TRACEABILITY OF AIRCRAFT PARTS

The installer of an aircraft part must determine its eligibility and traceability to approved source before installing the part on the aircraft. For aircraft parts to be eligible and traceable, they must be from a source approved or acceptable to the Federal Aviation Administration (FAA). Aircraft parts must be produced in accordance with a production system and data approved or found acceptable by the regulatory authority of the State of Design. Owner and operator of aircraft are also required to keep current status of aircraft life-limited parts and these records must be transferred to the new owner or operator after the sale. This paper reviews traceability of aircraft parts with special emphasis on approved and acceptable parts, the traceability documentation required, and back-to-birth traceability.

EASA Part M.A.501(a) states that “No component may be fitted unless it is in a satisfactory condition, has been appropriately released to service on an EASA Form 1 or equivalent and is marked in accordance with Part 21 Subpart Q, unless otherwise specified in Annex (Part-21) to Regulation (EC) No 1702/2003, Annex II (Part-145) or Subpart F, Section A of Annex I to this Regulation”. Which means it is the responsibility of the installer of an aircraft part to ensure the aircraft part is eligible for installation and is traceable to the source. The installer, in this case, may be the owner, operator or the maintenance organisation.

Approved and Acceptable Parts

Aircraft parts can be approved parts or acceptable parts. According to Federal Aviation Administration (FAA) Advisory Circular AC 20-62E, approved parts are parts produced under an FAA-approved production system that meets FAA approved data while acceptable parts are parts acceptable for installation on a type-certificated aircraft. The approved parts may include: parts produced by a Part Manufacturer Approval (PMA) holder; part produced under a Technical Standards Order (TSO) Authorisation; and parts produced as part of the type certification procedures for the aircraft. Acceptable parts may include: standard parts produced that conforms to established industry specification; parts produced by the owner or operator that conforms to FAA approved data; and parts fabricated by appropriately certificated persons or appropriately rated certificate holders. Aircraft parts must be traceable to birth and must be from any of the approved sources mentioned earlier. Aircraft parts are known to move from one operator or maintenance organization to another or from one aircraft to another most especially when removed from the aircraft for overhaul, inspection, repairs, or modification. Each time they are to be installed on any aircraft, the eligibility and traceability must be established from the aircraft type certificate holder’s Instruction for Continued Airworthiness (ICA) by the installer in order to prevent installation of a wrong part on an aircraft.  As contained in FAA Advisory Circular A20-62E, for standard parts like bolt and nuts to be acceptable, they must be manufactured in complete compliance with an established U.S. Government or industry-accepted specification, which includes design, manufacturing, and uniform identification requirements. The specification must include all information necessary to produce and conform to the part. The specification must be published so that any party may manufacture the part. Examples include, but are not limited to, National Aerospace Standard (NAS), Air Force/Navy (AN) Aeronautical Standard, Society of Automotive Engineers (SAE), Aerospace Standard (AS), Military Standard (MS),

Traceability Documentation Required

The following documentation will be required to ensure traceability of aircraft parts:

1. Certificate of Conformity or FAA 8130-3 or EASA Form One for aircraft parts that are new and manufactured by the Original Equipment Manufacturer (OEM);
2. EASA Form One or FAA 8130-3 or airworthiness approval tags for used aircraft parts that have been overhauled, modified, repaired or inspected by an Approved Maintenance Organisation (AMO);
3. Historical records logs or cards for helicopter parts either new or used.

Back-to-Birth Traceability

The term "back to birth traceability" describes documentation that clearly demonstrates every owner and installation of a part all the way back to the time that it was manufactured (the "birth" of the part) (ASA, 1999). Traceability of aircraft parts is good to know but it is not necessary according to FAA but the owner or operator are required to be able to show the current status of most especially life-limited parts and this includes the Time Since New (TSN), Time Since Overhaul (TSO), Cycle Since New (CSN), Cycle Since Overhaul (CSO) and sometimes calendar days, months or years. Back-to-birth traceability enables the owner or operator to trace the part back to the manufacturer, the maintenance organization that carried out maintenance on the part, each operator that may have used the part or the aircraft the part was installed on. For helicopter parts and engines that have historical service cards/logs and logbooks respectively, it is very easy to trace the previous information on the use of the part, the reason for removal, aircraft it was installed on, the last time it was overhauled, repaired, modified or inspected and the modification status.  Records that must be kept by the owner or operator of life limited parts include the name of the part, manufacturer part number, serial number, date of installation, TSN/CSN, TSO/CSO, date removed, reasons for removal and signature and certificate number of the person installing or removing the part. All these records are required to determine the eligibility and serviceability of the life limited part before installation on aircraft as life limited part that has expired should not be installed on aircraft.

Conclusion

            Either approved or acceptable parts, traceability to an approved source and eligibility must be in accordance with an approved data or industrywide accepted data. Aircraft parts can be time limited or unlimited based on the data for which they were manufactured. A time limited parts could either be ultimate/retirement life limited or limited by overhaul time. The service life of life limited parts installed on aircraft are expressed in calendar time, flight hours, landings or cycles. The information on the service life for life limited parts can be obtained from the OEM maintenance program or ICAs. The part number on the data plate on the part and the one in the maintenance program or ICAs must tally which shows initial traceability of the source while the historical records and / or the current status can be determined from the release documents or airworthiness approval tags before installation. Any aircraft part that does not fall under approved parts or acceptable parts are Suspected Unapproved Parts (SUPs) that should not be installed on a type-certificated aircraft and such should be reported to FAA or the regulatory authority with jurisdiction on the aircraft.