U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Guide for Developing a Receiving Inspection System for Aircraft Parts and Materials Date: 8/12/15 Initiated by: AFS-300 AC No: 20-154 Change: 1
1. PURPOSE. This advisory circular (AC) provides guidance and information for incorporation into operators’ existing receiving/inspection systems to help prevent the introduction of unairworthy parts into inventories. The aim is to establish sufficient traceability to establish that the part(s) were manufactured under Title 14 of the Code of Federal Regulations (14 CFR) part 21, were previously determined to be Airworthy under 14 CFR part 43, and produced to established industry or U.S. Government standards or accepted foreign standards.
Like all AC material, this AC is not mandatory and does not constitute a regulation. It is issued for guidance and to outline a method of compliance with the rules. This is one means but not the only means for developing a receiving inspection system. In lieu of following the method(s) prescribed herein, the applicant may elect to follow an alternate method.
2. PRINCIPAL CHANGES. This change incorporates new information, to ensure that the AC does not conflict with European Aviation Safety Agency (EASA) guidance, and includes editorial changes and updates to references.
PAGE CONTROL CHART Remove Pages Dated Insert Pages Dated Pages 2 thru 5 12/12/05 Pages 2 thru 5 8/12/15 Page 7 12/12/05 Page 7 8/12/15 Pages 12 and 13 12/12/05 Pages 12 and 13 8/12/15 Pages 15 thru 17 12/12/05 Pages 15 thru 17 8/12/15 Appendix 1 Page 2 12/12/05 Appendix 1 Page 2 8/12/15 Appendix 2 Page 2 12/12/05 Appendix 2 Page 2 8/12/15 ORIGINAL SIGNED by /s/ John Barbagallo Deputy Director, Flight Standards Service
U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Guide for Developing a Receiving Inspection System for Aircraft Parts and Material Date: 12/12/05 Initiated by: AFS-300 AC No: 20-154 Change:
1. PURPOSE. This advisory circular (AC) provides guidance and information for incorporation into operators’ existing receiving/inspection systems to help prevent the introduction of unairworthy parts into inventories. The aim is to establish sufficient traceability to establish that the part(s) were manufactured under Title 14 of the Code of Federal Regulations (14 CFR) part 21, were previously determined to be Airworthy under 14 CFR part 43, and produced to established industry or U.S. Government standards or accepted foreign standards.
Like all AC material, this AC is not mandatory and does not constitute a regulation. It is issued for guidance and to outline a method of compliance with the rules. This is one means but not the only means for developing a receiving inspection system. In lieu of following the method(s) prescribed herein, the applicant may elect to follow an alternate method.
2. APPLICATION. These elements are recommended for incorporation into operators’ existing receiving/inspection systems to help prevent the introduction of unairworthy parts into inventories. The aim is to establish sufficient traceability to establish that the part(s) were manufactured under part 21, were previously determined to be Airworthy under part 43, and produced to established industry or U.S. Government standards or accepted foreign standards.
3. REGULATIONS AND GUIDANCE MATERIAL.
a. Related 14 CFR Parts Include:
(1) Part 1, Definitions and abbreviations.
(2) Part 21, Certification procedures for products and parts.
(3) Part 43, Maintenance, preventive maintenance, rebuilding, and alteration.
(4) Part 45, Identification and registration marking.
b. Title 49 of the Code of Federal Regulations (49 CFR), Transportation.
c. Related Guidance Materials Include (current editions):
(1) AC 00-56, Voluntary Industry Distributor Accreditation Program.
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(2) AC 20-62, Eligibility, Quality, and Identification of Aeronautical Replacement Parts.
(3) AC 21-29, Detecting and Reporting Suspected Unapproved Parts.
(4) AC 21-43, Production under 14 CFR Part 21, Subparts F, G, K, and O.
(5) AC 43-9, Maintenance Records.
(6) AC 45-2, Identification and Registration Marking.
(7) AC 145-11A, Repair Station Guidance for Compliance with the Safety Agreement between the United States and the European Union.
(8) AC 145-9, Guide for Developing and Evaluating Repair Station and Quality Control Manuals.
(9) FAA Order 8130.2, Airworthiness Certification of Aircraft and Related Products.
(10) FAA Order 8130.21, Procedures for Completion and Use of the Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag.
NOTE: Interested persons can access ACs and orders on the FAA home page at www.faa.gov, selecting Regulations and Policies selecting the link for ACs or orders, or at http://www.airweb.faa.gov. Copies of FAA ACs and orders also can be obtained free of charge from the U.S. Department of Transportation, Subsequent Distribution Office, Ardmore East Business Center, 3341 Q. 75th Ave., Landover, MD 20785.
4. BACKGROUND. The FAA has expressed ongoing concern that unairworthy appliances, components, or parts thereof, as well as materials, are being installed on type-certificated (TC’d) products. Therefore, the FAA recommends that parts installers, maintainers, manufacturers, and suppliers establish an enhanced receiving inspection system to help eliminate the safety risk posed by unairworthy components, parts, or materials. A comprehensive network of regulatory controls governs the design, manufacture, installation, and maintenance of aircraft parts.
However, whether by inadvertent or deliberate action, components or parts have been reported that do not meet regulatory requirements and are not eligible for installation. Maintenance providers should have a procedure describing their processes for procuring, receiving, and inspecting aircraft components, parts, and materials. These procedures will ensure conformity to the type design or specifications to ensure that the product being returned to service conforms to specified airworthiness requirements and is in a condition for safe operation.
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5. DEFINITIONS.
a. Airworthy.
(1) The aircraft must conform to its TC. Conformity to type design is considered attained when the aircraft configuration and the components installed are consistent with the drawings, specifications, and other data that are part of the TC, which includes any Supplemental Type Certificates (STC) and field-approved alterations incorporated into the aircraft.
(2) The aircraft must be in a condition for safe operation. This refers to the condition of the aircraft relative to wear and deterioration, for example, skin corrosion, window delamination/crazing, fluid leaks, tire wear, etc.
b. Approved Part. A part or part thereof that was designed, fabricated, produced, and/or maintained under the appropriate regulation. This could include the following:
(1) Produced in accordance with a Parts Manufacturer Approval (PMA) issued under part 21 subpart K.
(2) Produced in accordance with a Technical Standard Order Authorization (TSOA) issued under part 21 subpart O.
(3) Produced during the TC application process under part 21 subpart B, or the STC application process under part 21 subpart E, prior to the issuance of the certificate; subsequently determined to conform to the approved TC or STC data (refer to part 21, § 21.303(b)(1)).
(4) Produced under a TC without a separate production authorization, and an Approved Production Inspection System (APIS), in accordance with part 21 subpart F.
(5) Produced under a Production Certificate (PC) (including production by a “licensee” if produced under PC authority), in accordance with part 21 subpart G.
NOTE: A licensee is a person who has exclusive or nonexclusive rights to apply for a PC (refer to § 21.132 under a “licensing agreement” if they hold or have been awarded rights to the benefit of a TC holder from the owner of the TC. The term licensing agreement does not imply or infer that a PC holder may grant production approval to any party on behalf of the FAA.
Authority granted by a PC holder to a supplier to ship parts directly to a customer of the PC holder is NOT considered to be a licensing agreement.
(6) Manufactured in accordance with an approval under a bilateral airworthiness agreement under part 21 subpart N, approval of engines, propellers, materials, parts, and appliances for import.
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(7) “Standard parts” has come to be understood by the aviation and manufacturing public as meaning a part, the specification for which has been published by a standard-setting organization or by the U.S. Government, and the FAA has traditionally regulated parts production with that understanding. Examples of such “traditional” standard part specifications include National Aerospace Standards (NAS), Air Force-Navy Aeronautical Standard (AN), Society of Automotive Engineers (SAE), SAE Aerospace Standards (AS), and Military Standard (MS). The FAA considers parts conforming to these standards as standard parts. For a specification to be acceptable, it must include information on the design, materials, manufacture, and uniform identification requirements. The specification has to include all the information necessary to produce the part and ensure its conformity to the specification. Furthermore, the specification must be publicly available, so that any party is capable of manufacturing the part.
The above examples of accepted specifications fulfill those criteria.
(a) In the past the FAA has applied § 21.303(b)(4) to parts that have specifications when a determination of physical conformity to a design could be made. This application largely excluded classes of parts in which the parts are conformed not on the basis of their physical configuration but by meeting the specified performance criteria. Much of the componentry used in electronic devices are manufactured under standard industry practices, often to published specifications developed by standards organizations such as the SAE, the American Electronics Association, Semitec, the Joint Electron Device Engineering Council, and the American National Standards Institute (ANSI). Such standards developed by these bodies is overseen by the Institute of Electrical and Electronic Engineers (IEEE), the IEEE Standards Committee, as well as the electrical and electronics industry, at large, which depends upon characteristic design standards for consistency in operation and performance.
(b) The FAA notified the public in the Federal Register on March 5, 1997 (62 FR 9923) that the interpretation of an acceptable U.S. Government- or industry-accepted specification may include specifications that may be limited to detailed performance criteria, complete testing procedures, and uniform marking criteria. These parts are best exemplified by discrete electrical and electronic parts, which include resistors, capacitors, diodes, transistors, and nonprogrammable integrated circuits (e.g., amplifiers, bridges, switches, gates, etc.).
Conversely, large-scale, application-specific, or programmable integrated circuits; hybrids, gate arrays, memories, central processing units (CPU), or other programmable logic devices would not be considered standard parts and are not discrete.
(8) Parts produced by an owner or operator for the purpose of maintaining or altering their own product. Parts produced and used by the owner/operator cannot be sold separately outside their organization.
(9) A part that is fabricated by an FAA-certificated repair station or other authorized person for use in the performance of an alteration under STC or field approval in accordance with part 43 and the current edition of AC 43-18, Fabrication of Aircraft Parts by Maintenance Personnel. These parts cannot be sold separately and can only be used for their intended purpose.
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(10) A part (which is not for sale as a separate part) that is fabricated by a qualified person in the course of a repair for the purpose of returning a TC’d product to service under part 43.
(11) Approved in any other manner acceptable to the Administrator (see part 21 subpart K).
NOTE 1: Parts which have been maintained, rebuilt, altered, or overhauled, and approved for return to service in accordance with 14 CFR parts 43 and/or 145, are considered to be “approved parts.” Parts that have been inspected and/or tested by persons authorized to determine conformity to FAA-approved design data may also be found to be acceptable for installation.
NOTE 2: Military surplus parts (defined as parts which have been originally released as surplus by military, even if subsequently resold by manufacturers, owners/operators, repair facilities, or any other suppliers of parts) may fall under this condition providing they meet the airworthiness requirements for the product to be installed on.
NOTE 3: AC 20-62 should be referred to for information regarding eligibility and traceability of replacement parts.
c. FAA Form 8130-3, Authorized Release Certificate, Airworthiness Approval Tag.
FAA Form 8130-3 has become recognized as an industry standard form used for the following purposes: conformity inspections; airworthiness approval of new products, parts, and appliances;
splitting bulk shipments of previously shipped products, parts, and appliances; approval for return to service after maintenance, preventive maintenance, rebuilding, and alterations of products and parts; and export airworthiness approval of Class II and III products. Procedures for the completion and use of FAA Form 8130-3 are contained in Order 8130.21. When using FAA Form 8130-3 as a dual-release form, block 12 must be completed in accordance with, and contain the language specified in, the current European Aviation Safety Agency (EASA) Maintenance Annex Guidance (MAG).
d. Bilateral Aviation Safety Agreement (BASA). An executive agreement concluded between the United States and a foreign country for the purpose of promoting aviation safety.
Also known as an Agreement for the Promotion of Aviation Safety.
e. Commercial and Government Entity (CAGE) Code. A five-position code that identifies contractors doing business with the Federal Government, North Atlantic Treaty Organization (NATO) member nations, and other foreign governments. The CAGE code is used to support a variety of mechanized systems throughout the government and provides for a standardized method of identifying a given facility at a specific location. The code may be used for a facility clearance, preaward survey, automated bidders list, identification of debarred bidders, fast pay processes, etc.
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f. Direct Ship Authority. Suppliers to a Production Approval Holder (PAH) may ship replacement and modification parts directly to the end user without the parts being originally processed by the PAH or its associate facility’s receiving inspection facilities only if the PAH or associate facility:
(1) Authorizes the authority, in writing, to the supplier to ship directly to a user/operator.
An individual written authorization is not required for each direct shipment. The authorization may include limitations such as specific part numbers, time periods, or particular users/operators.
This authorization will be maintained by the PAH or associate facility for review by the cognizant Manufacturing Inspection District Office (MIDO)/certificate management office (CMO).
(2) Includes in its FAA-approved quality control or inspection system, controls to compensate for the absence of inspection normally conducted at the PAH’s or associate facility’s location, e.g., receiving inspection and test. Compensating factors should include onsite evaluations of the supplier and the inspection of the part at the supplier by:
(a) The PAH or associate facility, or
(b) The supplier under a delegated inspection authority from the PAH or associate facility.
(3) Ensures that each part shipped is accompanied by a shipping ticket, invoice, or other document containing a declaration that the individual part was produced under the terms of the production approval, and the inspection/acceptance has been accomplished by either the PAH/associate facility or by the delegated inspection authority. The shipping document for parts manufactured under PMA, PC, APIS, and TC should identify the product on which the part is eligible for installation. The shipping document for subcomponents manufactured for Technical Standard Order (TSO) articles should contain the TSO number. When FAA Form 8130-3 is used for this purpose, the direct ship authorization will be annotated in accordance with Order 8130.21.
(4) Provides the appropriate part marking information to the supplier.
(5) Advises its cognizant MIDO/CMO of each direct ship authorization.
g. Distributors. Brokers, dealers, resellers, or persons engaged in the sale of parts for installation on TC’d products.
NOTE: In an effort to provide owners and operators of aircraft a readily available guidance for determining acceptability of components and parts, the FAA published AC 00-56. This AC describes a system for the accreditation of civil aircraft parts distributors on the basis of voluntary industry oversight and provides information that may be used for developing accreditation programs. The FAA strongly endorses participation in such a program to improve the ability of certificated persons to establish the eligibility of parts for installation on TC’d products. Purchasers conducting business
Par 5 Page 7 with participants in this program should not be discouraged from implementing their own procurement and acceptance procedures (as outlined in AC 00-56). The Aviation Suppliers Association maintains a listing of participants in the voluntary program at the following Web site:
http://www.aviationsuppliers.org.
h. European Aviation Safety Agency (EASA). An agency of the European Union (EU), which has been given specific regulatory and executive tasks in the field of aviation safety and environmental protection. This agency therefore constitutes a key part of the EU’s strategy to establish and maintain a high level of civil aviation safety and environmental protection in Europe. EASA is located at Ottoplatz, 1, D-50679 Cologne, Germany. The postal address is Postfach 10 12 53, D-50452 Cologne, Germany. Telephone [49 221] 8999 000, facsimile [49 221] 8999 099 or email info@easa.europa.eu. When an EASA Form 1 is used as a dual release, block 12 must be completed in accordance with, and contain the language specified in, the current EASA MAG.
i. Export Certificate of Airworthiness (C of A). A certificate issued by the National Aviation Authority (NAA) of the country of export. The Joint Aviation Authority (JAA) Airworthiness Approval Form 1 (JAA Form 1 is valid if dated prior to 11/28/04), EASA Form 1 (valid after 11/28/04), and Transport Canada Authorized Release Certificate – Form One are examples of acceptable forms if the country of origin currently has a Bilateral Airworthiness Agreement (BAA) with the United States that provides for U.S. recognition of replacement parts produced in that country.
j. Inspection. The act of testing or checking a product or part thereof against established standards to assure it conforms to its design requirements and is in a condition for safe operation.
Inspection could include documentation review, visual inspections, bench or functional tests, preservation (condition), packaging, technical data, or shelf-life limits. Technical data could include, but is not limited to, maintenance manuals, Structural Repair Manuals (SRM), Type Certificate Data Sheets (TCDS), airworthiness limitations (AL), manufacturer’s service documents, Service Bulletins (SB), or engineering data.
k. Life-Limited Part. Any part for which a mandatory replacement limit is specified in the type design, the instructions for continued airworthiness (ICA), or the maintenance manual.
NOTE: An audit trail tracing a life-limited part back to its origin would only be required when the operator’s records are not complete enough for an accurate determination of the elapsed time on the part to be established. A request for such an audit trace would probably be the exception (Federal Aviation Decisions, Interpretation 1992-35).
l. Maintenance Implementation Procedures (MIP). Procedures for implementing the provisions of a BASA that applies to maintenance.
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m. Production Approval Holder (PAH). A holder of a PC, an APIS, a PMA, or a TSOA, who controls the design and quality of the product or part thereof.
n. Receiving Inspection Area. An area where parts and materials are initially received and evaluated to determine their airworthiness status and are inspected for conformity prior to acceptance into the serviceable stock area.
o. Serviceable Stock. Components, parts thereof, materials, or appliances that have been evaluated in accordance with the FAA-approved or accepted data and have been determined to be eligible for installation on TC’d products.
p. Signature. An individual’s unique identification, used for accepting a component or part thereof, material, or appliance received or inspected under its receiving inspection system. A signature may be handwritten, in the form of an inspection stamp, electronic, or any other form specified to be acceptable under the receiving inspection system.
q. Supplier. Any person who furnishes aircraft parts, materials, or other related services at any tier to the PAH of the product or part thereof.
r. Traceability. The ability to establish that a part or material was manufactured under part 21, or were previously determined to be Airworthy under part 43. Possible sources for making a traceability determination could be shipping tickets, invoices, parts markings (i.e., PMA, TSOA), data plates, serial/part numbers, manufacturing production numbers, maintenance records (which could include log book entries), work orders, or any other means acceptable to make a sound determination of airworthiness or any other means acceptable to the Administrator to make a sound determination of airworthiness.
NOTE: Caution should be exercised when receiving a “Certificate of Compliance” that has a statement such as “document with traceability to the manufacturer available upon request.” This does not alone establish traceability to the PAH.
s. Vendor. Any person or business establishment engaged in the sale or transfer of parts for installation in appliances or TC’d aircraft, aircraft engines, propellers, or appliances.
6. DEVELOPING THE RECEIVING INSPECTION SYSTEM PLAN. This recommended receiving inspection system plan is intended to help prevent the entry of unairworthy parts into inventories and therefore preclude their subsequent installation. The plan describing a receiving inspection system should be detailed to the extent that it meets all its objectives and expectations to ensure identification and traceability. Operators and air agencies should consider the scope of their operation’s complexity for the development of and enhancing their receiving inspection system. The system should be commensurate with the privileges and limitations of the operation.
Appendix 1 contains a suggested receiving inspection system checklist derived from the contents in this AC and Appendix 2 provides a suggested flow chart for making a documentation requirement determination. Departments within the operator or air agency, such as purchasing, auditing, maintenance, etc., should be made aware of the enhanced receiving inspection requirements through training or other documented procedural means. The following are
Par 6 Page 9 suggested minimum elements that may be considered for incorporation into the written receiving inspection system plan:
a. Responsible Person(s). The responsible person should ensure that all incoming materials such as standard parts, components, or parts thereof, articles, equipment, and materials are acceptable for use on TC’d products. In addition, the responsible person(s) should be identified in the plan and given authority for ensuring continuing quality control for all functions of the receiving and inspection written procedures and established standards.
b. Internal Quality Audit. Used to evaluate ongoing conformity with the receiving inspection system. Persons performing the quality audit as part of the evaluation program may be employed by or an agent to the operator or company. The objective of the internal quality audit process is to ensure that the receiving inspection system in place is adequate for its intended function and meets all the regulatory requirements, as well as satisfies the needs of the operator.
c. Training. Training of all receiving and inspection personnel is to ensure personnel have a thorough understanding of the receiving inspection system. The training syllabus should include as a minimum recognition in part identification, determining the current status of the part, conformance determination of the part, regulatory compliance requirements, inspection procedures, handling, storage, ordering procedures, bench or functional testing, and recordkeeping requirements. All training should be documented and personnel training records established and maintained during the period of employment. Recurrent training should be implemented for familiarization of practices and any changes to procedures, regulations, or policies.
d. Technical Data. Ensure currency, applicability, and adequacy for making proper evaluations. A procedure should be established to ensure that technical data is current in accordance with the regulations or manufacturer’s recommendations. This includes, but is not limited to, data such as:
(1) TCDSs;
(2) Airworthiness Directives (AD);
(3) U.S. or industry specifications;
(4) Illustrated parts lists or catalogs;
(5) Maintenance and/or overhaul manuals;
(6) SRMs;
(7) SBs/Service Letters (SL), or other manufacturer’s technical information;
(8) Parts markings;
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(9) Engineering drawings;
(10) Maintenance records/return to service;
(11) Other applicable data for making an airworthiness determination, etc.;
(12) Federal aviation regulations; and
(13) AC guidance.
e. Measurement/Test Equipment. Precision measurement devices, test equipment, and gauges used to verify conformance to the applicable regulations of part 43, § 43.13 and part 145, § 145.109(b), industry standards and specifications must be calibrated in accordance with an effective program to maintain accuracy to the standards of the National Institute of Standards and Technology (NIST), manufacturer’s specifications (to include foreign manufacture of test equipment), or the standards of another country that is comparable to NIST. Calibration records must be maintained, showing established intervals for calibration for each precision measuring device and procedures for taking actions on deficiencies. This would include having a recall system to prevent inadvertent use of uncalibrated equipment.
f. Written Receiving Inspection Procedures. Developing a receiving inspection system can be a difficult task, considering the numerous forms and the complexities of the various manufacturers’, repair facilities’, and parts suppliers’ (distributors’) paperwork involved, along with the receiving organization’s requirements. Written procedures for the receiving and inspection of incoming parts/materials should be developed according to the individual company’s or the operator’s complexity and regulatory requirements. As an example, the written procedures could include the following items:
(1) Establish minimum training requirements for receiving and inspecting personnel. The training curriculum should be based on the complexity of the organization’s needs.
(2) To help minimize confusion, distributors (sellers of parts) should be requested to fill all blank entries with “NA” to signify that the blank box or section is not applicable. The purchasing department should convey its document requirements to all distributors in order to create a smoother flow of parts and material into inventories.
(3) A checklist should be created for receiving inspectors that would clearly identify the origin and traceability “path” of the part or material. This would help reduce confusion and aid accountability within the receiving inspection department.
(4) A method to identify whether the parts were obtained from the primary or secondary vendor. Primary and secondary vendors are determined by the purchaser on the vendor’s compliance with the operator’s needs and performance for supplying the appropriate parts and materials. At times, it may be feasible to review the required documents before purchase of the item via electronic means.