FAA SUPs Notices

BACKGROUND:
A sobering thought: The FAA’s SUP’s office in Washington DC (AVR-20), continues to receive hundreds of Suspected Unapproved Parts (SUPs) reports a year. Some turn out to be harmless or unfounded, and some result in actions by certain agencies. Most are handled without fanfare. In a few instances, when the FAA SUPs office feels that the public needs to be apprised of the results of an investigation, they will issue an Unapproved Parts Notice (UPN). An example of when to issue a UPN may involve a repair station that overhauled hundreds of parts that were not processed in accordance with approved data, and the FAA could not positively determine who in the aviation public were in possession of those parts. In this case, the FAA would issue the UPN to the public for the obvious reasons. On the other hand, if it was determined that the same repair station produced only 10 such parts, and the repair station and the FAA were able to contact all ten of the operators/owners of those parts to effectively recall the parts, there’s really no need to issue a UPN. Suffice it to say that even then the repair station may face some “administrative actions” by the FAA. How do you get these UPNs?

ACCESSING UPNs:
Being on distribution for UPNs depends on who you are. If you’re an airline or repair station, someone in your organization is already on distribution for these (most of the time). If you’re a distributor it is very unlikely that you are on distribution. If you are a distributor who is an ASA (Aviation Suppliers Association) member, you’ll see these published in the ASA Newsletter. In any event, you can access UPN’s directly at the FAA’s SUPs website at: 
http://www.faa.gov/avr/sups 
In fact I urge you to poke around this web site for all the useful information posted there regardless if you’re on distribution for UPNs or otherwise. OK, just what in the world are you expected to do with these UPNs?

WHAT SHOULD YOU DO WITH UPNs?
How you address UPNs depends again, on who you are.
Distributors: If you claim to have a wonderful Quality System, and in particular if you are an accredited distributor, your customers expect that you perform SUPs screening of the parts you process. If, as part of your SUPs screening program you do not methodically and routinely access UPNs, you are not being sufficiently thorough in your Quality system (there, I said it, and I meant it). Typically, when you get or access a new UPN your first question should be “Have we been in receipt of, or shipped parts that were affected by the UPN?” In most cases, the UPN will list the name of a company, and perhaps some part numbers. Have you purchased parts from that company? What about the part numbers? A quick check of your inventory control system should apprise you of that. If you make a determination that you have shipped parts to a customer affected by the UPN, the right thing to do is to apprise them of the fact, and work out a corrective action plan with them as necessary. The overwhelming majority of the time you won’t be affected by the UPNs, but consider the following. If you deal in the aftermarket, there may be some lingering affected parts that may eventually come across your inspection system. Can you place warnings in your inventory control system to apprise salespersons about accepting trace to a certain company? How about circulating the UPN to your inspectors for a ‘read and sign’ effort?
Airlines and Repair Stations: If these types of companies make the determination that parts installed or in their system are affected by the UPN, they have to make the tough decision about what to do with them. The corrective action depends on the circumstances. For example, do the parts affect safety of flight, can a simple BITE check or other visual check verify the airworthiness of the part, how many parts are involved, will the parts have to be removed and sent to a shop, etc? The realm of possibilities is really endless, and to list the possible corrective actions is beyond the scope of this Tech Log. I have the utmost confidence in the operators to make the right decisions.

BEWARE THE PARTS WITH MULTIPLE CHAINS OF CUSTODY.
Suppose you are inspecting a part and you have all its trace documents in hand. At this time it is quite easy to determine if the chain of custody (which may have changed hands several times) involves a company affected by a UPN. But what about those parts you’ve shipped or installed already? You’ve long ago filed the trace documents, and your inventory control system will only tell you from whom you directly purchased the part, not its chain of custody. This masks a potential positive determination that you have parts affected by a UPN. This is most troubling and problematic. Do you have the resources to dedicate to search stored boxes and boxes of trace documents because you think there’s a possibility that a trace chain of custody may involve a company named by a UPN? What you do really depends on your integrity and wisdom. If you have a basis to assume that a reasonable possibility exists of such trace, what will you do about it?
In a perfect world, someone at every aviation company involved with aircraft parts would access and take responsible action when affected by a UPN, then this problem would not be up for discussion. But since this perfection does not exist, the industry can only rely on informed, educated and responsible persons like yourself.