THE IMPORTANCE OF REMOVAL/DISASSEMBLY TAG

The following topics will be addressed:

• Background
• Requirements for Removal Tags
• Best Practices for Removal Tags
• Regarding your Trace Trail
• Accredited Disassembly Firms

BACKGROUND

Conspicuous in the aftermarket is the rise in the availability of Used Serviceable Material, USM, traced to aircraft or engine disassembly (AKA part-outs) projects. The disassembly phenomenon is one of the manifestations in the marketplace to mitigate well-known supply chain shortages. Disassembly operations can extend to not just whole aircraft and engines, but to subassemblies thereof. An informative article regarding this practice is titled “Performing Limited Disassembly Is On The Rise” and is available at this link:

https://www.aviationsuppliers.org/performing-limited-disassembly-is-on-the-rise

Regardless of whether the disassembly was for a whole aircraft, Engine, or subassembly, many of you have commercial requirements in your Purchase Order terms and conditions that such parts be provided with documented trace to the last operator/lesser. A critical document which authenticates that the part was removed from the aircraft or engine you have trace to is the Removal Tag, sometimes referred to as an identification tag, or may go by other names to accomplish the same purpose.

REQUIREMENTS FOR REMOVAL TAGS:

Firms which are accredited to perform Disassembly follow the requirements of AFRA’s (Aircraft Fleet Recycling Association) BMP; Best Management Practice for Disassembly. The BMP contains these requirements for the tags:

“Article V c) – Tagging in a Disassembly Operation

BEST PRACTICE (V)(c) 1 – Each part/component removed will have a removal tag bearing the facility name disassembling the asset. Information on the tag must include:

• Manufacturer’s part number

• Serial number (as applicable)

• Part description

• Quantity

• Condition code

• The Next Higher Assembly (NHA) the part was removed from, e.g., MSN, ESN, aircraft registration number (optional, but MSN has precedence), or manufacturer’s serial number for assets which are not Engines or Airframes

• Date removed

• Reason for removal (optional)

• The removal tag must be signed or stamped and dated by the facility or agency representative performing the disassembly. Optionally, the signature/stamp may be digitally generated.”

In addition to the AFRA requirement, China’s CAAC 145 MROs who have it in their Operations Specifications to perform disassembly use a CAAC specified removal tag form.

BEST PRACTICES FOR REMOVAL TAGS:

• Although not a requirement, an emerging best practice is that the tag have a unique number, a tag number.
• For firms performing the disassembly, the final tabulation of parts is a listing commonly called the Manifest, sometimes called the Harvest List. The Manifest would have the corresponding tag number for each part number. Since the tag is affixed to the part, this makes it easy to perform an inventory audit when you sort the Manifest by tag number.
• Another emerging best practice is that the tag has a unique QR code. The QR code could link to:
  • Its Manifest Listing
  • The file of pictures of the parts
  • The trace documents

REGARDING YOUR TRACE TRAIL:

Keep in mind that the company performing the disassembly may be performing it as a service; they were not the owners in the trace trail. Compare this to your owning an AR condition part in which you use the services of a repair station/AMO to have the part overhauled and it is returned to you. There was no exchange of ownership in the transaction, so while the repair station/AMO performed a service, it is not relevant to the actual trace trail.

As with repair stations/AMOs, disassemblers have two options:

• Disassembly is performed as a service for whomever owns the asset (aircraft, engine, major assembly, etc.). In this case they are not an integral part of trace trail.
• The disassembler purchased the assets themselves and owned the subsequent parts. In this case they are an integral part of the trace trail.

Previously I mentioned that at the conclusion of the disassembly project there is a resultant Manifest or Harvest list. If you are buying a single part traced to a disassembly, you may or may not be provided with that Manifest but insist on the Removal Tag. For that single part the Manifest is not really needed since the tag suffices to establish the trace.

On the other hand, there are some firms performing disassembly who are not AFRA accredited and therefor not following the AFRA BMP. Although increasingly rare, such firms may not use a Removal Tag and instead rely wholly on the resultant Manifest. In this case having the Manifest would be critical to establishing the trace otherwise accomplished by the tag, and you should demand it.

ACCREDITED DISASSEMBLY FIRMS:

A directory of firms which are accredited to perform disassembly can be found at this link:

https://www.afraassociation.org/accredited-companies

Make it happen, over ‘n out

Roy ‘Royboy’ Resto

Written without the use of AI