A commercial decision. 

By Chuck Marx, SkyThread Chief Strategy Officer

Note: this post is part of a 52-week series Chuck is posting about digital aviation. This post is Week 6.

Aircraft are registered, aircraft parts are not. We do understand that the regulations at the part level are carefully crafted “to be sure” that the collection of 3,500 parts that fly together in what we call “an airplane” are airworthy. And for the most part, the outcomes are achieved. But the inefficiency, waste and delay are tremendous. We’ve been talking about strengthening the aircraft part authentication process for well over 25 years. Including requiring “back to birth” reporting on aircraft parts. But …

“There is no FAA or EASA rule that makes "back to birth" traceability mandatory for all aircraft parts. The aviation regulations concerning installation of parts essentially require that the installer have some means of assuring that the installation of the part will return the aircraft or engine assembly to an airworthy condition. The aircraft operation rules require that all the important documentation associated with an aircraft must be transferred to the new owner at the time of sale, but there is no comparable regulation concerning the sale of a part. This means that there is no regulation that dictates the sort of documentation that is required to accompany an aircraft part during a commercial transaction.”

“Instead, the sale of aircraft parts is governed by commercial practices. Some of these commercial practices support the regulatory obligations of the customers, some of the practices support their regulatory quality concerns, and still others support the customers' economic initiatives. As a commercial measure, there is nothing wrong with a customer asking for "back to birth" traceability.”

“While it is not required by the rules, many in the aviation industry have championed the notion of "back to birth" traceability as a means of reducing the high level of manual efforts deployed by parts buyers and installers to assure part quality.  The proponents of this form of traceability make some good points about its utility. This method of documentation can be used as one method of achieving several important safety and regulatory compliance goals during the installation process. The biggest problem with "back to birth" traceability is that it is not always available, particularly for inventories of older parts meant for installation on older platforms. 

Nearly 20% of the aircraft in commercial fleets today are no longer in production by the airframer, making parts supply chains harder to plan and manage.”

“Often these parts were manufactured during a time when "back-to-birth" traceability of non-life-limited aviation aftermarket parts was less of a concern and thus either "birth" documentation never existed or was lost at front door to whichever air carrier first owned the inventory. Even today, many production approval holders do not provide the buyer with acceptable "birth" documentation when a part is initially sold (making subsequent traceability difficult or impossible). In short, “back to birth” traceability is sometimes impossible even though the parts are demonstrably airworthy.”

The Installer's Duties

Installation of an aircraft part is a maintenance activity.  As such, the installer is required to comply with the rules that require the work to be done in such a manner as to return the product to an airworthy condition with respect to the work performed. The installer has an obligation to be sure that the parts installed will meet the airworthiness standards of the regulations. In addition, the installer is responsible for generating records of the work performed.”

Installation of Approved Parts

By virtue of the FAA oversight and certification, there is a presumption that a part is airworthy for the intended installation(s) at the time that the part was manufactured. That same part bears the same presumption throughout its life. If an installer can verify that the part was originally manufactured under the controls of an FAA approved manufacturer, then the installer can rely on this presumption at the time of installation. This presumption of airworthiness does not relieve the installer of the obligation to inspect the part to assure airworthiness.

There is a wide world of misadventures that may befall a part, from the manufacturer's assembly line to the installer's hands, like shipping damage or expiration of shelf-life. Reliance on traceability to a manufacturer's certification can relieve the installer of the obligation to assure a fundamental baseline of airworthiness - an exercise that must be undertaken when the mechanic intends to install a part for which there is no reasonable assurance of airworthiness.”

“There are other ways for the installer to establish the baseline airworthiness of the part. Just as an installer can rely on the manufacturer's FAA certificate to affirm that the part is airworthy at the time it left the manufacturer's quality system, an installer can also rely on a finding of airworthiness made by a qualified entity during the life of the part. Qualified entities include repair stations, air carriers, and A&P mechanics. They can perform an inspection on a part to assure that it is airworthy and can then issue documentation to indicate the results of that inspection.” 

The fact that an installer can rely on a prior finding of airworthiness is the essence of the FAA's advisory circular, AC 00-56. The AC recommends a quality system for distributors of aircraft parts.  This circular indicates what sort of documentation must accompany parts admitted through the receiving inspection system, and parts that are sold by the distributor. Parts that arrive at the facility of the receiving accredited distributor must generally be accompanied by an airworthiness approval, like the 8130-3 or the JAA-1.   This means that even an "as is" part must bear a certified statement from the seller stating that it is in "as is" condition.

Where to begin?

SkyThread has launched SkyThread for Parts which has begun accepting data from across the industry to build the data sharing network through which a part’s life history can be documented, gaps identified and used to support the required research to evaluate a part. SkyThread is working simultaneously with the following actors to build the histories of the some 60 million flying serialized aircraft parts and 40 million parts “staged” for installation as needed.

New Aircraft Parts

• Tier 1 Suppliers - Begin capturing birth records for newly manufactured aircraft parts.

• Airframe and Airlines – Capture the initial aircraft registration number as the 1st use of that part.

• Activate the SkyThread for Parts storyline to capture removals, repairs and installation on new aircraft.

Existing Aircraft Parts

• Tier 1 Suppliers – Capture, where possible, the historical manufacturing records and documentation of all parts manufactured through its contemporary history.

• Airlines – capture the serial numbers of parts flying on planes today to establish a “current view” of active parts.

• MRO Providers – begin capturing the repair parametrics for each part repaired while carrying forward life limiting characteristics.

• Component Repair Facilities – capturing the ongoing and historical repairs parametrics for parts that have come through their facility, with quality document(s)

Decommissioned Aircraft

• A large supply of parts will be coming back into the USM markets.  Capture the serial numbers to be scrapped to record their “end of life” and the parts coming back into the supply chain to maintain their life history.

“This Part is on the Chain”

This topic has been in deep discussion on this topic for over 25 years. We’re ready to solve it now and not leave these issues to the next generation. Thank you to the Airline Suppliers Association for their article titled Back to Birth Traceability dated December 1998 which forms the background for this article.

ASA Home (aviationsuppliers.org)   6TURdec.PDF (aviationsuppliers.org)