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Bogus Parts
Are they still a problem for business aviation?


In these times of financial hardship- the temptation to some could arguably be greater to cut corners and use suspect or counterfeit parts in their business aircraft. The message from the FAA to the repair stations at the sharp end of the issue of Bogus Parts is- “Don’t Do It!”

Not only is it a criminal offence to knowingly supply and use suspect parts in an aircraft- but it can immediately jeopardize the aircraft’s airworthiness. Perpetrators can face huge fines and long jail terms. Given the sensitivity of the subject- not surprisingly some business aviation-related companies didn’t want to put a spokesperson forward for comment- but some are thankfully willing to lift their heads above the parapet for the sake of greater safety and awareness within the industry.

Some even suggest that the airline industry is more susceptible to the problem - and this is backed up by some high profile airline cases under FAA investigation as this magazine goes to press.

Suspected Unapproved Parts (SUPs)- as the FAA defines them- can range from anything - from a correctly made and tested part that is lacking the correct documentation- to deliberately counterfeited parts which might look genuine but don’t have a satisfactory provenance- and are often made from inferior materials with potentially dire results. The parts may be stolen- they might come from illegal manufacturing over-runs- they could be time-exceeded- or they could be improperly returned to service.

As the FAA sees things- all parts manufactured without FAA approval are ‘Unapproved Parts’. Other than legitimate parts manufactured by the OEMs (and their licensed contractors/ partners) or companies holding FAA Parts Manufacturer Approvals (PMAs)- or recycled and re-certificated parts there are no other approved aircraft parts in the eyes of FAA inspectors.

FIGHTING THE GOOD FIGHT
A company very much involved in fighting to keep business aviation clean is Fort Lauderdale based CRS Jet Spares (www.crsjetspares.com) which has offices worldwide. It supports Learjets- Hawkers- Gulfstreams- Challengers- Falcons and Beechjets through its comprehensive parts inventory- and it also has a wholly owned subsidiary- Thrust-Tech Aviation- which is a FAA and EASA Certified Aircraft Component Overhaul and Repair Station.

CRS Jet Spares’ CEO Armando Leighton Jr. says- “With today’s technology in manufacturing- it can be difficult at times to spot an SUP. Stampings and markings if compared side by side could be the first line of defense- however- there is no substitute for tracking and requesting proper documentation.”

Leighton adds that in some cases the fabrication of these SUPs is now so superior that at times- only a trained eye can spot the differences. If your source is unable to produce the paperwork- then you leave yourself exposed to something that potentially could be wrong with the integrity of the part. The FAA and all governing agencies send out the message of ‘buyer beware’- if you don’t have the correct documentation- then don’t use the part.

“Especially now- with operators trying to reduce their operating costs- lower priced spares can be attractive- but it is well worth remembering that if you don’t have the documentation then the part could be an issue somewhere down the line during a major inspection-” said Leighton.

So are there real counterfeiters infiltrating the industry? “In the old days there was a lot of that-” Leighton told World Aircraft Sales Magazine- “especially with reciprocating powered aircraft. Parts could be made in a small machine shop and substitute bolts could be obtained at the local hardware store. They looked the same- they had the same threading- but they didn’t have the right metallurgical properties required to handle the vibration- stress and heat.

“We’re in the PMA business which makes us much more aware of bogus or suspect unapproved parts. Additionally- we own a Part 145 repair station. This keeps us in the loop daily on what is out there and we can take necessary precautions.”

He added that PMA status gives a company the right to manufacture a part under FAA guidelines that is equal to- or better than the part supplied by the OEM. “Parts have to go through a rigorous testing regime – metallurgical analysis has to be identical and approved through the ACO and DERs (Designated Engineering Representatives) for the FAA.”

NEW LINES OF DEFENSE?
In recent years- new technologies- like the addition of holograms for tracking genuine approved parts- has developed. “That’s great new technology- and there is obviously a cost associated with it- but this technology will go places-” Leighton observes. “In the end though it is probably no different to someone counterfeiting Dollar bills; there’s always going to be somebody able to find better printing methods- better ink and paper. It’s unfortunate that with the value of parts spawns the wrong people to get involved.

“It’s hard to say just how widespread the problem of bogus parts is- but I would say it’s not too bad in the business aviation sector. I think there may be more cases in the airline industry- where sheer volume can be the driver. No one is going to make counterfeit items if they can’t sell them. Just compare the number of Boeings and Airbus’ in the world to- say- Falcon or Gulfstream types - only a few hundred of each have been produced against upwards of over a thousand for each of the popular airliner types.

“I’m not saying that we’re all safe- or that we can afford to let our guard down- but there may be less opportunity for someone to introduce a bogus or suspect part into the business aviation market- because it would be more profitable for them in larger markets. I feel the FAA has made great strides with awareness programs to the Aviation Community at large which has made it more difficult to introduce bogus parts. But who really knows what’s going on? It’s very hard to pinpoint.”

On the dangers of using bogus parts he emphasized that the use of a bogus part can result in nothing good. “The OEM sets the standards and quality and PMAs have to meet or exceed them. If a machined part is fabricated without proper engineering and metallurgical process- there is a possibility it could be made using inferior metal or alloy which could fatigue and cause a catastrophic situation. FAA standards for PMAs have become more stringent and so protect everyone by certifying every part.”

He explained that the process of getting a part approved can take between six to twelve months before gaining a PMA approval for it. The FAA website gives details of all companies issued with PMAs and approved parts. It’s important to be clear that an SUP can actually refer to any part of the airframe- engine- or avionics. “It can be all across the board-” Leighton added. “You could even make a plastic part for a passenger seat but the danger here concerns whether it would be fire retardant. Another example could be a seal: was it manufactured with the precise rubber compound that can withstand stresses of heat and cold in an aircraft environment.

Everything needs to be stringently tested and certificated.”

BOGUS PARTS AND THE CREDIT CRUNCH
Leighton observed that he didn’t think the problem had got any worse during the credit crunch. “We buy thousands of parts a year and I can honestly say that in our experience we haven’t seen any ramping up of bogus parts at all- but it doesn’t mean that it hasn’t happened in other areas beyond our sector.”

Elli Cotti- NBAA’s Director- Technical Operations- adds he hasn’t heard about any major recent business aviation related bogus parts problems.

“I’ve talked to individuals on our maintenance committee to check with them- and the conclusion is that these are old stories-” said Cotti. “The FAA has done a great job putting in a robust program on unapproved and bogus parts and it’s a program that has brought awareness and education to the forefront.

“People that I deal with in business aviation follow the protocols of insisting on pedigrees to every component- and work with authorized vendors. I think the big difference in business aviation is that the individuals doing the work are so close to the principle riding on the airplane that they won’t compromise on the maintenance of the aircraft. Theirs is a personal stake here.”

Asked if he thought the credit crunch could tempt some to cut corners- he added- “The only thing I would say on this- which evolves from the current market- is that older aircraft that don’t have a good resale value will be parted out and so there will be components taken off an airworthy airplane for resale.

“These parts will have to go through a pedigree process by being sent back to a shop for re-certification or validation and there is a formal process for getting this done. I guess what could be a potential [problem] is people selling- ‘as it came off my airplane’ without going through the validation process- or maybe bogus parts coming on to the market in the same way.”

Brian Clark- the Parts Manager at Banyan Air Services (www.banyanair.com)- whose parts division is a factory authorized parts distributor for Beechcraft and Twin Commander and also based at Fort Lauderdale- says from his personal perspective the credit crunch hasn’t worsened the unapproved parts situation.

“We’ve always had tight quality control over everything that comes in. Our business ethic would never allow us to use suspect or bogus parts just to make an extra dollar. You might make an extra $100 on that part- but it might cost you millions in fines.”

When asked if bogus parts for business aircraft are a major concern- he added- “Because some people are being sued over [unapproved] parts everyone is being more careful.

“We’ve come across parts that are sold as new surplus- and been told that documentation is on its way- but when it doesn’t come- we don’t use the part. It’s based on our incoming inspection and we have to make sure that documentation is there- marked properly- and that serial numbers match- etc.”

Clark added that unapproved parts can happen on anything from a Cessna 152 to a Boeing 747. “If people don’t document their parts then they are immediately suspect. It may not be that they are bogus parts but they are suspect until the documentation has been done. In my experience I haven’t seen anyone deliberately trying to sell something that they know is not good.”

His advice to customers is- “Know your vendors - we’ve been in business for 30 years and have developed good business relationships with companies that we know are in the business for the long-term. If you’re buying something from someone you don’t know- then obviously you’ve got to be a lot more careful than if it is someone you deal with every day.

“We have a very close relationship with our local FAA Inspector who would determine the correct course of action if we had a suspect part-” said Clark.

CRS Jet Spares’ Leighton summarizes that if you find a SUP- quarantine the suspected bogus part and contact your local FAA/JAA or governing office. If you are a Part 145 Repair station- you can fill out an 8120-11 form and submit it to the Aviation Safety Hotline or your local FAA representative.

“The best defense to protect the integrity of a component or an aircraft would be to take an offensive approach within your system that requires genuine traceablity from the source. Although bogus/SUP parts can surface anywhere- it is also good practice to purchase from reliable vendors and sources that have incorporated Quality Systems such as ISO9001 and/or AS9120 that internally forces the participating company to comply with the standards.”

Concerned personnel can submit a SUP report to the FAA’s 24-hour Aviation Safety Hotline at 1-800-255-1111- or email a report to the hotline on 9-awa-avs-aai-safetyhotline@faa.gov- or mail a copy to the Federal Aviation Administration- Aviation Safety Hotline Office- AAI-3- Room 840- 800 Independence Avenue- SW Washington- DC 20591.


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