MAINTENANCE AND CERTIFICATION

Maintenance and Certificaiton

Suspected Unapproved Parts (SUP)

by Ganesh Pandey, Civil Aviation Safety Inspector, Aircraft Maintenance and Manufacturing, Standards, Civil Aviation, Transport Canada

This article focuses on the effect of SUPs on aviation safety and how Transport Canada Civil Aviation (TCCA) communicates with internal and external SUP stakeholders. Yes, SUPs do still exist. However, TCCA-approved distributors, maintenance and manufacturing organizations, and individuals in general aviation work in partnership to maintain our high safety levels. This is achieved by controlling the parts used in aircraft by means of an approval system that aims to eliminate the potential risk posed by the entry of unapproved parts into the Canadian aviation community.

Parts that meet the requirements of the Canadian Aviation Regulations—Part V, Subpart 71 (CAR 571) are approved parts and acceptable/eligible for installation. When it is not clear whether a part meets CAR 571 requirements, it becomes an SUP. From that point on, it is a shared task to remove the suspicion by identifying it as either approved or unapproved. In CAR 591, the definition of an unapproved part is as follows:

“unapproved part”—means any part installed or intended for installation in a type certified aeronautical product, that was not manufactured or certified in accordance with the applicable regulations of the state of production or that is improperly marked or that is documented in such a manner as to mislead with regard to the origin, identity or condition of the part.

Based on this SUP definition, parts that have been maintained or repaired and returned to service by CAR-authorized persons or facilities but that have been subjected to sub-standard maintenance (e.g. incorrect or missing processes, etc.) are not considered SUPs. Although considered unairworthy parts, they should not be reported to TCCA as SUPs. However, they should be treated as unairworthy, and appropriate action should be taken to correct the circumstances leading to the sub-standard maintenance. The SUP Program traces an SUP to its supply-line point of origin at which its certification or approval was issued and corrects the circumstances that created the SUP or allowed the part to enter the system.

Thrust bearings

The thrust bearing on the left was determined to be unapproved
during a routine inspection. The correct bearing
is shown on the right.

Reporting the SUP is the first step in the process. In Canada, the mechanism for reporting an SUP is through the Service Difficulty Report system—as outlined in CAR 591. At present, CAR 591 requires that an SUP be reported for each specific occurrence. The aviation industry is responsible for reporting an SUP using TCCA Form 24-0038 (“Service Difficulty Report”) or through the Web Service Difficulty Reporting System (WSDRS) at: http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/CAWIS-SWIMN/logon-wsdrs-cs16101.asp?Lang=E.

When an SUP report is made, care should be taken to identify the person(s) or
organization(s) where the part was obtained, which should in turn lead to where the part was certified. There may be several sources in a supply chain; however, there should be only one at the origin, which will be the focus of follow-up activities. The SUP shall be removed from service, isolated, and quarantined for further follow-up and corrective actions, as necessary.

Once TCCA has received the report, the Transport Canada Centre is responsible for following up on SUPs submitted under its jurisdiction. This follow-up is co-ordinated through TCCA Headquarters, particularly when it involves multiple regions or international organizations. Normally, the follow-up is a routine function within Canada; however, many SUP follow-ups require coordination with stakeholders outside Canada.

When the SUP source and origin are outside Canada, TCCA Headquarters forwards a detailed report and supporting investigative materials to the appropriate foreign civil-aviation authority to investigate. TCCA Headquarters will ensure that follow-up action is completed and closures are made. Since the Canadian aviation industry buys a large portion of its aviation-related equipment and parts from suppliers in the U.S. that fall under the authority of the Federal Aviation Administration (FAA), TCCA maintains a close relationship with FAA SUP counterparts. When the source of an SUP is American, TCCA provides all the supporting materials along with FAA Form 8120-11 (“Suspected Unapproved Parts Notification”) to the FAA SUP Program Office so that it can investigate. The Canadian aviation community can also use this form for voluntary reporting directly to the FAA. It can be found on the FAA SUP Program Office’s Web site at: http://www.faa.gov/forms/index.cfm/go/document.information/documentID/623276.

TCCA does not list unapproved parts discovered through the program. Instead, once an SUP has been confirmed as an unapproved part, action is taken for the specific case and may vary from taking corrective action with the responsible organization, to issuing a service difficulty alert or an airworthiness directive, to notifying Canadian operators and maintainers, with the level of notification depending on the nature of the SUP.

Some foreign civil aviation authorities utilize an unapproved parts notifications system, as does the FAA. These systems may be used to inform TCCA about unapproved parts. In these cases, the information is normally received and forwarded to Transport Canada Centres via the applicable regional office to further inform Canadian organizations. The FAA does publish its unapproved parts notifications on its Web site (see address below). At present, some selected unapproved parts notifications are published as a courtesy in the TCCA publication, Feedback. However, not all of the FAA unapproved parts notifications are published in Feedback; therefore, it is always advisable to review the FAA Web site directly at: www.faa.gov/aircraft/safety/programs/sups/upn/.

Communications and partnering are key to eliminating SUPs from the Canadian aviation system. While the aviation community continues to report SUPs, and provide information for follow-up, TCCA will continue to chase down leads, identify the source of unapproved parts, and remove them from the system. As it evolves through reorganization, TCCA plans to improve its communications with new Web site structures and more effective requirements.

All aeronautical products subject to maintenance and parts modification and/or replacement must conform to the type design and allow for safe operation.

Fatigue Risk Management System for the Canadian Aviation Industry: Policies and Procedures Development Guidelines (TP 14576E)

This is the fifth of a seven-part series highlighting the work of the Fatigue Risk Management System (FRMS) Working Group and the various components of the FRMS toolbox. This article briefly introduces TP 14576E—Policies and Procedures Development Guidelines. Intended for managers, this guide proposes a policy structure and provides examples and guidelines to help organizations through the process of designing fatigue risk management policies and procedures. The complete FRMS toolbox can be found at www.tc.gc.ca/eng/civilaviation/standards/sms-frms-menu-634.htm. —Ed.

How to use TP 14576E
A fatigue risk management system (FRMS) is an integrated set of management policies, procedures, and practices for monitoring and improving the safety and health aspects related to fatigue within your organization. This guide is intended to help you to build an effective fatigue risk management policies and procedures manual tailored to your specific operational requirements. Such a manual should provide both the overall governance policy for fatigue risk management and a detailed framework for how to manage fatigue on a day-to-day basis within the workplace.

Implementing an FRMS does not mean you need to create another set of documents. Some aspects of the policy may already be covered in your safety management system (SMS) manual. If this is the case, just cross-reference or copy the information in your FRMS manual.

In accordance with the Canadian Aviation Regulations (CARs), the FRMS manual must clearly define:

  • the level of senior management commitment;
  • the purpose and goals of the FRMS;
  • the responsibilities of all employees for managing fatigue risk;
  • the training requirements;
  • the reporting procedures for fatigue-related hazards;
  • the fatigue-reporting policy (any punitive actions that may be taken as a result of non-compliance, for example); and
  • a procedure for the evaluation and continuous improvement of the FRMS.

This approach is in line with Transport Canada’s (TC) guide to implementing an SMS: Safety Management Systems for Flight Operations and Aircraft Maintenance Organizations—A Guide to Implementation (TP 13881E)1.

Each section of TP 14576E has three components:

  • Introduction—information about the purpose, theory, and framework of the given FRMS policy component;
  • Points to consider—a summary of the main points to be covered in that section of the manual. These have been framed as questions that can be used as a framework for discussing the core components of an FRMS in consultation workshops; and
  • Sample text—examples of what might be included in the given policy-component section. These examples have been provided so that organizations can see the style of phrasing and content acceptable to TC. Each section of your policy manual should be tailored to the specific needs of your organization.

Each section of the FRMS guide is labelled as either mandatory or recommended:

  • mandatory sections must be included in your document. The sample text provided in the guide should be reviewed and modified appropriately to suit your operation.
  • recommended sections should be discussed with employees or your FRMS committee to determine whether they are appropriate and how they should be adapted to meet your operational requirements.

The guide follows the same organizational structure recommended for the FRMS policies and procedures manual.

Preamble (mandatory)
The FRMS manual should include clearly defined policies, procedures, and practices to ensure that the risk of fatigue-related error is reduced as much as possible. The FRMS should be tailored to your operation. To ensure its maximum effectiveness, the manual must reflect what you actually do.

The aim of implementing an FRMS is to effect change in organizational culture that results in enhanced flight safety and a safer working environment. Organizations must take the time to write their own FRMS policy statements and not simply paraphrase generic ones. The FRMS manual should be used as the primary means of communicating to employees the FRMS policies and procedures to be followed during regular operations.

You should review and update the FRMS manual one year after implementation and on a set schedule thereafter (e.g. every two years). You will need to include a control process for amending documentation as per the CARs documentation requirements.

Points to consider

  • Why is the organization implementing an FRMS?
  • Who will be affected by FRMS implementation?
  • What are the basic responsibilities of employees within the FRMS?
  • How often will the FRMS policy be reviewed and updated?

Document control (mandatory)
All Canadian civil aviation certificate holders are required by the CARs to amend the FRMS manual when necessary. You should systematically create, circulate, and record any amendments to the FRMS policy. You may choose to use your current procedure for this or the one described in the sample text included in TP 14576E. This text provides a basic amendment process for a simple FRMS manual. You may wish to add extra controls suitable for the size or complexity of your operation.

Points to consider

  • How will amendments to the FRMS policy be recorded?
  • How will employees be informed of FRMS policy amendments?
  • How will employee understanding of FRMS policy amendments be recorded?

We conclude this overview of TP 14576E by encouraging our readers to view the entire document at http://www.tc.gc.ca/Publications/en/TP14576/PDF/HR/TP14576E.pdf.

1 This document has since been replaced by Advisory Circular 107-001—Guidance on Safety Management Systems Development, which can be found at: http://www.tc.gc.ca/eng/civilaviation/opssvs/managementservices-referencecentre-acs-100-107-001-toc-117.htm.

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