It has been 22 years since the ATA Spec 106 was updated, and it is now at revision 2023.1. The proper and full name of this document is ATA Specification 106, Sources & Approved Parts Qualification Guidelines (herein ‘the spec’). In this article the following will be presented:

• Common misconceptions
• Interesting facts about the spec
• What has changed with the Form?
• Use of the form to comply with the ASA-100
• Continuing issues with the form and specification
• The ASA Statement Form

COMMON MISCONCEPTIONS

• The ATA Spec 106 consists of just the one-page form:
  • In fact, the spec consists of 50 pages, of which only 8 pages currently address the use of the form. I’m frequently asked about certain entries on the form, and I respond by asking ‘have you looked at the spec regarding how to fill it out?’ This is met by raised eyebrows, a pause, and a ‘thanks, I’ll get back to you.’

• This is an ASA (Aviation Suppliers Association) form:
  • ATA stands for Air Transport Association, who is now the A4A or Airlines for America. The spec retains the legacy ‘ATA’ for ease of identification. The spec and its form have never been an invention of the ASA.

• The ASA requires the use of the form:
• The ASA has never required use of this form; however many distributors use it as a means to show compliance with certain sections of the ASA-100. More on this later.
  

INTERESTING FACTS ABOUT THE SPEC

• Documentation: First released on April 1, 1993 the spec, which was a creation of the member airlines of the ATA, created a simple to understand Table B-1.1: Aircraft Parts Documentation Requirements. This was a significant development which for the first time standardized the expected documentation from a given source for a given condition, a big deal… Many companies copied this table, adapted it, and continuously updated it for their own uses; I see the vestiges of this ATA table in many manuals.

• Back to Birth: It was in this same table (note 2 of the table) that ‘Cradle to Grave’ (AKA Back to Birth) was born, and established in the eyes of the airlines, the legitimacy of such documentation for Life Limited Parts even though this has never been a regulatory requirement. Oddly enough, some of those same airlines that require Back-to-Birth for purchases of Life Limited Parts don’t themselves provide this same extent of documentation when they sell their own Life Limited Parts…, there, I said it and I meant it. This should be removed from the spec and made to align with regulatory requirements.

• Definitions: The spec contains a section on definitions. The value of this is that it contains definitions for many words which do not find expression in regulatory literature. For example, As Is, Production Overruns, Rotable Parts, Supplier, Surplus, and Traceability. The traditional and widely circulated legacy definition of “Traceability” came from here.

• The ATA Spec 106 Form: The need for the form was born in the turbulent ‘bogus parts’ era of the 1990’s. For example, at one time when I worked at a major airline all the Receiving Inspectors reported to me. Surplus parts documentation ranged all over the map, and every receipt had to be deciphered as to what were the circumstances of the purchased parts. The airlines posited that use of a single page form which summarized the major topics of interest would greatly aid and simplify the receiving process. In fact, a gentleman at Northwest Airlines, Jim Frisbee, drafted and presented such a form which in its draft status was humorously referred to as the “Frisbee Form”. The Form was presented to the ATA and voila, the welcomed ATA Spec 106 Form was born.

• NIS, Non Incident Statement: In the legacy copies of the spec in the section regarding the Form’s Remarks block it states:
  • If a particular part was obtained from any of the following, then it should be so identified:
    • a. Government agency (non-military) or non-FAA certificated aircraft.
    • b. Aircraft or engine subjected to extreme stress or heat, major failure, accident, or fire.

And there you have it, the birth of the Non-Incident Statement

WHAT HAS CHANGED WITH THE FORM?

• Added a new Block 18B (thereby making the existing Block 18, now 18A). According to the spec:
• 1.22. Block 18B Non-Incident Confirmation:
  
By initialing the check box, the signature acknowledges that to the best of their knowledge the identified part does not meet any of the “Unusual Circumstances” identified in section 3-1 paragraph D. of this document.

Section 3-1 paragraph D of the spec which refers to paragraph C:

• C. Surplus "used" supplier's parts obtained from any of the following "Unusual Circumstances" that do not have a FAA Form 8130-3 filled out according to the "RTS" section of current revision of Order 8130.21 (procedures for use of Form 8130-3) must be accompanied by documentation identifying the circumstance.
  • (1) Noncertificated aircraft (aircraft without airworthiness certificated, i.e., public use, non-U.S., and military surplus aircraft).
  • (2) Knowledge of aircraft, aircraft engines, propellers or appliances that have been subjected to extreme stress, sudden stoppage, heat, major failure or accident.
  • (3) Salvaged aircraft or aircraft components.
• • D. Document the above condition on Block 13A – Remarks, on ATA106 Form (see instructions below). ATA106 Form block 18A, when completed, denotes that the supplier, to the best of their knowledge, attests the part does not meet any of the “Unusual Circumstances” noted in paragraph C. of this section.

Although the above paragraphs appear to have some minor issues with the cross references, the following can be reasonably concluded:

• The spec requires that only when the part does not have an 8130-3 with a Return to Service release, and when any of the ‘Unusual Circumstances’ describes exists, then those circumstances must be stated in the Remarks block of the form.
• If none of those circumstances exists, then block 18B is to be checked. Clearly, when 18B is checked (initialed), the spec is saying there is no further need to have any sort of non-incident statement in Remarks.
  

USE OF THE FORM TO COMPLY WITH THE ASA-100

Likely contributory to the mistaken perception that the ASA requires use of this form and/or that it is an ASA form, is that many accredited firms use it to comply with a section of the ASA-100 standard. Section 10 of the standard is titled: Certification and Release of Materials. Its paragraph B:

“B. Additionally, a certified statement disclosing the following should be issued about the material or parts, certifying that they were or were not:

1) subjected to conditions of extreme stress, heat or environment,

2) previously installed in a public aircraft, such as a government use aircraft or a military aircraft.”

To date, the form most used to express these statements is the ATA Spec 106.

CONTINUING ISSUES WITH THE 106 FORM

• The form retains Block 9, Eligibility. The intent of this block is for the originator to enter “The aircraft, propeller, engine or appliance model on which the part may be installed if known.” This block has always been optional, but the industry, in recognition that it has always been up to the installer to determine Eligibility, long ago removed the same block from the 8130-3 and EASA Form 1 among others. On this form today, nearly all originators enter N/A or TBV (to be verified by installer), meaning that, this has fallen into disuse.
• Block 14 New Parts Verification: For new parts being signed on the ‘left side’ of form, the block refers only to the USA-centric FAA. But what if you have new parts from a CAA or EASA source, for example? Signing here would appear to be a falsehood.
• The cited language above, which refers to what is loosely called the Non-Incident Statement does not recognize what the global community is moving toward which is called the ICS or Incident/accident clearance statement. For more information read my article on the topic here:
  • https://www.aviationsuppliers.org/NON-INCIDENT/ACCIDENT-STATEMENT-NIS-and-INCIDENT/ACCIDENT-CLEARANCE-STATEMENTS-ICS

THE ASA STATEMENT FORM

For all the reasons cited above, the ASA’s QA Committee worked on developing the ASA Statement Form 2020. It brings into the 21st century the desired information and retains the one-page summary of the essential data needed to expedite the receiving process – BRAVO! Here’s the link to the form, training, and detailed instructions:

https://www.aviationsuppliers.org/asa-statement-form-2020

Most importantly:

It has been a long time since I’ve seen a customer’s PO specifically call for an ATA Spec 106 from their supplier. If your customer uses generic titles in their Terms & Conditions requiring your ‘C of C’, or ‘Material Certification’ then you are free to use the ASA Statement Form… make it happen!

This article was written without the use of any AI apps or programs.

Over ‘n out

Roy ‘Royboy’ Resto

www.AimSolutionsConsulting.com