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Testimony of Gary Clemmer, Northwest Airlines on Suspected Unapproved Parts. Safety Hearing October 8, 1997

Air carriers have depended upon the manufacturers part lists for reference in the purchase and installation of aircraft parts. This is a widely accepted practice reinforced by ATA Specification 100 statement "The Illustrated Parts Catalog (IPC) is intended for the use in identification and requisitioning of replaceable aircraft parts and units".

Most Airlines employ the use of an Acceptable Parts List as one method for its part requisitioning, receiving, stocking and installation. These are parts listed by vendor number or supplier code in the manufacturer parts catalog not carried under the manufacturers part number. Under current Federal Aviation Regulations and FAA Directives, procurement of parts from manufacturer parts list are not approved unless they have an acceptable approval classification such as Parts Manufacturer Approval,

Technical Standard Order, Drop Ship Authority, Technical Assist letter, Standard or Commercial parts or Quality Surveillance by the manufacturer.

The industry has suffered from unscrupulous persons dealing in aircraft parts which has attracted considerable notoriety, the FAA has stepped up its enforcement of parts certification rules. Additionally, product liability issues have arisen with both manufacturer and air carriers. Airline suppliers and repair stations are taking enforcement action very seriously and are making a concerted effort to bring all aircraft parts to an FAA approved status. Most major air carriers are taking actions to protect themselves by assuring they obtain and use FAA approved parts, which includes parts exchanged between carriers. Today, proper certification is a must in order to do business.

However, lack of clear understanding of part certification coupled with seemingly inconsistent rules governing the part certification process are leading the industry to self regulate without real consensus.

In a more definitive way, should the primary burden of reproducing airworthy parts shift from the operator (buyer) to the manufacturer and the FAA who has oversight authority.

While the adage "Buyer Beware" is always with us, it does not mean that practical precautions cannot be taken to give a reasonable assurance that parts procured by an air carrier are airworthy and meet installation requirements for FAA type certified products. Our system seems to be confused with definitions, numerous rules and orders that lend themselves to individual interpretations by a wide variety of persons not always knowledgeable in aviation practices. In fact, many manufacturers of aircraft parts have little knowledge of aviation regulatory requirements. In this case there is a de facto responsibility by the operator (air carrier) to assure airworthiness and give oversight for quality manufacturing. This burden has been assumed by the air carriers to protect themselves in order to provide safe and reliable aircraft for the flying public.

Maintain a position that the FAA declare rulemaking that is more definitive in directing the burden of quality upon the manufacturer. Moreover, the FAA must have oversight responsibilities with adequate resources.

* Require certification approval at the manufacturer level for all aircraft parts except standard and commercial parts.

Require a universal Airworthiness Certification form accepted domestically and internationally.

Issues that would promote the above mentioned concepts:

Definition of Airworthy and Approved are not synonymous.

Airworthy part (FAA Order 8130.2)

- Conforms to type certificate requirements.

- Must be in condition for sale operation.

Approved part (FAA Order 8120.10)

- Must meet one of eleven criteria in FAA Order 8120.10

We speak of airworthy parts, however only approved parts are addressed in the parts certification process.

If the FAA assumes the responsibility for certification primarily at the manufacturer level it would only add to a more complete and protected policy for processing of aircraft parts that meet quality standards. This could be coupled with the air carrier’s own responsibilities for parts awareness under its operating certificate. The

FAA would still use its Suspected Unapproved Parts (SUP) office for reporting of unapproved parts that might escape normal quality standards. Together the air carrier and FAA would work to rid the industry of this problem.