Findings
In the aerospace industry, the primary focus on parts traceability for many years has typically been for life-limited parts (LLP), or parts with a hard limitation on their lifespan, normally given in cycles, hours, or calendar days. LLP are found on both aircraft and aircraft engines, and current aviation regulations require aircraft operators to have a documented understanding of the current lifecycle status of any LLP installed on its engines or aircraft. That said, industry practice has generally developed beyond this regulatory requirement, and most LLP transactions today will require documentation of back-to-birth (BtB) traceability for the entirety of the lifespan of the LLP. By its nature, LLP are typically, but not always, serialized parts which raises the question of how to implement traceability features for non-serialized parts, such as those that were involved in the AOG Technics situation.
Although significant challenges remain for ensuring traceability of non-serialized parts–including constraints such as limited physical space of small parts, the need for extensive engineering and design analysis, and the ability to safely integrate in-service parts into any tracing scheme–the Coalition has identified several recommended actions to close this gap, including:
- Strengthening training materials, programs, and best practices;
- Ensuring the verification and auditing of scrap material and recycling vendors;
- Enhancing coordination between industry and aviation regulators to identify SUPs; and
- The long-term development of new technological solutions to improve parts traceability.
Short Term Actions
Recommendation #10
Strengthen Training Materials, Programs, and Promote Best Practices
While enhanced digitation and strengthened processes will provide greater traceability and validation of parts documentation, physical inspection of parts by experienced, well-qualified technicians remains a fundamental backstop to prevent SUPs from being installed on aircraft and engines. SME assessment respondents consistently identified the importance of upfront and continuing education and training on the parts purchasing, receiving, and inspection processes.
The Coalition thus recommends that the industry work collaboratively to develop best practices and principles for training materials to include for all personnel involved in procurement, receiving inspection, shipping inspection, and material control. Receiving inspectors serve as the last line of defense to prevent SUPs and non-airworthy parts from entering the system and must be highly trained and knowledgeable in inspection techniques and methods used to determine part quality.
Recommendation #11
Improve Verification and Auditing of Scrap Material and Recycling Vendors
The Coalition is concerned with the potential of scrap material exiting the ecosystem to be, either accidentally or otherwise, reinserted into the supply chain and used in parts installed on an aircraft. Scrap parts that have been removed from an aircraft or engine after reaching the end of their service life, pose a significant threat of being re-sold. Such parts that are not properly destroyed or mutilated may be reworked or camouflaged to appear as used serviceable material (USM) by bad actors looking to re-sell the material at a significant gain by misrepresenting its quality.
The Coalition recommends that any organization that handles aircraft parts— including parts distributors, air carriers, repair stations, aircraft manufacturers, engine manufacturers, and others—ensure that proper procedures and record keeping practices are in place. This verification should extend both to companies’ internal operations as well as third-party vendors that a company may contract with to dispose of scrap parts and material, in order to prevent such material (including non-serialized parts) from entering back into the marketplace disguised as USM. Regular auditing is a tool that should be utilized for third-party vendors to ensure compliance.
Medium Term Action
Recommendation #12
Improve Real-Time Data Sharing to Identify Unapproved Parts
The Coalition believes there is an opportunity to improve real-time data sharing across the industry to enable a quicker alerting of SUPs. The Coalition’s research found leveraging public databases that Civil Aviation Authorities maintain, along with other data sources, would help reduce the time between when SUPs are determined and when key individuals across the industry are informed.
The Coalition recommends the industry works to develop a clear process and clarify roles and responsibilities for all actors (operators, MROs, OEMs, suppliers, vendors, and others) for notifying when SUPs are identified in the supply chain.
Long Term Action
Recommendation #13
Develop New Technologies to Improve Parts Traceability
In the long term, the Coalition believes that technological solutions may exist to support the traceability of physically small non-serialized parts, including the use of digital twins. That includes using a digital unique identifier, the use of digital twin technology, and blockchain.