SUPs still a scourge of Aviation Safety
Regulators adopt different approaches
FAA’s too convoluted ?
Airlines, MROs and Parts Distributors could use help.
There is no more complex aviation safety than the requirements under the Suspected Unapproved Parts. The materials available to airlines, Part 145s and parts distributors for learning the vagaries of distinguishing the legal from the illegal are long and require considerable focus to absorb. The time, effort and expense for educating your inspectors, QC staff and purchasing agents are cost productive because the consequences of including an SUP on a plane can be disastrous in terms of safety.
Equally daunting are the efforts by the regulators to interdict these parts. The world’s CAAs first must define the critical parameters that distinguish legal from illegal parts. For those entrusted with interpreting the airworthiness, the difficulty is exacerbated by variations in criteria, i.e. FAA v. EASA:
EASA has created a webpage listing all of its SUPs in one place-
The FAA has similar advice but not as consolidated. Its internal SUP seems disjointed with processes which appear not to expedite the determination of whether the part is an SUP:
The US Department of Inspector General (OIG), sub silento, found problem with the closing of an FAA office devoted to SUPs and delegation to regions and field offices. As noted by the OIG and here, the subject requires considerable expertise in order to make these judgments:
The FAA’s order explains the desired process—
Division of responsibilities like this tends to slow the time needed to decide what the part’s status is and the dispersion of duties will not likely maximize the subject matter expertise needed.
More curious is the selection of the Office of Audit and Evaluation (AEE) as the inception point? If one queries the FAA Website for where to report an SUP, the page that appears is this—
AEE is a small office and serves as the FAA focal point for public and employee safety complaints; reports of waste, fraud and abuse; internal FAA rule or policy violations; and whistleblower disclosures—FAA Hotline and AIR21 Whistleblower Protection Program. What value does this add to keeping SUPs out of the system?
This review should make it clear that SUP compliance is not intuitive, is subject to variations in the CAA community and has seen changing criteria. It appears wise to seek assistance in acquiring superior SUP knowledge.
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