SUSPECTED UNAPPROVED PARTS IN AVIATION AND DEFENCE

Safety Information Bulletin Airworthiness
SIB No.: 2017-13
Issued: 24 August 2017
Subject: Suspected Unapproved Parts
Applicability:
Product(s), part(s) or appliance(s), and components thereof, which are considered Suspected Unapproved Parts (SUP) cases, as published on the EASA website (link provided below).
Note: For simplification of the text of this SIB and for consistency with the term SUP, this SIB refers to product(s), part(s) or appliance(s), and components thereof as ‘parts’.

Recommendation(s):
When in doubt about the origin of a part, maintenance organisations, aircraft owners, operators, independent certifying staff, manufacturers, and parts suppliers are invited to consult, in addition to the content of the Safety Publications Tool, the information reflected in this SIB and in the SUP list (see link below) before accepting such a part into their organisations or before fitting it to an aircraft.

Link to the list of SUP cases on the EASA website:
Refer to the webpage below for information on confirmed unapproved parts, SUP under investigation, and stolen parts (from 24 August 2017).
https://www.easa.europa.eu/easa-and-you/aircraft-products/suspected-unapproved-parts
Contact(s):
For further information on the technical content of this SIB and the SUP list, contact the EASA Safety Investigation and Reporting Section, Safety Management Directorate:
E-mail: IORS@easa.europa.eu

Companey supplier shall plan, implement, and control processes, appropriate to the organization and the product, for the prevention of counterfeit or suspect counterfeit part use and their inclusion in product(s) delivered to the Companey.

“Counterfeit Parts Prevention Program Requirements” apply to the procurement of electrical, electronics and electro-mechanical parts as well as standard parts (fasteners, nuts, washers, springs, o-rings, inserts, pins, etc.). “AS6174 Counterfeit Materiel; Assuring Acquisition of Authentic and Conforming Materiel” should be used as a general guideline in establishing a counterfeit parts prevention program in order to mitigate risks of receiving and installing counterfeit parts.

The following additional requirements apply to the procurement process of supplier that are autorized by Companey for procuring standard parts its products.

 Parts sold or installed in any work delivered to Companey under PO shall not be in a used / altered / reclaimed condition and misrepresented as new.

Certificate of conformance from OEM (Original Euipment Manufacturer) must be delivered with each lot/shipment of electric, electronics, electro-mechanical and standard part.

Suppliers that deliver next-higher assembly shall flow down this requirement to sub-tier Suppliers and ensure their compliance

Supplier receiving process must assure the detection of counterfeit parts (review of certificates of conformity to ensure an unbroken chain of documentation tracing back to OEM, visual inspection, etc.) prior to formal acceptance of the product in order to alleviate their introduction into inventory, use in manufacturing or distribution to other parties.

Non-conforming parts or those unsuitable for use require physical destruction prior to disposal

Surplus product should only be re-sold or dispositioned to external organizations with demonstrated adherence to these requirements.

Return product should only be accepted on a proper return material authorization and require the original paperwork.

Suspect or confirmed counterfeit parts must be controlled (identify the parts, segregate in quarantine, investigate to confirm authenticity, obtain engineering disposition, report counterfeit parts to the customer).

KH Suppliers shall immediately notify KH of any pertinent facts concerning a suspect part already delivered under a purchase order

Supplier may be liable for remedial costs associated with provision of counterfeit product and/or penalties associated with fraud as detailed in applicable law(s).

Procurement Engineer is not under obligation to return suspect or confirmed counterfeit product to the Supplier except under controlled condition which would preclude re-introduction of the product into the supply chain.

According to AS9100 Rev d, counterfeit parts prevention processes should take into account::
* Training of appropriate persons in the awareness and Prevention of counterfeit parts
• Implementing a part of the aging monitoring program
• Controls for obtaining products that are externally supplied from original or authorized manufacturers, authorized distributors or other approved sources.
• Requirements to ensure the traceability of parts and components to original or authorized manufacturers
• Verification and testing methodologies for detecting fake parts
Monitoring of counterfeit tracks reported from external sources;
Quarantine and reporting of suspicious or detected fake parts.