COVID-19 exposes fragile Aviation Supply Chain
Congress asks OIG to assess its Vulnerability
A robust Supply Chain ‹ Aviation Safety
The Republicans on the T&I Aviation subcommittee asked for “an audit to (1) determine how DOT is tracking imported aviation products and (2) identify potential impact on the U.S. aerospace industry if imported aviation products are unavailable in the future.
The minority Members asked for the study because they are conscious of the need to protect supply chains for critical aviation parts in the United States. (see Executive Order 14017 on America’s Supply Chains). As the initial graphic amply demonstrates, the flow of parts around the globe involves multiple segments, a variety of participants – OEMs, domestic and foreign repair stations, parts dealers and airline inventories (central and field)and repaired parts based on their internal processes. The airworthiness issues mark these parts as they flow from one CAA to another and possibly more. Both criteria and varying degrees of government strictness of interpretation may inhibit the free flow of these products due to regulatory/safety criteria .
The DOT Office of Inspector General OIG) is well acquainted with the precise requirements of airworthiness proof (documentation and/or proof) for spare parts. The staff has issued many, many reports on the standards, the FAA’s management of the issue and federal prosecution of violations. Typically, these auditors have gravitated to stricter standards.
Similarly, the OIG has been asked by Democratic leaders to assess the work of foreign repair stations. Repeatedly, their findings have questioned these overseas facilities.
Based on these experiences, the OIG auditors need to balance the need to support the supply chain bridge while maintaining the integrity of the SUP protections.
CAVEAT: while examining your books for this report, the OIG may use the opportunity to assess your documentation of all inventory purchases and sales.
April 29, 2021
Requested by the Ranking Members of the House Committee on Transportation and Infrastructure and its Subcommittee on Aviation.
The coronavirus pandemic has highlighted the importance of developing and maintaining resilient supply chains in industries that are essential to the Nation’s economic vitality, national security, and public health. Citing the significance of the aviation industry to the Nation’s economy, the Ranking Members of the House Committee on Transportation and Infrastructure and its Subcommittee on Aviation asked us to assess how the Department of Transportation (DOT), working with other Federal agencies, tracks the amount of imported critical aircraft, aircraft engines, and other aviation parts and components.
In addition, the recently issued Executive Order 14017 on America’s Supply Chains reflects the Administration’s increased interest in understanding and protecting supply chains for critical aviation parts in the United States. Accordingly, DOT-OIG is initiating an audit to (1) determine how DOT is tracking imported aviation products and (2) identify potential impact on the U.S. aerospace industry if imported aviation products are unavailable in the future.
 The White House, Executive Order on America’s Supply Chains, February 24, 2021. This executive order, in part, directs the U.S. Department of Transportation to prepare a report within a year on the supply chains supporting the Nation’s transportation industrial baseShare this article: