Component Confuse-Un

Geoffrey Holder, an actor from Trinidad, is best remembered for the mid-1970s comparison of the cola nut and the un-cola nut. The commercial’s intent: distinguish between a Kola nut, used for making cola soft drinks; and Un-cola nuts, a lemon and a lime. The joke: the lemon and lime aren’t nuts of any kind, therefore this un-cola is the anti-cola; the direct opposite of a cola. How’s that for totally useless information?

The letters u-n together either form a pronoun, initials, abbreviation, or a prefix. As a prefix it should make a word’s meaning opposite to itself; the dispute comes when a reader’s interpretation takes the word’s meaning out of context.

When talking about suspected unapproved parts (SUP) and that term ‘unapproved’ is applied incorrectly, its meaning becomes ambiguous when coupled with its cousin, "unairworthy." Those who think that unairworthy and unapproved are synonymous should know that these two words describe two different conditions. When interpreting regulatory verbiage one must be careful not to confuse similarity with interchangeability. There are those who feel that the two are equivalent in definition. I submit: a SUP isn’t always unairworthy and an unairworthy part, well... is not always a SUP.

Can an unapproved part be airworthy? Absolutely, by meeting the manufacturer’s type design and being in a condition for safe operation, the part in question can be considered airworthy even though it is not approved. Deeming a part airworthy does not automatically translate into one being able to use an unapproved part on an aircraft. It would be like making tofu-shaped Buffalo wings; you can make it look like real wings, but I wouldn’t serve it to the guys at a Super Bowl party. One can cast the material, drill it, build it, and test it to an airworthy standard, but all they end up with is an expensive component-shaped paper weight that meets the type design, but isn’t approved for installation. If one uses the exact materials, dimensions, and sub-components as the manufacturer dictates, but without proper authority to produce, e.g. PMA per 14 CFR Part 21, one would own an airworthy piece of scrap metal.

Now let’s move the ‘u-n’ around: can one have an approved part that is unairworthy? Without a doubt — yes! The reason is simple: you may have an approved part that was incorrectly maintained using the wrong torque limits, incorrect o-rings, or fittings that are the wrong part number. Let’s say a repair station employee puts an approved part in an incorrect application and it makes it to the parts shelf. Holy bad-from-stock, Batman, doesn’t that make it an unapproved part? One doesn’t need a Bat-computer to know that the part off the shelf, which is now leaking when pressurized, is still approved; it’s just not airworthy. The reality is that quality assurance doesn’t always catch the problem on the acceptance inspection; parts do get through to the parts room. That’s why technicians perform operational checks on installations before returning to service.

Can someone who provided an approved part in an unairworthy condition be accused of providing a SUP or a violation of 43.13? I’m not discouraging anyone from pursuing a SUP, especially where faulty manufacturing may be the result. However, the one overhauling a part with, for example, the wrong torque value, is in violation of 14 CFR Part 43. The SUP investigator would have to determine intent, the burden of proof being upon the investigator. Some believe that making an approved part unairworthy makes said part a suspected unapproved part. That may be true in some cases, but not all; it would be irresponsible to clump all unairworthy parts together.

There is a problem with making blanket judgments on the incorrect maintaining of airworthy parts in that one throws un-SUP-able repaired parts in with those that are a legitimate SUP. This subject has become a matter of contention for those who feel that parts not maintained to the manufactured or engineering standards should be considered unapproved. The point to remember is that when speaking of approved parts one refers to the nine requirements spelled out in 14 CFR Part 21, that parts are either approved, fabricated, and/or produced to the applicable standards. Part 21 says nothing about being maintained to a standard. When one begins speaking to maintenance and to whether a part is airworthy or unairworthy, we have to go a few regulations ahead, to 14 CFR Part 43, to determine if a violation has occurred.

To clarify, let’s look to AC 21-29, for a direct quote for the definition of a SUP:

"A part, component, or material that is suspected of not meeting the requirements of an ‘approved part.’ A part that, for any reason, a person believes is not approved. Reasons may include findings such as different finish, size, color, improper (or lack of) identification, incomplete or altered paperwork, or any other questionable indication."

Consistency dictates that preserving the intent of a policy prevents one’s personal interpretation from clouding everyone else’s understanding; maintaining the policy’s correct intent is the ideal goal. Or, as Geoffrey Holder would say, "Mah-velous! Ab-solutely mah-velous!"