Aftermarket: What’s SUP with Parts?

How can you ensure that your shop is not accidently using bogus parts? Always use a supply chain that is reputable, be certain that all parts have the appropriate documentation and that the parts remain traceable throughout their existence. Even then, you may encounter a bogus part.

I was probably 18 or 19 years old the first time someone approached me on the street and tried to sell me a "genuine Rollex watch" for the attractive price of $100 (cash, of course). It’s a good thing I had neither the money nor the interest, because even though I knew a Rolex watch sold for a lot more than that, I didn’t notice that the one this street corner entrepreneur was trying to sell me had one "L" too many in its name. Had I bought that cheap wristwatch, I would have spent $100 for a $10 piece of costume jewelry that wouldn’t have had the time of day right more than twice in a 24-hour period, but I’m sure the fly-by-night merchant was hoping I didn’t know that.

And so goes the problem of customers who unwittingly run the risk of purchasing something that is a lot less than what it seems. In my case, the watch would have been called a "knock-off." Had he been trying to sell me a "Hunnywell" fuel control unit for a Rolls-Royce turbine engine, it would have officially been called a suspected unapproved part or "bogus" part.

What is a SUP?

In the interest of time (and the preservation of everyone’s sanity) I’ll skip the book definition provided by the Federal Aviation Administration (FAA), and hit the highlights of what a Suspected Unapproved Part or "SUP" is. Generally speaking, a SUP comes in one of three different flavors:

1. A part that was once officially ap-proved (i.e., blessed by the manufacturer and the FAA) to be installed on one of the manufacturer’s products, but is no longer approved for reasons including, but not limited to age, damage or design changes.

2. A part that was once officially ap-proved, but its traceability since manufacture, regardless of time span, cannot be thoroughly accounted for.

3. A part that was never officially ap-proved for installation on one of the manufacturer’s products, usually because it either failed to pass a rigorous aviation-specific functionality or reliability test or it was never subjected to one in the first place.

Where Do SUPs Come From?

To get a better handle on where SUPs come from and how they sometimes find their way aboard aircraft, I visited the department of aviation maintenance science on the Daytona Beach campus of Embry-Riddle Aeronautical University (ERAU). There, I met Roger Sonnenfeld, ERAU’s repair station manager, who overseas the health and well-being of the university’s 50-plus training aircraft.

When asked how a part that is not approved can find its way aboard an aircraft, Sonnenfeld readily admitted that it wasn’t easy, at least not through the majority of repair stations operating in the United States. "A lot of the time it’s because someone accidentally shipped the wrong part from the supplier and the customer doesn’t realize it," he said. He then reached for a plastic bag containing brushes for a motor.

"See this?" he said holding the bag in the palm of his hand. "These come in two different kinds, so we teach the students to make sure the item is what’s written on the bag, and that both match what is supposed to be going on the aircraft. If something doesn’t match, we go back and find out why."

In the case of those motor brushes, ERAU received the correct ones, but had they been made of copper, they may have been approved for some other model, but not any of their aircraft. Therefore, had the supplier tried to sell ERAU copper brushes by telling them they were made of a different material, an otherwise approved copper brush would have been a SUP, as far as ERAU was concerned.

On the other end of the spectrum are members of the criminal community trying to make a buck. They are the people who pull junk parts off of old airplanes, clean them up and draw-up phony documentation with the intent to sell bogus or even counterfeit parts as approved parts to unscrupulous A&Ps or private owners trying to save a few thousand dollars.

According to the FAA, there is a thriving black market for parts that are anywhere from good, yet undocumented, to just plain dangerous. The FAA has an on-going partnership with a variety of federal law enforcement agencies to identify and arrest those who intentionally produce, obtain, distribute and use bogus aviation parts. As a regulatory agency, the FAA also monitors the practices of legitimate suppliers and end-users to ensure they minimize their exposure to the danger of bogus parts by way of carelessness or poor management; issuing fines and other sanctions to those found in violation of basic regulations.

Who’s Putting SUPs on Airplanes?

Most repair facilities are reputable, especially the ones operated by the major airlines because they know that if an improper part is found on one of their aircraft during an accident investigation, their liability will be immense, not to mention the damage to their reputation. Chuck Horning, ERAU’s associate chair for the aviation maintenance science department, confirmed the airlines industry’s lead in keeping bad parts out of the air.

"I was far removed from the level that handled ordering parts," said Horning, who once served as a line mechanic for Delta Airlines. "But I know the screening procedure was very strict." (And let’s face it; the line mechanic’s level is the main place a SUP shouldn’t be!)

Unfortunately, bogus aircraft parts are more likely to find their way aboard an aircraft at the hands of a seemingly unlikely suspect: the aircraft’s owner!

"I can show you an example of how someone might put an unapproved part on an airplane," said Sonnenfeld. He then led me from his office into the classroom area where he placed three seemingly similar alternators on the table.

"This old dirty one was made by Ford," explained Sonnenfeld as he pointed to the company’s name on the data plate. "Cessna used them for many years before going to this one." He then pushed the second alternator across the table for my inspection. They looked virtually the same to me, but he said there were subtle internal changes that made it more airworthy, thus replacing the old ones that were built with cars in mind.

"Here’s the problem," said Sonnenfeld, as he slid a third alternator toward me. "This one looks pretty much the same, right?" It did to me, except it looked brand new and the fan blades on the flywheel weren’t shrouded.

"Well, that third one is not an approved part," Sonnenfeld announced. "When people saw that Cessna was using a 15-ampere Ford alternator, they assumed they could use one from the neighborhood [auto parts] store, so people put those on their own planes to save money."

Sonnenfeld went on to explain that Cessna probably moved away from the car alternator originally supplied by Ford, because it wasn’t quite as flight-worthy as a newer design. Ford more than likely built the new version, and then got it approved with very few outwardly noticeable changes, leaving the ones sold in car parts stores for use only on cars.

"I don’t think a reputable repair station would buy a part from [an auto supply store], but a private owner might to save money."

Sonnenfeld also mentioned aircraft "bone yards" as another way SUPs find their way aboard aircraft. "I know of a guy who went to a bone yard looking for a part for his plane," he began. "He just pulled the strut out of a pile and probably put it on his plane without knowing what he was getting." In fact, the parts disappear from all kinds of aircraft hulks, presumably to show up on national or overseas black markets.

In both the case of the alternator purchased from an auto store and a strut resurrected from a junk heap, the parts are outside the scope of being approved because they weren’t specifically certified for the aircraft or properly documented on a Form 8130-3, respectively. In essence, they became SUPs by virtue of the owner’s actions.

During our conversation, Marshall Tetterton, a test pilot and ERAU instructor, joined us. Tetterton knows a lot about the problems with parts because when ERAU began servicing their own fleet or aircraft, Tetterton was in charge of setting up and managing the parts department.

Tetterton tells his students that to have a good maintenance facility they should have a good parts department. He instills that belief in them by giving blocks of instruction on how to manage parts from time of order to time of installation.

ERAU ensures the quality and authenticity of its parts by sending Tetterton to conduct on-site inspections of the university’s various parts manufacturers.

"Embry-Riddle is considered a fleet operator, so I can deal directly with many of the manufacturers," said Tetterton. "I want to make sure they manufacture and stock things properly." He said it makes him more confident that the parts he gets for the school meet the university’s high standards and are all approved.

One area where Tetterton said bogus parts — in this case, parts that have lost their approval for one reason or another — can be a big problem is with small, unserialized parts, such as fasteners.

"Let’s say you had a bin full of bolts," began Tetterton. "And as new bolts came in, you dumped them in with the ones you already had. Now, lets say an AD comes out on that new batch of bolts because they were made using inferior materials and were no longer authorized for use. How would you know which ones were the good ones and which ones weren’t?" If that happened at the supplier’s warehouse, they could inadvertently send a bogus part out to an equally unwitting customer, especially since a Form 8130-3 usually does not accompany each individual nut and bolt.

ERAU teaches its students (and practices) a policy of segregating all incoming parts and their accompanying Form 8130-3 from in-stock parts and forms, so that they can easily identify recalled, counterfeit or otherwise bad items from their huge inventory. In fact, the school has a printed procedures list and flow chart describing how parts are to be received, inspected and stored.

The Paper Trail

Most people don’t want any paperwork on their jobs, with the exception of their paychecks. Those in the aviation community are no exception. But many maintenance technicians, pilots and aircraft operators agree that the paper trail associated with aviation parts plays an important role in the safety of the traveling public.

FAA Form 8130-3 — probably the first form number an A&P student can recite in his or her sleep — is the paper watchdog that sits in the corner and keeps an eye on nearly everything that’s bolted, welded, screwed, glued, strapped, soldered, riveted or kicked onto an aircraft. One look at that sheet and someone can trace the life of the listed part. And, according to Tetterton, while there is no technical requirement to use an 8130-3, a manufacturer is obligated to document at least the same information required by the 8130-3 on its own company’s form and marry that form to the part in at least the same manner prescribed for an 8130-3. Oddly enough, this too can be problematic.

"I find there’s no standard across the board," lamented Tetterton. "Some companies send photocopies of all the forms to the customer, like who they got their raw materials from." Tetterton said he personally didn’t need that much information, but believes it is the result of inferior metals being used by certain foreign countries to produce components, then becoming the subject of an AD to get them out of the sky.

Playing Keep-Away with SUPs

The FAA and the excellent instructors at Embry-Riddle all agree that the best way to avoid bogus parts is to ensure that the supply chain is reputable, that all parts have the appropriate documentation, and that all parts remain traceable throughout their existence. Of course, human error can create gaps in the process. In those cases, the part in question should be removed from the supply chain until a thorough examination into the history and health of that part has been conducted and an FAA Form 8120-11 "Suspected Unapproved Parts Report" completed immediately if something doesn’t seem legitimate.

For more information on how to guard against SUPs or to report an incident involving them, visit www.faa.gov/aircraft/safety/programs/sups/ or contact the nearest Flight Standards District Office.