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Section 27  Safety Assurance System: Conducting a Program Manager/Air Carrier/Air Agency Inspection to Detect Unapproved Parts


A.    Program Tracking and Reporting Subsystem (PTRS). For Title 14 of the Code of Federal Regulations (14 CFR) part 91 subpart K (part 91K), use PTRS activity codes 3622 and 5622.

B.    Safety Assurance System (SAS):

1)    For 14 CFR part 121/135, use SAS automation. This section is related to SAS Element 4.7.2 (AW), Aircraft Parts/Material Control.
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2)    For 14 CFR part 145, use SAS automation. This section is related to SAS Element 4.7.4 (AW), Parts and Materials.

6-763    PURPOSE. This section provides guidance for principal inspectors (PI), aviation safety inspectors (ASI), and aviation safety technicians (AST) conducting unapproved parts surveillance/inspections at part 91K program manager, air carrier, and air agency facilities. This guidance will assist inspectors in performing a comprehensive inspection, including parts accepted into their system and parts approved for return to service by the program manager/air carrier/air agency. Consider information within Volume 14, Chapter 3, Section 3 that discusses false and misleading statements regarding aircraft products, parts, appliances, and materials.

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6-764    DISCUSSION. Principal maintenance inspectors (PMI), principal avionics inspectors (PAI), and ASIs will conduct surveillance to detect unapproved parts to ensure compliance with 14 CFR and policy outlined in the current edition of Federal Aviation Administration (FAA) Order 8120.16, Processing Reports of Suspected Unapproved Parts. A part is considered to be unapproved if it has been produced contrary to 14 CFR part 21, or if it has been intentionally misrepresented (i.e., false, fraudulent, and/or counterfeit). Specific definitions related to the Suspected Unapproved Parts (SUP) Program are contained in Order 8120.16.

6-765    ACTION. ASIs charged with certificate management responsibilities for air carriers and air agencies, as well as management specification (MSpec) authorizations for part 91K program managers, should ensure that those operators/program managers have procedures to prevent both unapproved parts from entering into their parts inventories and/or being released from their system.

A.    Inventories. ASIs should evaluate their program manager/air carrier/air agency’s parts receiving inspection procedures to ensure that only approved parts and materials are accepted into inventories. A representative sample of the inventory should be examined to validate parts for the following, as applicable:

1)    New parts (accepted into the system) that were produced under part 21 or were otherwise approved by the Administrator.
2)    Documentation identifies the approved manufacturer of that part/material and states that the part/material complies with the applicable regulations and contains the required information. Documentation may include:

·    FAA Form 8130-3, Authorized Release Certificate, Airworthiness Approval Tag;

·    Authorized Release Certificate European Aviation Safety Agency (EASA) Form 1;

·    Transport Canada (TC) Authorized Release Certificate –Form One;

·    Joint Aviation Authority (JAA) Form 1, Authorized Release Certificate (leave as is); and

·    Shipping tickets, packing slips, purchase orders, material certifications, and/or certificates of conformity.

3)    FAA Parts Manufacturer Approval (PMA) parts are marked per 14 CFR part 45, § 45.15.
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4)    Parts produced under an FAA Technical Standard Order Authorization (TSOA) are also marked per § 45.15.
5)    Standard parts (e.g., bolts and nuts) and raw materials (e.g., sheet metal and welding rods) contain certification statements or other evidence that they conform to established industry or United States (U.S.) Government specifications.
6)    Used parts have an approval for return to service by an FAA‑certificated person (e.g., air carrier, repair station, or mechanic).
7)    Parts with a specified replacement time, inspection interval, or related procedures are permanently marked with a part number and serial number (or equivalent) per § 45.15 or § 45.16, or dispositioned in accordance with 14 CFR part 43, § 43.10.
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NOTE:  For additional information, refer to the current editions of Advisory Circular (AC) 20-62, Eligibility, Quality, and Identification of Aeronautical Replacement Parts; and AC 20-154, Guide for Developing a Receiving Inspection System for Aircraft Parts and Material.

NOTE:  Parts that have not been maintained or altered in accordance with the provisions of part 43 are ineligible for installation on a type-certificated product. These parts are to be evaluated and investigated in accordance with improper maintenance guidance in Volume 6, Chapter 2, Section 37.

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B.    Maintenance Records/Work Orders. ASIs should review a representative sample of maintenance records and/or work orders of parts approved for return to service by the program manager/air carrier/air agency to ensure approved parts were used during the course of maintenance, repair, or alteration.

6-766    COMPLIANCE ACTION. If a mistake is discovered that is honest or legitimate, and the person willingly corrects it, document the deviation as a Compliance Action per Volume 14, Chapter 1, Section 2. However, if the misleading character of the statement remains, or the mistake is one in a series of such mistakes, the FAA will presume knowledge on the part of the person and must report their findings of unapproved parts and/or SUP.


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A.    SUP Findings. FAA personnel shall report findings of SUP and unapproved parts, as outlined in Order 8120.16. (Also refer to the current edition of AC 21-29, Detecting and Reporting Suspected Unapproved Parts.)

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B.    Reporting SUP Findings. To report findings of SUP, submit an FAA Form 8120-11, Suspected Unapproved Part Report, to the Office of Audit and Evaluation Reporting & Data Analysis Branch (AAE-300) by completing and forwarding the FAA Form 8120-11 to the FAA Hotline. The form and instructions for completion are available at http://www.faa.gov/aircraft/safety/programs/sups/ or http://employees.faa.gov/tools_resources/forms/.

6-768    TASK OUTCOMES. ASIs are to document inspections in accordance with the applicable guidance.

A.    Complete the PTRS Entries. For part 91K:

1)    PTRS Activity Codes 3668/5668, Surveillance/Agency/Inspection/Unapproved Parts. ASIs shall make a PTRS record entry to record the surveillance for each part 91K. Use PTRS codes 3668/5668 to record the inspection activity, along with the primary area, keyword, opinion code, and comments (as applicable). Record Compliance Action taken to correct unintentional deviations or mistakes as described in Volume 14, Chapter 1, Section 2.
2)    PTRS Activity Codes 3775/5775, Investigation/Technical Support. Use PTRS codes 3775/5775 to record activity associated with SUP investigations. Refer to Order 8120.16 for information regarding SUP investigations.
3)    PTRS Activity Codes 3622/5622, Surveillance/Part 91K Program Manager/Air Carrier/Operators/Inspection/Unapproved Parts. ASIs shall make a PTRS record entry to record the surveillance for each program manager. Use PTRS codes 3622/5622 to record the inspection activity, along with the primary area, keyword, opinion code, and comments (as applicable).
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B.    Follow SAS Guidance Modules 4 and 5. For part 121/135/145.

RESERVED. Paragraphs 6-769 through 6-781.