Suspected unapproved parts

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Suspected Unapproved Parts (SUP) (English, literally 'presumably not approved components', technically translated 'parts of dubious origin') generally describe components from the aerospace industry whose usability is doubtful due to certain criteria. These are components that presumably do not meet the requirements of aviation law and require an examination before use.

Components that appear unusable because they may not meet the relevant requirements for development, manufacture, maintenance or documentation are referred to as SUP. As long as there are doubts about the usability of a component, use of the component in the aircraft must be excluded for safety reasons.

SUP is not having Bogus Parts (Engl. Bogus , counterfeit ' , spare parts , spare parts' ) as equal, as is the case with this as opposed to always SUP criminal intent.

As soon as existing doubts about the airworthiness are dispelled, an SUP becomes an approved component. If it is not possible to dispel these doubts using all available means, the SUP will become an unapproved part. The use of a non-approved component in the aircraft must be unequivocally excluded.

General information

The US -Luftfahrtbehörde FAA operates a program used to display such parts.

The Federal Association of the German Aerospace Industry BDLI has set up a working group on the subject of SUP.

Information on the subject can also be found on the LBA website .

Definitions

The following definitions were established within the framework of the BDLI working group Suspected Unapproved Parts and should be used accordingly in the aerospace industry.

Approved components ( Approved Parts )

are based on approved development documents and are in accordance with the applicable aviation regulations

  • manufactured,
  • maintained and
  • documented.

Unapproved parts ( Unapproved Parts )

are not based on approved development documents or are not in accordance with the applicable aviation regulations

  • manufactured,
  • maintained and
  • documented.

Allegedly not approved components ( Suspected Unapproved Parts )

are parts that are presumably based on unapproved development documents or that do not comply with aviation law

  • manufactured or
  • maintained or
  • were documented.

Counterfeit components ( Bogus Parts )

are unauthorized parts that were manufactured or put into circulation with criminal intent.

Legal basis

Regulation (EC) No. 216/2008, Article 5, Paragraph 2c: An aircraft is airworthy if it can be demonstrated that it corresponds to the type design approved in its type certificate and the relevant documents, inspections and tests prove that the aircraft meets the requirements for ensures safe operation. This includes the products, parts and equipment installed in the aircraft.

Regulation (EC) No. 1321/2014 of the Commission of December 17, 2014 on the continuing airworthiness of aircraft and aeronautical products, parts and equipment and the granting of permits to organizations and persons who carry out these activities.

Annex I to Regulation (EC) 1321/2014 (Part M)

MA504 Monitoring of non-operational components

a) A component is considered to be inoperable if any of the following circumstances apply:

  1. Expiry of the service life specified in the maintenance program,
  2. Non-compliance with the applicable airworthiness directives and other mandatory requirements prescribed by the agency for continued airworthiness,
  3. non-existent information necessary to determine airworthiness status or suitability for installation,
  4. Signs of defects or malfunctions,
  5. a malfunction or accident that could affect its operability.

c) Components that have reached their approved service life or have an irreparable defect must be shown as scrap and they may no longer enter the system for the material supply [...] (see also 145.A.42 d))

d) Persons or organizations responsible under Part M must in the case of a component classified as non-reusable in accordance with paragraph (c)

  1. keep such a component in a location as specified in paragraph (b), or
  2. ensure that the component is modified in such a way that it cannot be economically recovered or repaired before responsibility for such a component is transferred.

Annex II to Regulation (EC) 1321/2014 (Part 145)

145.A.42 Acceptance of components

d) Components that have reached their approved service life or have an irreparable defect must be identified as scrap and they may no longer enter the system for the material supply [...]

LBA circular no. 18-01 / 03-2

to all approved manufacturing companies, maintenance companies, aeronautical companies and independent inspectors of aircraft equipment.

"Finding and reporting parts of dubious origin"

FAA AC 21-29C - Detecting and Reporting Suspected Unapproved Parts

Describes the requirements of the FAA with regard to SUP and is aimed at all aviation companies within the scope of the FAA legislation.

Dealing with SUP

Affected processes and company areas

  1. Supplier approval
  2. Purchasing
  3. Goods Receipt
  4. storage
  5. Installation / use

Notification of SUPs

If, despite internal research, doubts about the usability of a component cannot be dispelled, further measures may be necessary.

  1. Within the scope of the FAA, there is an obligation to report SUPs within the framework of the FAA Suspected Unapproved Parts Program. This also applies to European companies that have a corresponding FAA approval, e.g. B. German companies that have an FAA Certified Repair Station approval as part of the EU - FAA Bilateral (BASA).
  2. European approved companies are strongly advised to also report SUPs to the respective responsible aviation authority. In Germany, the Luftfahrt-Bundesamt (LBA) is the responsible aviation authority for SUP matters.

Individual evidence

  1. a b FAA website
  2. a b Website of the AG SUP of the BDLI
  3. a b c Website of the Luftfahrt-Bundesamt (LBA)  ( page no longer available , search in web archivesInfo: The link was automatically marked as defective. Please check the link according to the instructions and then remove this notice.@1@ 2Template: Dead Link / www.lba.de  
  4. Regulation (EC) No. 216/2008 at EUR-Lex .
  5. a b c Regulation (EC) No. 2042/2003 at EUR-Lex .
  6. FAA Advisory Circualar AC 21-29