FAA Seeks Comments on a Major Revision to SUPs Guidance

The FAA has published revised guidance on Detecting and Reporting Suspected Unapproved Parts (Proposed AC 21-29D).  This revised guidance is currently out for public comment.

The existing guidance has always strongly focused on aftermarket procurement.  The new draft guidance mixes aftermarket procurement and production approval holder procurement in a way tat may cause confusion.  In addition, the new draft has placed some advice in places that simply don’t make sense, and that are likely to cause confusion.  For example, there is a list of situations that may raise question in section 5.2.2.  Some of them are normal red flags, like non-manufacturers who suggest an unlimited supply of certain articles.

Some of the advice is contrary to industry norms – the fact that a distributor has parts on the shelf when the manufacturer is advertising a long lead time is listed as a red flag; however maintaining parts on the shelf and selling them when the manufacturers have no parts on the shelf is exactly what distributors do in the aviation industry.

But some of the advice in nonsensical.  One of the situations that may raise question in section 5.2.2 states:

Traceability to approved design and production approval should be requested by purchasers on their purchase orders for all parts intended for use on TC products.

This sort of advice may be useful to the industry, but it is clearly misplaced in a list of ‘red flag’ situations.

Another example where change is necessary is found in  section 5.3.5, which lists acceptable documentation but (a) fails to list some normal industry documents that are considered acceptable in other FAA guidance and (b) fails to harmonize with the documentation matrix found in AC 00-56.  This latter failure to harmonize is particularly surprising, because the new guidance strongly focusses on the value presented by the FAA’s Voluntary Industry Distributor Accreditation Program.

Those who are interested in learning more about the FAA’s Voluntary Industry Distributor Accreditation Program (including its history) should examine the ASA-100 page, which also has links to the relevant FAA and ASA documents.

This is a major revision when compared to the “C” revision of AC 21-29.  There are some clear opportunities to improve this document.   Distributors, and those who buy from distributors, should strongly consider reading this document and commenting on it.

Comments on this draft are due September 28, 2015.  You can email comments to:
Joseph.palmisano@faa.gov, but please send copies of your comments to ASA so that ASA’s comments can be sure to reflect your concerns.

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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