determine the quality and nature of the part. If the part can be discerned as an “approved part” based on part markings (e.g. TSOA markings or PMA markings) then these markings might be just as useful to an installer as paperwork would be. In other cases, manufacturer’s packaging might yield evidence of source. In still yet other cases, there might be nothing more than a certificate from an airline verifying that the part is a new surplus part. Do you have to rely on such documentation? NO! Are you allowed to rely on this documentation? YES (as long as it is trustworthy)! And this is the real trick with traceability. Certain documentation is deemed to be inherently more trustworthy than other documentation by the marketplace (remember the regulations do not describe appropriate nor inappropriate traceability documentation). Sometimes there will clearly be a “right” document. When exporting aircraft parts from the United States to Europe, for example, an 8130-3 is the “right” document according to the existing US-EU guidance. And because the 8130-3 tag is issued by the FAA, that document has been considered to be an acceptable document for many other transactions. But if you are receiving
a new surplus expendable, any document that you trust to validate that the part is really a genuine article that remains unused is sufficient. So, for example, an airline certificate verifying that the part was received new, and remains unused at the time of sale may be sufficient documentation of new status for many purchasers. For aircraft parts distributors, this lack of uniformity creates a potential nightmare: every repair station and every air carrier could have different standards for what they will accept (and many do have divergent standards for acceptance). The FAA recognized this issue, and as a consequence the FAA published recommended guidance for what the FAA believes to be acceptable documentation in FAA Advisory Circular (AC) 00-56A. AC 00-56A was created by the FAA in partnership with the manufacturing, air carrier, repair station and distribution communities. It provides reasonable standards for documentation: the documentation should identify the part and it should identify the part’s condition. It does not require documentation that does not add value (and some commercial documentation matrices do seem to seek non-value-added documentation).
Remember, AC 00-56A is not the law – it is merely guidance; but it is generally acknowledged as the starting point for any traceability list developed to discern appropriate documentation upon receiving inspection and upon subsequent transfer of an aircraft part.
AC 00-56A is available on the FAA’s
website. The documentation matrix from AC 00-56A is also reproduced in the ASA- 100 standard, which is available at www.
aviationsuppliers.org. AM
Aviation Maintenance |
avm-mag.com | April 2013 43
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