Terms to Know
Now that you have a better idea of the different types of aeronautical parts and what makes them officially “approved,” let’s talk about how to identify and report a SUP. The differences can be subtle.
To help with the FAA’s ability to investigate as well as educate the aviation community on SUPs, the agency formed a SUP Program Office in 1995. The FAA’s Flight Standards Service (FS) assumed initial responsibility for the program, but in 2012 it was transferred to the Aircraft Certification Service (AIR). Today, the FAA’s Office of Audit and Evaluation processes all FAA Hotline complaints (more on that later) and forwards all SUP related reports to focal points in both AIR and FS for evaluation. These individuals then work together to properly classify the report and assign it for investigation, as determined by the details of the case.
From the perspective of the SUP office, there seems to be a lot of confusion regarding SUPs. That’s understandable, because it is a nuanced issue. It also uses terminology that overlaps into other aspects of the aviation industry, making it hard to differentiate among those terms.
Here are a few, real-world examples that illustrate some of this confusion:
Use of Known Unapproved Parts:
We received a report that identified the use of grade 8 hardware store bolts in place of approved standard aircraft hardware. This error was obvious and easy to spot; the reporter spelled out the issue and included numerous photos to document the error. The intentional use of known unapproved parts in place of approved aircraft parts is a case of “improper maintenance” and is not a SUP case. Ultimately, we assigned this case to the local Flight Standards District Office (FSDO) for investigation.
This term means that a production certificate holder makes an error and ships a part that does not conform to the type design. There may be a variety of reasons for this occurrence. For example, there may have been a missed step in the part’s manufacturing process, which was then missed by quality control. This is not a SUP case, but it gets immediate attention from the FAA’s Aircraft Certification personnel to identify and fix the problem.
Approved Parts Installed in Unapproved Places:
This is another instance of “improper maintenance” rather than a SUP case. When you install an approved part in the wrong place, it does not lose its classification as an approved part if it has not lost traceability to its approved roots.
These are unapproved parts manufactured and sold without FAA approval. You should report them to the FAA as a SUP. There may be obvious, or not so obvious, visual clues to help you spot these parts. The FAA aggressively investigates these cases and works closely with the Office of Inspector General (OIG) and law enforcement officials to ensure proper adjudication. There are cases of this nature that have resulted in significant civil penalties and/or jail time for those involved.
Even standard parts like these bolts can be easily counterfeited. Inspect using industry standards to ensure conformity.
Play Your Part
As an aircraft owner, operator, or mechanic, you play an important role in ensuring the integrity of aeronautical products, especially when it comes to determining the quality, eligibility, and traceability of aircraft parts. One tool you can use to report any instances of SUP is the FAA’s Hotline Program (hotline.faa.gov). The hotline is a national reporting system established to receive reports of potential unapproved parts entering the aviation system primarily at the supply and repair level of aircraft maintenance. You can also report SUP via mail, and the SUP Report form is available at faa.gov/aircraft/safety/programs/sups. Please note that you can no longer report a SUP by phone.
If the SUP office receives a hotline report that is ultimately classified as something other than a SUP, please don’t think it gets ignored or discarded. Instead, the SUP focal points evaluate each report, make the appropriate classification change, and recommend assignment to the appropriate FAA office. The FAA investigates all cases.
An excellent resource for dealing with a potential SUP case is FAA Advisory Circular (AC) 21-29, Detecting and Reporting Suspected Unapproved Parts (see Learn More at the end of this article for a link). This AC provides detailed guidance on how to identify unapproved parts, as well as prevent the procurement, acceptance, and installation of such parts.
It is important for all airmen to remain vigilant on this issue. If you identify a SUP, we are here to support you. So please send us a report.
Sign Up For Unapproved Parts Notifications!
To receive an email alert when new FAA UPNs are posted to the FAA Suspected Unapproved Parts UPN webpage:
- Go to this website: bit.ly/2Wrvbpo
- Enter an email address and click on Submit
You are now subscribed to receive FAA UPN alerts through GovDelivery.
James Niehoff is an FAA aviation safety inspector and the SUP Focal Point with the Aircraft Maintenance Division’s Special Programs Branch.
This article was originally published in the May/June 2019 issue of FAA Safety Briefing magazine.