Findings
Documentation plays a critical role in tracking parts in the aviation supply chain, and maintaining the industry’s commitment and focus on safety requires a robust process by companies to correctly track, inventory, and validate paperwork to follow manufacturing and maintenance procedures.
Upon issuance of a certificate of conformance or airworthiness (FAA Form 8130-3 or EASA Form 1), new aircraft and engine parts are deemed genuine, and can be traded freely on the marketplace. Given the inherent importance of these certificates to the authenticity of the parts they accompany, they remain subject to potential fraud and counterfeiting—as we saw with AOG Technics.
Given the significant risks of SUPs to aviation safety, the Coalition spent a significant amount of time discussing recommendations to improve the authentication, verification, and traceability of documents within the industry.
The aviation industry continues to rely on physical paperwork, which can be both easier to counterfeit and more difficult to process in a timely manner. Several of the Coalition’s SME assessment respondents noted that the industry’s heavy reliance on paper documentation made investigating and responding to the AOG Technics case more difficult and onerous, and that they began to digitize their paper documentation and employ Optical Character Recognition (OCR) to process their paperwork faster in response to the threat realized from the AOG Technics circumstances.
In many instances with AOG, the counterfeit ARCs included what looked to be fairly accurate depictions of an authorized signature, while other falsified features of the document were disparate—a purchase order number that did not conform to the OEM’s practice, or a part number that conflicted with the part the document accompanied.
The Coalition’s recommendations in this area seek to increase digital documentation and digital authentication tools across the industry and utilize emerging technologies to reduce the risk of fraudulent airworthiness certificates.
In the Coalition’s view, there are several methods that can be employed to utilize technology to improve traceability, and ensure authenticity of documentation, as the Coalition heard from SMEs across the industry, including:
- Expanding the use of digital Authorized Release Certificates (ARCs) and increasing the use of other digital tools to enhance document authentication;
- Establishing industry standard documentation requirements to ensure consistency across the industry;
- Promoting the digitization of existing and past parts-related documents;
- Developing and adopting an industry-wide use of a software database to verify key Authorized Release Certificate (ARC) fields; and
- Establishing a voluntary industry database of Back-to-Birth parts documentation with non-competitive data.
Short Term Action
Recommendation #5
Expand the Use of Digital Key Documents and Increase Digital Authentication Tools Use
While digital ARCs, including FAA Form 8130-3 and EASA Form 1, have been authorized by the FAA since 2009, their broader use remains limited. Further, while certain facets of the industry, including many sales offices and brokerage firms, utilize digital ARCs more regularly—primarily in PDF form—their use may not translate to the records retention or receiving inspection department where critical parts and parts documentation operations occur. Additionally, the use of digital verification and authentication tools remains very limited.
In response to these challenges, the Coalition strongly recommends that all stakeholders within the industry, including MROs, repair stations, air carriers, lessors, and brokers, adopt digital ARCs in as many functions as possible. This shift towards digital documentation is crucial for enhancing the security, efficiency, and traceability of the supply chain.
Furthermore, the Coalition recommends the use of sophisticated digital document verification tools to ensure the authenticity of ARCs.
Medium Term Actions
Recommendation #6
Establish Standard for Required Information in Documentation
The development and adoption of industry standard documentation requirements would enhance consistency, uniformity, reliability, and quality across the industry. This will not only reduce variability in how documents are completed and processed but also significantly decrease the risk of fraud if implemented properly. This also facilitates easier compliance checks and regulatory approvals.
Recommendation #7
Digitize Existing and Past-Parts Documents
The Coalition recommends that industry work to digitize all parts-related documents, including ARCs, using Optical Character Recognition (OCR) to create a fully digital environment. While newly generated documents will be originated in digital format, there remains a need to digitize older physical documentation.
Recommendation #8
Develop and Adopt Industry-Wide Use of Software Database to Verify Key Document Fields
The Coalition recommends developing a software system or algorithm, potentially hosted through a third party, that can query OEMs, air carriers, and PAH databases of ARCs to electronically validate the data listed in each field on the ARC for accuracy, authenticity, and legitimacy. The proposed solution involves creating Application Programming Interfaces (APIs) to facilitate real-time data querying of ARC fields such as part number, form tracking number, and serial number.
Long Term Action
Recommendation #9
Establish Voluntary Industry Database of Back-to-Birth Parts Documentation
During the research phase, many SME respondents highlighted the value of back-to-birth (BtB) traceability for new parts, in which PAHs provide an airworthiness certificate upon an article being produced under their system. While a long-term effort will require significant coordination across the industry, the Coalition believes in the value of establishing BtB traceability for as many parts as reasonably possible, and has established several suggested principles to inform a voluntary base that could be created to track such parts across the supply chain.
Long term, the Coalition recommends the establishment of a voluntary industry database of digitized ARCs with the goal of achieving BtB traceability for all parts, including non-serialized “standard” parts. The database would provide detailed traceability for parts from production to end-of-life, crucial for ensuring authenticity, safety, and compliance.