
Roy Resto
VP Technical Operations
FAA-DAR
Direct: 414 875-2191
Cell: 414 467-3063
Fax: 414 875-0200
royboy@tracercorp.com |
(Tuesday,
December 7th, 2004)
Shelf
Life Challenges
I learned
a new word recently: Whinge. It’s an old English
word meaning to moan, or to complain fretfully; to whine.
When it comes to certain shelf life issues, I feel an
unexplainable urge to engage in whinging.
Shelf
life control should be an easy program to manage, right?
Not always. The easy part is when the packaging on a part
has a stated expiration date; these are most easily
identified and placed on your shelf life control program.
Most difficulties however, arise from the following:
- New
parts that have a stated cure date, but no stated
expiration date or shelf life limitation
- New
parts that really have a shelf life but do not have
either a stated cure date, shelf life, or expiration
date, or any other indication of shelf life
- In
service rotables (repaired or overhauled for example)
that have shelf life limitations, but the company
stocking these parts is not aware of the limitations
We’ll
talk more about these, but first an introduction to the
subject.
A
PRIMER: Certain
parts and commodities (I’ll refer to both collectively
as ‘parts’) start to deteriorate or degrade from the
moment they are manufactured. Engineers determine how long
a part or commodity can last in storage, and thus the
shelf life. The shelf life is typically expressed either
in the length of time of the shelf life, or with an actual
expiration date. The length of time might be expressed in
quarters (a quarter being three months), 20 Quarters for
example (5 years) from the time of manufacture. It’s
most easy when there is a plain expiration date on the
packaging. There is another class of part, that although
it does not deteriorate or degrade as discussed, must
nonetheless be periodically tested. These don’t have a
literal ‘shelf life’ per se, but nonetheless must be
tracked as are typical shelf life parts to assure none are
issued ‘expired’.
Such
parts known to contain shelf life include:
- Aircraft
Main, or APU Batteries.
- Parts
containing batteries such as Flight Data Recorders,
Cockpit Voice Recorders, life jackets, Survival
Equipment, Emergency Path Lighting Packs,
defibrillators, and Emergency Locator Transmitters (ELT’s).
- Parts
required by FAR’s to be tested periodically such as
ATC Transponders (FAR 91.413)
- Certain
o-rings, packings, hoses, or components containing
such parts.
- Certain
greases, paints, enamels and sealants.
- Pressure
vessels, such as oxygen cylinders and fire
extinguisher bottles have mandatory tests that must be
performed periodically. Known as Hydrostatic tests,
the period depends on the type of bottle.
- Aircraft
First Aid kits
For these
parts, you should have a shelf life control program that
accomplishes the following:
- For
parts in stock you should have a system to track
these such that stock is rotated for First-In,
First-Out, and most importantly, that no stock is
issued beyond its date of expiration. Depending on
the markings on these parts, you may need to affix the
expiration date on the individual parts, or some sort
of other conspicuous indicator. There are many
variations on how you control this stock, but suffice
it to say that the process should be documented in
your Quality System, and be in compliance with your
chosen quality standard.
- For
commodities issued to the shop or to mechanics:
Your stock room may issue greases, paint, and sealants
to the shop, or for mechanic’s use. If these are
shelf life controlled items, operators typically affix
their own expiration date decals to each issued
commodity. Its purpose is to assure that shop
employees don’t use the commodity beyond its
expiration date. Most operators have written
procedures making it clear that it is the mechanic’s
responsibility to assure when using such products, it
not beyond it expiration date.
THE
CHALLENGES: But
wait! I have not yet engaged in the sport of whinging!
Thus far, the aforementioned Primer section was pretty
routine for those of us familiar with shelf life control.
Lets now examine those challenging areas:
New
parts that have a stated cure date, but no stated
expiration date or shelf life limitation:
Some people see a stated “Cure Date” on a part’s
packaging and assume the part must be shelf life
controlled. Not necessarily. I’ve seen many parts with a
stated cure date, but the manufacturer helped us by also
stating “No expiration date”, or some variation of
that. Great huh? The problem arises when there really
is an expiration date, but there is no indication of
that except the cure date. Here’s a sampling of the
reasons I’ve heard for leaving it off:
- The
part is also used in the commercial world
(non-aviation), where there is not a quality concern
with shelf life, so, to standardize packaging, they
leave off the expiration date.
- The
expiration dates were originally controlled by
military specs, and those specs are no longer being
maintained by the government
- The
application determines the shelf life
Exacerbating
this is the fact that quite a few end users/operators will
evaluate these parts and establish their own shelf life
limitations. So what’s a person to do with these parts?
Your first option is to call the manufacturer and ask them
if any shelf life limitations exist. Your second option is
to call your customer and ask them the same question. Regardless,
you should be able to track the cure dates for the parts,
and state as much to potential customers for them to make
up their mind whether they want to proceed with the
purchase. Unfortunately,
there is no black and white answer to this problem, other
than to whinge about lack of support from the
manufacturers.
New
parts that really have a shelf life but do not have either
a stated cure date, shelf life, or expiration date, or any
other indication of shelf life. Now, this one really
chaps my hide! We have a lot of bearings in stock, and a
customer’s auditor asked us why we didn’t have the
bearings on our shelf life control program? Imagine,
bearings of course don’t have a cure date on them, and
these don’t have any indication either on the
packaging or accompanying
paperwork of such limitations. Surprised, I called the
manufacturer, and sure enough, there is shelf life. I’m
now heard to raise my incredulous voice and ask the
obvious: Well, why don’t you put it on the packaging?
A long list of self-serving excuses ensues, along with a
cryptic faxed document explaining the shelf life policy.
It is based on the bearing’s preservative grease and
packaging. Unless we are blessed with the Spirit of
Prophecy, we are simply not going to know these things!
I’m want to whinge some more, but nah...
In
service rotables (repaired or overhauled for example) that
have shelf life limitations, but the company stocking
these parts is not aware of the limitations.
Here’s where we could help by expanding a little on
parts affected by shelf life.
- Anything
with batteries in them. If you see a Cockpit Voice
Recorder (CVR) or Flight Data Recorder (FDR) with an
installed acoustic beacon, check the beacon, and
you’ll see it has an expiration date on it. The
beacon, or pinger as some call it, sets off an
emergency signal when immersed in water; it runs on
batteries, and thus the shelf life. The beacon is
usually a cylinder about 4 inches long by 1.5 inches
in diameter on the front of the CVR/FDR. As stated,
the beacon will have an expiration date, and the
repair/overhaul shop’s paperwork will state the
same. Life vests, emergency equipment such as that
found in life raft kits, Defibrillators, Emergency
Locator Transmitters, Main Aircraft batteries, APU
batteries, and Emergency path lighting packs, all
contain, or are batteries. A visual inspection of
the part and paperwork will reveal its shelf life.
- Parts
required by FAR’s to be tested periodically such as
Transponders (FAR 91.413). This is another
potential gotcha. Transponders are typical of
parts that must be periodically tested, in this case
every 24 months. They must be tracked similarly to
shelf life parts to assure none are issued to your
customer expired. The DOT also requires
pressure vessels to be tested periodically. For these
parts in your serviceable stock, are they on a
monitoring program?
Savvy
Shelf Life Purchasers:
Keen purchasers of shelf life limited parts usually put a
boiler plate statement in their purchase orders that they
will not accept such parts unless 80% of the shelf life
remains. So much for first in, first out! Of course if
there’s an AOG, and you’re the only game in town, and
only 20% remains, guess what? But don’t get me
started...
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