Italy flags SUBSTANDARD PARTS what’s wrong with the PAH’s QA/QC requirements and FAA surveillance???
The AEROSPACE SUPPLY CHAIN has had significant problems since the pandemic and simultaneously the incidence of SUSPECTED UNAPPROVED PARTS has increased substantially. Given those two negative conditions have, not surprisingly, contributed to criminal charges being brought in Italy against companies and individuals accused of supplying substandard parts to Boeing.
At issue here is compliance with the FARs applicable to production approval holders (PAH) under 14 CFR Part 21. More specifically, AC 21-20C makes it clear that use of suppliers is not a static requirement. Here is a summary of what the PAH MUST COMPLY WITH TO MEET THE REQUIREMENTS OF THIS PRIVILEGE and of the FAA’s knowledge and involvement in this approval:
- to establish a quality control/fabrication inspection system as a prerequisite to the issuance of an FAA production approval, and to maintain the system after the approval has been issued conduct initial evaluation before accepting its product into the OEM’s inventory,
- First article inspection (FAI), to verify that the article conforms to the approved data and any additional contract/purchase order requirements, including, if necessary, destructive testing.
- create a quality system that includes a means to determine whether supplier-produced products, parts, appliances, software, consumables, materials, standard parts, and services conform to FAA-approved design data
- The system must ensure that all items furnished by its suppliers, including sub-tier suppliers, conform to contract/purchase order requirements.
- The contract/purchase order requirements depend on the complexity of supplied items and whether or not the supplier holds a production approval for similar items. These terms must ensure that safety critical items are specifically required to meet the requirements.
- The PAH is responsible for supplier adherence to the requirements flowed-down through the supplier chain.
- The PAH may not “delegate” responsibility under its production approval to a supplier; the PAH remains responsible.
- PAHs may use suppliers in other countries when the PAH has ESTABLISHED AND IMPLEMENTED A SUPPLIER CONTROL SYSTEM acceptable to the FAA. A PAH who plans to use a supplier in another country should notify the FAA as soon as possible to allow the FAA to determine the FAA’s ability to perform surveillance.
- The FAA does not “approve” suppliers, but may conduct surveillance of the PAH’s supplier control system at both PAH and supplier facilities in 09/24/2009 AC 21-20C 4 accordance with FAA Order 8120.2
- thoroughly document the selection of the contractor,
- periodically, on an ongoing basis evaluate the manufacturing,
- when the appropriate, disapprove supplier (based on the PAH’s onsite evaluations,
- the OEM may delegate some its tasks to suppliers,
- Immediately report all nonconforming items that may have left the supplier’s quality system,
- address potential undue burden issues,
- utilize industry shared processes, procedures, and methodology for supplier evaluation and surveillance,
- control direct shipments from a PAH’s supplier directly to a customer for items manufactured under the PAH’s production approval; and 09/24/2009 AC 21-20C 2
- A PAH is responsible for ensuring that each item conforms to the FAA-approved design data and is in a condition for safe operation. This responsibility remains the same whether the PAH produces the entire item at its facility or uses suppliers to furnish related items. Implementation and maintenance of the supplier control system is subject to evaluation by the FAA. FAA PRODUCTION APPROVALS ARE BASED ON THE ABILITY OF THE QUALITY SYSTEM TO ENSURE PRODUCTION OF CONFORMING ITEMS.
- Laboratory analysis for complete chemical and physical properties to be performed on each item when such tests can be performed without destroying the item; and 09/24/2009 AC 21-20C 6
- When laboratory analysis of items cannot be performed without destroying the item, a sample of such items should be subjected to a qualitative and quantitative analysis to verify complete chemical and physical properties (e.g., by test coupon or small section of the item).
- document an arrangement between a PAH and a supplier.
- Risk assessment, which must account for the combination of supplier and product risk factors. Product risk factors include safety classification from the design approval process, special process, and design and manufacturing complexity. SAE ARP9134 is an industry guideline that the FAA has reviewed and found acceptable to provide guidance for the identification of supplier risk factors
A PAH’s QA/QC obligations continue as the product hits its inventory storage. This is especially true when the technical specifications, e.g. “static and stress” resistance. Applicable design criteria should be established and subjected on a statistically appropriate random testing.
To add to the difficulty of assuring that the final assembled aircraft is airworthy, the PAH must deal with Suspected Unapproved Parts, scourge of aviation safety. SUPs are particularly nefarious because they are difficult if not impossible to detect. Paperwork can be easily faked with all the image technology. Bogus parts that superficially meet form, fit and function can be reversed engineered with laser measure technology and 3D manufacturing but likely lack the manufacturing steps that assure durability, strength, heat resistance and other unseen critical performance elements. Detection of SUPs is no longer a matter of careful comparison of an item to the OEM drawings/specifications. The mere reliance on the offered documentation is no longer reliable proof of the authenticity of a part. The expertise to perform these Quality Control determinations requires frequent updating of the SUP scams state-of-the-art information.
The procedures set by the regulations and amplified by the FAA’s written materials SHOULD HAVE PRECLUDED this influx of substandard parts. WHAT WENT WRONG ON THIS SIDE OF THE ATLANTIC?
Italy: Two Companies Made Substandard Parts For Boeing
By Spyros Georgilidakis | October 6, 2024
Authorities in Italy accuse two companies and seven individuals of risking aviation safety by supplying flawed parts for Boeing aircraft.
This is an issue that goes back to 2021. In October that year, Boeing revealed that a number of 787 components that it got from a subcontractor, weren’t up to standard. This wasn’t a new problem. Boeing discovered that it had been assembling 787s with these parts for the previous three years!
Boeing got these parts through contractors like Leonardo and Spirit AeroSystems, but these companies, in turn, got them from another subcontractor in Italy. That company was called Processi Speciali, and later went bankrupt.
Then a newer entity, called Process Manufacturing Specification (MPS[1]), replaced Processi Speciali. The owner of MPS is Antonio Ingrosso, while his father, Vincenzo Ingrosso, previously owned Processi Speciali.
These two companies are now believed to be at the centre of an investigation in Italy, involving non-conforming Boeing 787 parts. MPS and Processi Speciali had to supply parts made of titanium and aluminum, which they then processed further.
Suspect Boeing Parts in Italy – Lower-Grade Metals?
But according to prosecutors in Italy, the two companies used LOWER GRADES OF TITANIUM AND ALUMINUM, to make these Boeing parts. These meant that the parts had “…significantly lower static and stress resistance characteristics, with repercussions on aviation safety”, according to the prosecutors.
Several experts helped prosecutors in Italy and elsewhere identify non-conforming parts that the two companies made for Boeing. In total, prosecutors now believe that the companies supplied 4,829 TITANIUM COMPONENTS, plus 1,158 other parts made using ALUMINUM. That’s up from 4,189 COMPONENTS in total, that we knew from earlier reports (in December 2021).
Boeing has already identified aircraft that include suspect parts from the two subcontractors in Italy. It appears that these parts are primarily fasteners (nuts, bolts, washers). Boeing reassured operators that this DOESN’T REPRESENT AN IMMEDIATE SAFETY-OF-FLIGHT ISSUE, BUT THEIR LONGEVITY COULD BE A FACTOR.
Removing all of these parts from stored and in-service aircraft was a TIME-CONSUMING AND VERY COSTLY process, something that prosecutors are factoring into the proceedings. However, the case hasn’t yet made it to court. A lawyer for the Ingrossos stated that they believe that “they have acted respecting fully the law”.
One of the many criticisms on Boeing over the past couple of decades is a push to outsource much of its parts manufacturing and assembly outside its own installations in the United States. Keeping quality control in check when dealing with an expanding network of suppliers has been a key part of this challenge.
[1] Not 100% clear that this link is for this company.
