Suspected Unapproved Parts (SUP)

There are four types of aircraft parts:

Good parts with good paperwork
Good parts with bad paperwork
Bad parts with “good” (bogus) paperwork
Bad parts with bad paperwork

The first of those listed represents properly authorized parts that, when properly installed, are approved parts, and the aircraft can be returned to service. The last of those listed represent unauthorized and unapproved parts. The technician should be alert for these and must never install them on an aircraft.

The center two categories of parts represent suspected unapproved parts. If either the physical part or the paperwork associated with the part is questionable, it is best to contact the shop foreman, shift supervisor, or the assigned quality individual to discuss your concerns. Suspected unapproved parts (SUPs) should be segregated and quarantined until proper disposition can be determined. Contacting the manufacturer of the product is a good way to start gathering the facts concerning the product in question.

Detection of Suspected Unapproved Parts

The airworthiness of aeronautical products may be compromised if a part’s approval status is suspect or unknown. Positive identification of unapproved parts has proven to be difficult because they can closely resemble approved parts. The following guidelines offer a means to use in your facility’s receiving section to evaluate received parts (and their sources). These steps will help prevent the procurement, acceptance, and installation of unapproved parts into aircraft and aviation components.

Supplier Evaluations

The process should include criteria for the initial evaluation, selection, periodic or ongoing evaluations, and disapproval of suppliers. The FAA strongly encourages production approval holder’s (PAH) to conduct initial onsite evaluations based on multiple risk factors.

Although the supplier evaluation function is not required for repair stations and non-PAH holder facilities, repair stations are required to ensure each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition.

Procurement Process

Establish a procedure to ensure the procurement of approved parts prior to purchasing parts and material for installation in type certificated (TC) products. This procedure should include the following at a minimum:

1. Methods of identifying distributors and/or suppliers who have a documentation system and receiving inspection system that ensures the traceability of their parts to an FAA-approved source.

2. Methods of screening unfamiliar distributors and/or suppliers to determine if the parts present a potential risk of being unapproved. The following situations may raise questions:

A quoted or advertised price that is significantly lower than the price quoted by other distributors and/or suppliers of the same part.
A delivery schedule that is significantly shorter than that of other distributors and/or suppliers (when the stock of a like item is exhausted).
Sales quotes or discussions from unidentified distributors that imply an unlimited supply of parts, components, or material are available to the end user.
A distributor or supplier’s inability to provide substantiating documentation that the part was produced in accordance with an FAA approval or inspected, repaired, overhauled, rebuild preserved, or altered.

Receiving Inspection

Your internal procedures should include a means of identifying unapproved parts and preventing their acceptance. An effective receiving inspection should address the following suggested areas:

Confirm that the packaging of the part identifies the supplier or distributor and is free from alteration or damage.
Verify that the actual part and delivery receipt reflect the same information as the purchase order regarding part and serial number.
Verify that the identification on the part has not been tampered with (e.g., serial number stamped over, label or part/serial numbers improper or missing, vibro-etch or serial numbers located at other than the normal location).
Ensure that the parts’ shelf life and/or life limit has not expired, if applicable.
Conduct a visual inspection of the part and supporting documents to the extent necessary to determine if the part is traceable to an FAA-approved source.
Evaluate any visible irregularities (e.g., altered or unusual surface, absence of required plating, evidence of prior usage, scratches, new paint over old, attempted exterior repair, pitting, or corrosion).
Conduct random sampling of standard hardware packaged in large quantities in a manner that corresponds to the type and quantity of the parts.
Segregate suspect parts and attempt to resolve any issues regarding the part’s questionable status through your supplier prior to initiating a SUP report (i.e., obtain necessary documentation if not provided or determine if irregularities resulted from shipping damage and handle accordingly).

Eligibility, Quality, and Identification of Aeronautical Replacement Parts

AC 20-62 was published to promote compliance with FAA regulations and to offer further guidance and clarification relevant to the eligibility of aeronautical replace-ment parts. This AC includes definitions of various terms (e.g., “surplus” and “as is”) and outlines a means by which the installer can make the required determinations.

Note: Aircraft parts that are for sale but are not represented as being airworthy or eligible for installation on a TC product are not considered a SUP. It is not contrary to the CFR as such, to sell aircraft parts as is or for decorative purposes. It is essential that the buyer request and receive the necessary documentation to substantiate the status of the part if it is intended to be installed in a TC product.

SUP Reporting Procedures

SUP reports may originate from numerous sources such as incoming/receiving inspections, audits, facility surveillance, complaints, congressional inquiries, accident or incident investigations, or various service difficulty reports.

Disclosure of Information

It is the FAA’s policy to encourage the disclosure of information regarding aviation safety. Reporters may be concerned with the potential repercussions of reporting the discovery of parts that are alleged to be unapproved. Although reports may be submitted anonymously, requesting the reporter’s name enables the FAA to verify information and provide confirmation and/or follow up to the reporter.

Suspected Unapproved Parts Report

FAA Form 8120-11 includes instructions to complete the form, and provides the information needed to initiate a SUP investigation. [Figure 1-3]

Figure 1. Instructions for Completing FAA Form 8120-11, Suspected Unapproved Parts Report

Figure 2. Suspected Unapproved Parts Report (continued)

Figure 3. Suspected Unapproved Parts Report (continued)

Refer to the current version of AC 21-29, Detecting and Reporting Suspected Unapproved Parts, for additional information. Current contact information for submitting a SUP Notification can be found at www.faa.gov.

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