FAA issues new SUPs Guidance

The FAA has issued a “change one” to the SUPs Advisory Circular: AC 21-29D, Detecting and Reporting Suspected Unapproved Parts.
The change adds better information on how to subscribe to the FAA’s Unapproved Parts Notices (UPNs) in order to get them when they are issued, and it also updates some office references to make them consistent with the FAA’s reorganization.
Remember, the FAA eliminated the ability to make a SUPs report by phone when they issued the “D” revision last summer.  SUPs reports must be provided to the FAA by e-mail or by US mail.
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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  The new draft guidance mixes aftermarket procurement and production approval holder procurement in a way tat may cause confusion.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.

FAA Updates SUPs Guidance

The FAA has updated the guidance on detecting and reporting suspected unapproved parts (SUPs), which is known as Detecting and Reporting Suspected Unapproved Parts, FAA AC 21-29C CHG 2 (August 17, 2011).

The advisory circular’s update provides new references to various sections in Part 21 , to coincide with the October 16, 2009 changes in Part 21.  It also makes reference to the new commercial parts definition (part of the 2009 rule change), and clarifies that commercial parts are approved parts.

References to “fabrication inspection systems” are removed from the guidance (the concept of “fabrication inspection systems” was removed from the regulations in favor of unified standard production quality system regulations for all production approval holders).

Finally, the guidance is updated to reflect changed addresses and telephone contact numbers.

The newest guidance can be found online here:

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