Suspected Unapproved Parts (SUPs)
Enhancements Are Needed to FAA’s Oversight of the SUPs Program
Suspected Unapproved Parts (SUPs) are among the most insidious threats to aviation safety. They are introduced into the system by entities with the intent to beat the system. While some SUPs may only be lacking the regulatory paperwork, many of them are counterfeit parts or improperly repaired parts likely to fail with disastrous consequences.
These circumstances compel vigilance in the effort to keep SUPs out of airline inventories. The FAA responded to this threat with a level of energy and focus needed to intercept these parts. The Office of Inspector General has issued a report suggesting that the FAA may have diminished its attention as to SUPs. Here are the findings:
- Develop guidance and provide training to Hotline employees on how to accurately record specific data about Suspected Unapproved Parts (SUPs) in FAA’s databases.
- Develop a management control to ensure that all SUPs reports received by local inspection offices are submitted to the Hotline for processing.
- Develop a management control to ensure FAA Hotline employees conduct trend analyses in accordance with the Hotline’s guidance.
- Develop a management control to ensure inspectors adhere to guidance when conducting SUPs investigations.
- Revise FAA’s risk-based oversight system to incorporate a risk indicator for manufacturers where unapproved parts have been found.
- Require FAA Headquarters officials to forward all confirmed SUPs cases to Federal law enforcement agencies, whether or not criminal activity is suspected, in accordance with the letter of agreement.
- Coordinate with DOT’s Office of Inspector General to determine the need for its investigators to receive all improper maintenance cases, including those initially reported as SUPs as well as those reported directly to FAA.
- Require FAA Headquarters officials to provide quarterly SUPs investigation reports to Federal law enforcement agencies, in accordance with the letter of agreement.
- Develop a management control to ensure inspectors issue UPNs consistently when notifying the aviation industry about unapproved parts.
- Develop a management control to ensure inspectors follow existing guidance requiring operators to remove unapproved parts from use and their inventories.
- Include a “best practice” in the SUPs Advisory Circular to encourage industry to register to receive automated notifications about unapproved parts.
The FAA essentially agreed with the OIG’s recommendations. It appears that the SUPs issue did not continue to be prioritized by senior management. Moving SUPs from a focused program office to the Aviation Safety Hotline is some measure of relaxation of the aggressive attention to these insidious parts. Failing to train the Hotline staff, to assure the field follow up, and to coordinate with OIG, law enforcement and industry all reflect a lack of high diligence.
Headquarters staff responsible for managing the national SUPs program should have recognized that most of the Regional ASIs did not like SUPs investigations because the investigations take time away from scheduled activities and can be very complex and require a lot of careful review.
Another consideration that by FAA reclassifying improper maintenance as non-SUPs, it ignored a major safety issue. When the improper maintenance is intentional, it is a SUPs. The ISO audit process was going to be a double check on the current process and of course, it appears that never happened either.
Findings 3 and 5 involve the incomplete implementation of SMS by all of the FAA Headquarters organizations. Trend analyses and risk indicators are central to successful SMS discipline. Whoever was responsible for designing a national program, if (s)he had fully adopted the gospel of SMS, would have built the SUPs regimen to include these two and other statistical measures.
A reoccurring FAA problem has been a failure to adequately follow up. It may be due to the change in staff or the imposition of other priorities, but many things simply “fall through the cracks.” The OIG analysis of the SUPs program’s short-comings should act as a wake-up call. Hopefully the OIG will do, as its report indicates, a follow up audit to see if the FAA actually does what they said they will do.
Private industry should take a hard look at the report and not rely on the FAA to find SUPs. Industry needs to implement their own SUPs program to insure unapproved parts do not get into their stock or supply chain and require those that are involved with parts receiving and distribution receive SUPs training.
Just a few thoughts on the status of the FAA SUPs program.
For those of us, who were involved in the SUPs program, we were certain that the program would deteriorate once the oversight was taken away. When the program was shifted to the Aviation Safety Hotline Center, the only role it played was to log and pass SUPs to the Regions for “investigation.” The Center did play an oversight role. Most of the Regional ASIs did not like SUPs investigations because the investigations take time away from scheduled activities and can be very complex and long term. One of the other factors that struck at the heart of the program was the FAA reclassifying improper maintenance as non-SUPs. When the improper maintenance is intentional, it is a SUPs. The Regions used that as an opportunity to close out many SUPs cases to “clear the books.” The ISO audit process was going to be a double check on the current process and of course it appears that never happened either.
One of the major problems the FAA has for the last 30 years is that they infrequently follow up on anything they say they will and many things simply “fall through the cracks.” When reading the OIG report one can say, “So what’s new.” In this writer’s opinion, the SUPs program needs to be re-energized and go back to some of the basic tenets including proper oversight, training, and analysis. I certainly hope the DOT/OIG will do a follow up audit to see if the FAA actually does what they said they will do. After all, the FAA concurred with all the recommendations in the report. But let’s not forget, the FAA’s Office of Audit and Evaluation cannot order changes. It’s up the Federal Aviation Administrator to make things happen.
Private industry should take a hard look at the report and not rely on the FAA to find SUPs. Industry needs to implement their own SUPs program to insure unapproved parts do not get into their stock or supply chain.