CAVU Café: Royboy’s Prose & Cons, Page 3 of 17

In this age where we bask in torrents of overwhelming data, we must pause and ask, as we used to say in the military, what bits of this information comprise actionable intelligence? Most importantly is which bits can be data-mined for analysis which will contribute to continuous improvement in your operation?

BACKGROUND: In my experience in working with many firms, an often-overlooked opportunity exists to data mine product returns to suppliers, or from customers and/or RMA (Return Material Authorizations) activity, or reported discrepancies, for possible quality issues. Among firms that do track such data, there is great variation in the level of data mining occurring.

There is no question that for firms with robust tracking of this data, when quality issues are identified it may drive as applicable:

• Flagging, or requalification of suppliers.
• The need for additional training to prevent recurrences.
• The revision of existing procedures.
• The creation of new procedures.
• Triggering your Corrective or Preventive Action Process.
• Possible reporting of Suspected Unapproved Parts.
• Possible submission of malfunction and defect reports (if you’re an MRO or airline).

Regarding product returns from customers and/or its RMA activity, it’s interesting that none of the FAA AC 00-56, ISO/AS, ASA-100, or AFRA BMP standards appear to require the tracking of this data. ISO/AS/EN may infer or encourage such data to be tracked but it is not specifically called for and so once again there are some ISO/AS/EN firms that do, and some that don’t. So, if you choose not to analyze this data, you are not literally breaking any standards or regulations. For firms with Quality Systems not based on ISO/AS/EN, this is rarely tracked.

Regarding returns to suppliers or reported supplier discrepancies, standards like the ASA-100 require that a ‘Quality History’ for the approved suppliers be established.

CATEGORIES: The broad issues under consideration here naturally fall into three types of data with their own peculiarities and thus should be tracked separately:

• Product returns from customers.
• Product returns to suppliers.
• Discrepancies identified by customers, or by you regarding supplier parts, and both of which did not result in returns of the product.

DATA COLLECTION: If you’re convinced of the need to monitor this activity, the initial challenge arises from how you will gather the data.

• Product returns from Customers:
  • If your ERP system has built in features to facilitate RMAs for customer returns, this is a good source of data to tabulate, analyze and act upon. Make sure all your employees are using the RMA for such activity.
  • Don’t overlook warranty claims from your customer in this data mix.

• Discrepancies reported by your customers, but which did not result in product returns:
  • In this entire article this is perhaps the one issue that should be looked at critically. Effective and methodical collection and analysis of this data has the greatest potential to solidify a strong and mutually beneficial relationship with your customer.
  • “You don’t know what you don’t know”. The difficulty in obtaining every instance of a customer issue is directly proportional to the size of your company. The bigger you are, the greater the potential pool of employees interfacing with your customers, and if so, does each one have the discipline to uniformly document or report a customer issue in such a way that it can be collected and analyzed? So, just how are you collecting this information? If not, start now!

• Product returns to Suppliers:
  • Consider using the Claims section of your ERP system.
  • If you are using a Receiving Discrepancy Log or equivalent, also consider this to be a source of data. Make sure that even the minor issues are logged.

• If the data is dispersed in your system and not easily retrieved, consider finding someone that is handy with Crystal Reports to write a script that will automate the extraction and tabulation (how the data is presented) for either scenario (Returns from Customers, or Returns to Suppliers).

DATA MINING: Regarding the data which either of the three scenarios creates, the mining aspect would consist of the following:

• Accurately tracking the data- Make sure there no go-arounds or discreet off-the-record activity, see below.
• Analysis- Tracking and graphing the data is not enough. Here’s where the skills of your staff can shine. See Analysis section below.
• KPIs – Consider instituting Key Performance Indicator levels for the subsequent data.

ANALYSIS: An employee who is good at analysis is always a rock star on the staff. Analysis not only requires a command of the subject material, but skills at connecting the dots - taking apparently disparate points of data and seeing common connections. Effective skills often reflect a bit of creativity in this processing.

• Consider that there may be interplay between Returns from Customers and Returns to Suppliers. For example, your customer returns material to you on your RMA resulting on your returning it to the supplier.
• Minimally, consider using Pareto Analysis to drive your corrective actions.
• The many root cause analysis tools may be called upon.

BEWARE OF UNDOCUMENTED UNDERREPORTED ACTIVITY:

You have a favorite customer. They have been tracking the discrepancies caused by your shipments to them. Very few of these resulted in product returns to you via RMAs, and your sales staff have been rectifying each issue directly with the customer. Suddenly, you stop getting POs from them. It turns out that like so many major customers, there are set limits with quality issues which, once exceeded result in your being restricted from further business activity. When your company is apprised of the circumstances, your QA Manager is held to answer but was never made aware of the activity in the first place. Whose fault is this?

It's similarly interesting that some of the product return activity from customers may be deliberately underreported or handled in such a way that it does not draw too much attention within the firm. For example, the firm may be using an ERP system that has an RMA capability built in, but when asked how many RMAs have been issued to their customers for returns, they appear proud to say that there have been none or its remarkably low; probing further it’s discovered that certain salespersons have deliberately gone around the RMA system and discreetly handle the return with emails and personal intervention. The QA Manager remains in the dark.

Put the right data to work for you; be a rock star with your customers; make it happen…

Over ‘n out

Roy ‘Royboy’ Resto

www.aimsolutionsconsulting.com

The content of this article was written without the assistance of any AI programs.

In aviation a conspicuous requirement among all the standards and regulations is training, Every. Single. One.

Do you claim to have a Quality and Safety culture? Show me your training program.

If there has ever been a critical time to revisit and emphasize your training program it is now.

In this article we’ll address the following:

• Industry Characteristics.
• Executives: We need to talk.
• Types of Training.
  • Required Training
  • Recurrent Training
  • Remedial Training

Industry Characteristics. Consider these following current characteristics of our industry:

• High rates of turnover among staff.
• New employees in important positions performing their tasks for the first time.
• Staff shortages lead to employees being cross utilized into positions they have no experience in.
• Employees new to aviation.
• Retirements.

Executives: We need to talk (don’t you hate it when an exchange starts out with that characterization? This will be one of those). I’ve noticed a troubling trend among executives; they don’t attend their company’s training sessions. Let me share a few stories:

• I’ll have a training session at a client’s place of business and afterwards employees tell me privately (while pointing their accusatory index finger in the direction of the executive offices) that ‘they’ should have been in the class to hear the subject matter.
• I noticed early in my career after I had received a nice promotion, that I would get the firm’s invitations to attend training classes. I was new and young and determined to learn all I could. In those classes the absence of anyone in management at my level or above was, to me, conspicuous. The instructors told me on more than a few occasions that they appreciated my participation and that it sent a positive message to the rank and file. Some of the union members would also share their observation that they respected this, and further that they thought the non-attending management staff thought of themselves as ‘too good’ and self-important to attend training sessions with the employees. I have never forgotten this lesson, and yes, I did learn from attending those classes.
• Recently a client, among the many whose firm was shaken up by the AOG Technics case, asked that I come and speak to the staff about the lessons learned and impart a training session on the same topic. It was the CEO who called me. While I was in the process of setting up the date with his staff assistant, I learned that the CEO, and some of his executive staff ‘would not be able to attend.’ I called the CEO and politely shared that if he and his executives did not attend, neither would I. After a pregnant pause, he agreed and set up the mandatory session. Before the class I asked that at the end he share with the staff his feelings on the subject matter, the expectations of the company, and any ensuing policy. This went very well and afterwards the CEO thanked me for pushing this.
• As an auditor of various standards, I notice when members of the executive staff have chosen to be on the required Roster. Anyone on the Roster can be sampled for training records, and many times it’s disappointing to notice that, while the documented training for these executives may be compliant, it may have been years since any additional training of any kind has been documented. Often, unsurprisingly, if called upon to perform the duties they are authorized on the Roster to perform, the results are less than compliant with their own written procedures.

For sure no one is suggesting that your executives take introductory classes such as those for new employees, but some course material is more relevant and of importance to the broader staff. Go; turn off your cell phone, ask questions, and at the end make a supportive statement for the attendees regarding the imparted topics; it will gain the respect of your staff and demonstrate management’s support for the importance of training.

Types of Training:

• Required Training: This is simply training that is required by your regulators, accreditation standard, or by your own choice. Depending on the scope of your operations, such topics may include Unapproved and Counterfeit Parts, HAZMAT, Human Factors, Forklift and other machinery, ESD, FOD (Foreign Object Damage) Prevention, Lockout/Tagout, Fall Protection, Confined Space, and Use of PPE (Personal Protective Equipment) among many others,
• Recurrent Training: This is training which must be performed at specified intervals for the employee to remain qualified, or topics which the firm feels are important enough to warrant repeated training, including refreshers. For example, HAZMAT, Human Factors, and Forklift training are required periodically as are others. On the other hand, your firm may decide, for example, that SUPs and Counterfeit Parts need to be updated and imparted annually or biannually.
• Remedial Training. Typically, this is imparted to an individual employee or department due to some event or need. The event may be an accident that occurred, a finding of non-compliance during an audit, or simply refresher training due to an employee not having performed a function for some time.

Methods to Deliver Training:

• Classroom: This is the typical training with an instructor addressing a class
• OJT: On the Job Training. This is classically over-the-shoulder training whereby a supervisor or experienced colleague is showing you, or leading you through the task, and is usually one-on-one. This is very effective as it allows the trainee to ask questions in a casual setting and for the trainer to gauge the trainee’s progress and effectiveness - did the trainee grasp it? The problem I observe with OJT is that it is not always consistently documented as are the other types of training.
• LMS: Learning Management System. An LMS is a software tool that allows you to create, deliver, and report on training courses and programs. There are many LMSs to choose from, each offering different features and capabilities. The LMS may be the product of a company internal system, or you may rely on the LMS services of an external provider, or a hybrid program.
• Zoom or MS Teams Live Sessions. Many of you have employees performing their duties remotely in geographically diverse locations. It is understood that it is impractical to fly them in for every classroom event, so a remote session may be set up for those employees. My experience with this type of impartation method is that unless it is for one-on-one OJT type training with screen sharing for example, it is the least effective. I have had Zoom or Teams sessions where the attendees were obviously multi-tasking or not in attendance. I’ll call their name and ask a question about the topic and their response is an embarrassing excuse that they were ‘distracted’ during this part of the class. In some cases, the attendee will not respond at all. Later I’ll try them again in case they were in the restroom. After a third attempt with no response, I won’t sign for them on the training listing. Wait, wait, was that an Executive I just took off the list? Nah, couldn’t be.

The Science of Training:

Immersive Virtual Reality, Artificial Intelligence, LMS, and Learning Analytics are among the many buzzwords trainers are today embracing to make learning more effective and useful. While it is certainly beyond the scope of this article to discuss these, the point is made that the methods to impart effective training are evolving and so should your analysis of the quality of training in your own operation.

Over ‘n out

Roy ‘Royboy’ Resto

www.AimSolutionsConsulting.com

https://www.linkedin.com/in/royresto/

This article was written without the use of AI generated content.

As many of you know I have a fondness for electronics born of my avionics and electronic warfare background and experience, so the subject matter herein always commands my attention, as it should for you too since so many of you either sell assemblies with electronic/electrical components in them or sell the individual electronic/electrical components themselves. In this article we’ll review:

• Definition of counterfeit.
• Who is ERAI?
• The data.
• The new Quality Standards being flowed down to suppliers specifically target these parts with detection, reporting, and mitigation measures.

DEFINITIONS OF COUNTERFEIT:

• Counterfeit Material: Fraudulent materiel that has been confirmed to be a copy, imitation or substitute that has been represented, identified, or marked as genuine, and/or altered by a source without legal right with intent to mislead, deceive or defraud.

• AS9120 defines it as: “An unauthorized copy, imitation, substitute, or modified part (e.g., material, part, component), which is knowingly misrepresented as a specified genuine part of an original or authorized manufacturer.
  •  NOTE: Examples of a counterfeit part can include, but are not limited to, the false identification of marking or labeling, grade, serial number, date code, documentation, or performance characteristics.”

WHO IS ERAI?

Founded in 1995, ERAI, Inc. is a global information services organization that monitors, investigates, and reports issues affecting the global electronics supply chain. As the industry’s leading source of risk assessment tools, ERAI provides exclusive services and in-depth information that enable its members to perform industry-specific risk mitigation on suspect counterfeit, high-risk, and non-conforming parts and identify problematic suppliers and customers.¹

I follow ERAI on LinkedIn², so I tend to keep up with their data on the topic. The latest for the complete year of 2023 was recently posted³ which is being shared herein.

THE DATA:

A very telling graph of the total number reported against total sales.

What parts are affected?

NEW QUALITY STANDARDS BEING FLOWED DOWN TO SUPPLIERS WHICH SPECIFICALLY TARGET THESE PARTS WITH MITIGATION MEASURES:

Notice that these (see below) are all AS numbered for Aerospace Standards. Suppliers who these are being flowed down to are either being asked to implement them with full accreditation, or to be compliant with key aspects. I’ve audited a company who was fully accredited to one of these and worked with another to write compliant procedures for limited aspects. Both are ASA-100 accredited as well.

With certainty the data covers the broadest cross section of different industries, but as can be seen in the AS Standards, Aerospace is taking positive action to mitigate the phenomenon. The DoD has taken a well-founded alarmist view of this, and a Senate Armed Services Committee Hearing was held to herald the issues. The trouble is that the data seems to show that the activity continues unabated except for the dips in reports during the Covid period. Here are recent press releases reflective of this disturbing activity.^{4, 5}

This article was written without the use of AI generated content.

Over ‘n out

Roy Resto

www.AimSolutionsConsulting.com

https://www.linkedin.com/in/royresto/

1: https://www.erai.com/aboutus_profile

2- https://www.linkedin.com/groups/3758841/

3- https://www.erai.com/erai_blog/3183/_2023_annual_report

4- https://www.justice.gov/opa/pr/man-pleads-guilty-selling-35m-counterfeit-and-deficient-electronics-use-military-systems

5- https://www.nj.com/monmouth/2024/05/ceo-gets-6-years-for-selling-counterfeit-equipment-that-ended-up-on-fighter-jets.html

Me at home: ‘Honey, where’s the ketchup, did you finish it?’

Wife: ‘It’s in the fridge’

Me: ‘I looked, it’s not there’

The sound of pounding footsteps on a mission are heard marching to the fridge, whereupon an impressive and commanding opening swing of the door is given, the wife’s hand swivels like a whip, tip towards the now mysteriously reappeared bottle of ketchup and voila, there it is. I bow and kiss her backhand then meekishly apply the condiment.

Occasionally solutions to our problems are right in front of us, and like ketchup on a burger, sometimes it’s advisable to add additional words to season our documents for the many reasons we’ll discuss.

What are one of the entries that all these forms have in common?

• ASA Statement Form
• ATA Spec 106
• Other Material Certifications
• FAA 8130-3
• EASA form 1
• TC Form 1
• CAAC ACC 038
• ANAC Segvoo
• CASA Form 1
• CAA Form 1

As you’ve likely deduced, these all have provisions for Remarks. From my experience this feature is one of the most underutilized blocks in any form.

Use of this block can prevent a customer from rejecting your part or be used to explain issues that might otherwise cause angst upon receipt. Let’s look at some real-world examples.

• I was in the process of issuing a DAR 8130-3 for about twenty new-condition Igniters. These were all serialized. The problem was they were in opaque packaging, and I could barely read the serial numbers on the parts. I would have to open each OEM packaged part and reseal them after the s/n verification. The applicant (old school term for the person asking that I issue the 8130-3) cringed that I was going to do so because the customer would see the OEM packaging had been opened and resealed and possibly reject the order for these new parts. The solution? I put a comment in the Remarks block:

• “Note: The undersigned opened and resealed these Igniters for the purpose of verifying the serial numbers.”

There was no problem with the customer and the Igniters were accepted.

• Another time one of my Inspectors brought a part to my attention which had unusual coloration patterns on it. The MRO that Overhauled it said it was normal but still my Inspector and I were not 100% comfortable with it. This was the part:

• We took some pictures and sent them to the Purchasing Customer who also confirmed it was normal. Based on this I insisted the Inspector put this in Remarks on our Cert:
• “Note: The potentially unusual coloration patterns was shown to Mr. XXXX on XX/XX/XX via emailed pictures, and he stated this was normal and acceptable.”

The part was accepted with no problems.

• SIDEBAR: About similar occurrences: Many times, a lot of you communicate any unusual circumstances to your customer who, perhaps by email or a phone call say it’s alright and to ship it. ALWAYS keep this in mind: Is the person who told you to ship it the same person or department who will perform the receiving inspection? Unless your customer is a very small company, this is unlikely. So, the part goes to the customer, the Inspector rejects it and puts it in the hold area peppered with a new blemish against your company, only for the details to be sorted out a week later. In these situations, the timely use of a Note in the Remarks section of your cert (as per above for example), would have saved you time and embarrassment and contributed to on time payment.

• On another occasion a friend asked me to evaluate about 15 pages of trace. Embedded within the pages of a Tear Down report from an MRO was the fact that the application of a Service Bulletin had changed the dash number of the part. This bit of information helped explain some concerns expressed about the trace paperwork. I strongly urged my friend to place an explanatory note in the Remarks block of his Material Certification to explain these acceptable circumstances. Salted thusly, the part and its 15 pages of Trace Documents sailed through the customer’s receiving inspectors.

By the way, I wrote an article on the importance of MRO Tear Down reports which I hope you’ll find interesting. Here’s the link:

https://www.aviationsuppliers.org/THE-VALUE-OF-TEAR-DOWN-REPORTS

• Those silly ‘Fresh Tag’ requirements: Lets say you have a New condition part with an EASA Form 1 which is 4 years old. Your customer wants the part but has a 2-year fresh tag requirement. A common option is to have it sent to an MRO for a fresh tag. The problem is that an MRO cannot issue a tag who’s status is NEW… only approved manufacturers can do that. The MRO can state Inspected, for example. In your PO to the MRO ask that they put a statement in the Remarks block that the part was received in New condition on EASA Form 1 FTN (Form Tracking Number) 123456. When you ship the part send the EASA Form 1 and the fresh tag.

Even though the fresh tag is now in Inspected status, under this simple example Royboy would support you marketing the part in New condition since the part still has zero Operating Time and Cycles, which is the de facto definition for New parts.

By the way, regarding the ‘silly’ requirement in my characterization, here’s another article I wrote directly challenging it:

https://www.aviationsuppliers.org/aftermarket-tags-overhauled-vs-repaired-vs-2-years

TO MANUFACTURERS AND MROS.

If your parts have shelf life, PLEASE put this information in the Remarks Block of your Airworthiness Release Certificate; some of you do and some of you don’t, and it may get overlooked on page 3 of your certs or Tear Down Report.

IN SUMMARY: Regardless of what form and ERP system you are using, these all have provisions for the addition of free text. Use it for Remarks!

This article was written without the use of AI assistance.

Over ‘n out

Roy ‘Royboy’ Resto

www.AimSolutionsConsulting.com

Scenario: You are a distributor, and you have an MMR (Multi Mode Receiver) in your Quarantine Cage because the MRO- Maintenance Repair & Overhaul shop returned the part to you as BER- Beyond Economical Repair due to an unrepairable power supply. There is a customer who is looking for a cover whose part number is the cover for the MMR in the Q Cage. You simply remove the 10 screws to disassemble the cover from the MMR assembly, and voila, you have an AR- As Removed condition part and you’re a hero to your customer because this part was not to be found on the market.

Certainly, this is a simple example, but the concepts we’ll go over in this article can be applied to this small assembly (the MMR) or to major assemblies such as Landing Gears, APUs, and Air Cycle Machines. This brings to mind many details we’ll cover in this article including the following:

• Background
  • USM
  • Do I need to be Certificated by an AA- Aviation Authority?
  • AFRA intro

• Forms and procedures to consider
  • Procedures in your manual
  • Tags and
    • Do I need a certificated Technician to perform the disassembly?
    • Who can issue an ‘Inspected’ 8130-3 or equivalent for removed parts during a disassembly of an aircraft?
  • Removal log
  • Capping, bagging, packaging
  • Trace considerations/representations
  • Records
  • Royboy’s Parting Counsel

BACKGROUND:

USM or Used Serviceable Material is increasingly popular as an alternative to factory new parts whose prices have soared, and lead times extended. Besides those well-known supply chain issues there are in some cases a challenged aftermarket environment due to certain OEM behaviors as explained in this blog article:

https://www.aviationsuppliers.org/AIRLINE-MX-COSTS-WILL-GO-UP

An increasingly popular source of USM parts is from aircraft and engines which have been disassembled.

Before we go any further, we need to point out that the ‘S’ in USM means Serviceable (Inspected, Tested, Repaired, Overhauled). Nearly all parts disassembled from a NHA- Next Higher Assembly are at that moment in AR- As Removed condition. That AR part will have to be sent to a Repair Station/AMO- Approved Maintenance Organisation which will reestablish the part’s airworthiness before it can be installed on an aircraft. I only mention this because the USM moniker is bandied about for a broad range of parts in the aftermarket including these AR unserviceable parts, so its ok to continue to use USM if this is kept in mind.

Do I need to be Certificated by an AA- Aviation Authority? As long as you are not declaring any of the disassembled parts as airworthy, then the answer is no. This is neatly articulated in Jason Dickstein’s blog article:

https://aviationsuppliers.wpcomstaging.com/2014/08/28/no-aircraft-disassembly-is-not-a-maintenance-activity-under-the-faa-regulations/

AFRA Intro. For firms whose core business is disassembly of entire aircraft, engines, or any subcomponents, there is likely an affiliation with AFRA, Aircraft Fleet Recycling Association.

https://afraassociation.org/

AFRA has established disassembly and recycling standards whereby compliant firms can be accredited for Disassembly, Demolition, and Recycling; see the Directory tab at the noted website. With a certainty this article is not suggesting that any of your limited disassembly activates as a distributor be accredited by AFRA, but you should be made aware of their standards and activities in case you want to step up your game. It is interesting to note the synergies between the ASA and AFRA which are quite natural considering the overlapping activities of each other’s members. For example, many AFRA accredited firms are ASA-100 and vice versa. You’ll also notice that the ASA and AFRA annual conferences have been held concurrently now for many years.

FORMS AND PROCEDURES TO CONSIDER.

Procedures in your manual. The ASA-100 paragraph 1.A.1) states:

1. The quality system, including procedures and operations, shall be described in detail in a quality manual, or other appropriate documents.

If you’re selling parts from your disassembly operation under your accredited name and enjoying the business benefits of your ASA-100 accreditation therein, then there is the expectation that your Quality Manual will describe your disassembly operations (exception: you are also AFRA accredited and disassembly procedures are described in the AFRA manual). Consider some of the items presented here for inclusion. Consider placing this in your manual:

• A description of what you’re doing.
• Blank samples of the Tags or Logs in the forms section of your manual, and in your procedure describe their use.
• A description of any technical data you may be using and whether you have access to Manufacturer’s online data or use of For-Reference-Only manuals.

Tags: Perhaps one of the most important documents to implement which facilitates the sale of the part and establishes the trace trail (more on that later), is the use of the Removal or Identification Tag. Here is a blank sample and a filled-in example:

Currently, use of such a tag is dominant in the industry and is sometimes supplemented by, or replaced by a Manifest of removed parts, but the current best practice is the simple tag. It should be affixed immediately upon removal. This is just a sample, and variations of it are common.

Do I need a certificated Technician to perform the disassembly? There are certainly advantages to using a Certificated Aircraft Technician to perform your disassembly operations. Generally, they are familiar with Technical Manuals, tools, and proper handling of aircraft parts. Some firms also feel that having a Technician exercise their credential on the removal tag, for example “A&P Joe Smith” is added value or adds credibility to the process. To be certain, however, this is not required. Royboy’s recommendation is then to use someone with attention-to-details, and who is mechanically inclined.

Who can issue an ‘Inspected’ 8130-3 or equivalent for removed parts from a disassembly of an aircraft? If you are a Repair Station or Approved Maintenance Organisation, and you have a written procedure in your manual to do so, you’re the one who can issue an Inspected tag (8130-3 or equivalent). I have written procedures accepted for this process, and these should always have a document number, for example WI-1501. Here’s a quick summary of the logic. An aircraft arrives at your hangar for disassembly. For it to have flown there it must have been Airworthy, and the Airworthy Certificate carried on board. Except for any open write-ups in the logbook, you can reasonably assume that the aircraft (and its parts and components) are airworthy. If there are any open write-ups, they will be found in the logbook with its ATA chapter noted. Let’s say you want to start to remove all the radios. You look in the logbook and there are no ATA Chapter 23 write-ups. Next you go to the AMM- Aircraft Maintenance Manual and find in chapter 23 where it typically requires a visual inspection of the system during operational checks or troubleshooting. You perform the visual check and find nothing untoward. You remove the radio, cap it, and the resulting 8130-3 says Inspected as its condition. I highly recommend that the remarks block transparently and plainly state the circumstances involved, for example, “Removed from MSN 12345”. Of course, the remarks must also contain a reference to the AMM and cite your written procedure. For example, “Visually Inspected per AMM 23-15-44 paragraph 23-14, and (Company Name) Procedure WI-1501.”

Regarding this process, some customers will accept such parts, and some won’t. I was once told by an airline person wagging their loaded finger at me that this could not possibly be allowed! I countered by saying, ‘then how is it that you’re allowed to do it?” What! For more info read this background article titled “Cannibalizing, Robbing, and Swapping Aircraft Parts” at this link:

https://www.aviationsuppliers.org/Cannibalizing-Robbing-and-Swapping-Aircraft-Parts

The following is a simple and generalized flowchart regarding tagging options for a disassembly I have presented in the past at conferences. Apologies if it seems small for the posting.

Removal Log. If you have a complete assembly of any kind and you start to harvest parts from it, Royboy highly recommends that you have a method to track the parts removed from this Next Higher Assembly. Why? The reason is that if for any reason you are now presented with a PO (Purchase Order) for the entire assembly, you’ll have to restore or provide the parts removed in order to sell it as a complete assembly. If you have a Removal Log entry for every part that was removed, you now have a simple listing to facilitate the process. The Removal Log would always stay with assembly.

I distinctly recall my airline days whereby we had spare engines at a few major bases, and those engines were always tempting targets to harvest parts which were not in stock. The written procedure included posting a Removal Log so anyone would instantly know what parts were missing and on order.

Tooling, Capping, Bagging, Packaging. In addition to a wide assortment of tools it is recommended that you also have a wide assortment of caps and plugs for electrical, pneumatic, fuel, oil, and hydraulic connections upon disassembly. This must include a reasonable assortment of ESD caps and bags for such parts. Depending on the size and type of part being disassembled, consider hoists, drip pans (for parts with oil, fuel, or hydraulic fluids which will leak), or stands made for major assemblies such as engines and APUs, see below.

Trace Considerations/representations. If you have heard me speak or read many of my articles, you’ll have taken notice of my repeated use of the word ‘transparency’, and so it is with parts that have been disassembled from a NHA. Our customers continue to require clear and transparent trace as stated on their T&Cs- Terms and Conditions on their Purchase Orders. For the example given for the MMR cover, providing the removal tag (or copy) is important. Next is what is the trace for the MMR? Unless you’re selling the part in AR condition, then of course your documentation package would include the Airworthiness Release Certificate from whomever you used to perform the Overhaul, Repair, or Inspected/Tested.

Records: As with any activity occurring in your distributorship, and as required by the ASA-100 and nearly all Quality Standards and Aviation Regulations, keep precise records which are reasonably accessible upon request.

Royboy’s Parting Counsel:

• Don’t let your disassembly area turn into a junk yard! Keep it neat and tidy which is a positive reflection of your operation.
• Say what you do and do what you say. Put it in your manual.
• Just because you have AR parts does not give one license to treat aircraft parts any different than you would Serviceable parts; properly cap, protect, and tag the parts. This too is a positive reflection of your operation.

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

Over ‘n out

Roy ‘Royboy’ Resto

www.AimSolutionsConsulting.com

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