
Roy Resto
VP Technical Operations
FAA-DAR
Direct: 414 875-2191
Cell: 414 467-3063
Fax: 414 875-0200
royboy@tracercorp.com |
(revised Oct
2007, original blog posted Tuesday,
December 7th, 2004)
Shelf
Life Challenges
NOTE:
I’ve updated this article with some information that I
thought would be of some value to those of you similarly
‘challenged’. (10-2007)
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...
ROYBOY’s COUNSEL:
For rubber products, there is a document published by the
Department of Defense Titled “Rubber Products,
Recommended Shelf Life.” If you are pressed for
placing these commodities on a shelf life program, and you
can find no credible information, I’d use this document.
It is 45 pages long and available free at this
link:
https://progate.daps.dla.mil/home/
1) At the home page, click
on the “Specs/Stds” link
2) In the Document ID
block, type in MIL-HDBK-695, and submit it, then follow
the links. Royboy’s cool insider info: If you
are looking for any government specs or standards, try
this link first to see if it’s available free. It’s
also useful to see the latest revision and it’s status;
is it still active?
Another document which may
help as well is titled “Storage of Elastomer Seals
and Seal Assemblies Which Include an Elastomer Element
Prior to Hardware Assembly.” It is 18 pages long,
numbered ARP5316, and is available from the SAE for
purchase at www.sae.org. Try the DoD handbook first, since
it is free. Both documents contain very useful tables of
cross references to standards, part numbers, and of
course, recommended shelf life limitations.
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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