an FAA National SUPs Program Office

• Establish a New Parts Reporting Information System

• Improve Cooperation With Law Enforcement Agencies

1–6 1.0 Introduction

• Target Receiving Inspection Procedures for Surveillance and

A special “campaign” of surveillance and enforcement should be outlined

• Clarify the Responsibility of Persons Performing Maintenance

1.0 Introduction 1–7

• Improve SUPs Investigation Training for the FAA Workforce

• Define Procedures to Dispose of Scrap Parts

• Define Procedures to Remove “Unapproved Parts” from Inventories and

1–8 1.0 Introduction

1.0 Introduction 1–9

1.4 Task Force Mission

• An effectively managed and designed organization

• A comprehensive data collection methodology

1–10 1.0 Introduction

1.5 Task Force Charter

• To define a uniform system of terminology to be used by all FAA

• To develop organizational processes or structure that support

• To suggest rulemaking or policy guidance that would assist in the

• To identify significant technical issues that require resolution which

• To define roles, responsibilities, and working relationships with

• To assess data and information needs to support SUPs processes.

• To supplement the current training program with SUPs training for

• To prioritize all recommendations according to their impact on

1.0 Introduction 1–11

1.7 Scope of the Task Force’s Work

1–12 1.0 Introduction

1.8 Task Force Methodology

1.0 Introduction 1–13

1–14 1.0 Introduction

2.0 Policy 2–1