As early as 1956, the Civil Aeronautics Administration (predecessor of the Federal Aviation Authority) issued Aviation Safety Releases regarding unapproved parts."Unapproved parts'' is the Federal Aviation Administration's (FAA) term for components not certified as airworthy; in the industry, they are known as "bogus parts.''
A bogus part is either a part that is purported to be as good as a manufacturer’s part, or at least as good as one manufactured according to the standards set by the FAA’s Parts Manufacturing Approval, but lacking the necessary supporting documentation or engineering substantiation; or it is an old item that has been cleaned up and sold on again. In addition to breaching internationally recognised airworthiness regulations, the suppliers of these potentially life threatening parts are guilty of criminal fraud and anyone purchasing suspiciously cheap parts for further sale could also be deemed guilty of fraudulence.
According to a report by the Civil Aviation Safety Authority of Australia, there are cases of hardware failing qualification testing and being sold as scrap metal, only to find its way back into the market via the scrap dealer; there are cases of aircraft hardware being copied, including the proper manufacturer’s identification markings, but made from substandard steel and/or alloy.
Most disturbingly there have also been incidences of outlaw salvagers rushing to crash sites to get their hands on as many parts from the plane as possible, using sophisticated tools to extract engine thrust reversers, cockpit avionics and other valuable parts. These damaged parts have then been offered for sale. According to one article published in the Lubock Avalanche Journal, parts illegally salvaged from crashes, counterfeit parts and other substandard components regularly find their way into the world's air fleets and are sold at bargain prices, often with falsified documents about their origin or composition. The financial gains are so great that one Colombian parts trafficker told a Miami detective she had switched to the trade from drug-running.
Another term used in the aviation industry is “rogue components”. Typically these are genuine components, for example an aircraft black box, that are unserviceable but marked and certified as serviceable and re-distributed in the aviation market to make profit. Consider the recent British Airways incident at London Heathrow in January 2008. The Air Accident Investigation Bureau (AAIB) in the UK is convinced that the incident resulted from auto throttle fault. What if the Auto Throttle Management Unit was a rogue component that escaped detection? Mere conjecture, but nonetheless not impossible given the obvious financial incentives.
Some of the bogus parts are not even that sophisticated and easily spotted by an expert. Mark Scott is a Licensed Aircraft Maintenance Engineer and, as such, responsible for inspecting aircraft to ensure that they conform to safety regulations. He related an incident in which he discovered a bogus aircraft part on a Boeing 757-200 aircraft: “…during a routine landing gear inspection, I noticed that the left-hand landing gear strut door links were bogus; just bits of aluminium alloy shaped to look like the genuine part.”
As with all forms of counterfeiting, there are major risks involved – the risk of criminal prosecution and the risk to lives – but the financial rewards and savings that can be made sometimes outweigh the risks. In 2000 writer and author Jerry White reported on the lengths that Alaskan Airlines went in their cost cutting by falsifying maintenance data on inspections that were not actually carried out. This was found to be a contributory factor in the Alaska Airlines flight 261 accident that killed 88 people as a result of a faulty horizontal stabiliser jackscrew.
Overseeing aviation standards
An agency of the United States Department of Transportation, the Federal Aviation Administration is responsible for the safety of civil aviation in the U.S. The FAA is responsible for certain airworthiness recommendations that are often mandatory to be implemented by countries that operate such aircraft.
The European aviation industry and operators are regulated by the European Aviation Safety Agency (EASA) and the Civil Aviation Authority (CAA) is the UK’s specialist aviation regulator, carrying quite a bit of weight in the industry.
Other countries with civil aircraft manufacturing industries have similar regulatory organisations, for example, Canada’s is the Canadian Air Transport Security Authority (CATSA) and Brazil’s is Agência Nacional de Aviação Civil (ANAC), while Australian aviation is overseen by the Civil Aviation Safety Authority (CASA).
Click here for a global list of aviation authorities.
From an engineering perspective, the mandatory requirements enforced by these organisations come in the form of Airworthiness Directives (ADs) with accompanying Service Bulletins (SBs) from the country of manufacture, via the manufacturer. The strength or effectiveness of a certain country’s aviation authority is audited regularly by other countries for performance to the minimum regulatory requirements with respect to airworthiness. The EU, in consultation with EASA, currently holds a list of countries which are not allowed to fly into Europe due to the poor performance of their aviation authorities. Indonesian carriers, for example, are not allowed to fly in European airspace.
In the past the FAA has come under criticism, chiefly from PASS (the Professional Airways Systems Specialists and responsible for independent assessment of the FAA’s performance) for its “continued failure to identify and curtail the uses of bogus parts in our nation’s aircraft”. Michael Fanfalone, President of PASS.
PASS’s criticism was directed towards FAA’s unwieldy and lengthy legal process, taking an average of two years. Undeniably, what the FAA and the other regulatory bodies have to deal with is a highly difficult issue to police. A single aircraft is composed of thousands of parts, each of which has to be registered and recorded, right down to the nuts and bolts. The temptation for less scrupulous operators to make maintenance savings must be considerable. For example, a screw that is fitted to an aircraft may cost USD1 and, on release, this screw is batched or has an FAA form for a Boeing. However, the same screw, almost identical but purchased for industrial applications may only cost 3 cents US.
As a Licensed Aircraft Maintenance Engineer with personal experience of bogus parts, Mark Scott’s professional view of this is that “…if there are unscrupulous individuals out there who are prepared make money from fake medicines and baby formula, just imagine the gain from high cost aircraft parts.”
Links to relevant news stories and reports
The Air Alaska Airlines crash: signs point to a wider crisis in air safety
Many things have happened since the crash that indicate serious problems not only with this particular plane, but with Alaska Airlines in general, and, more broadly, the US airline industry as a whole. What emerges from these revelations is an alarming picture of the state of air safety.
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Plane parts on black market plagues airline industry
“The whole system is contaminated,'' said Peter Friedman, director of quality at an aircraft repair station in Oakland, Calif. "In my position, I find unapproved parts on a daily basis.''
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Unapproved aircraft parts investigation
A short report including a definition of terms, case examples and images of bogus parts from a ‘teardown inspection’.
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Situational awareness, watchfulness is the best defence against bogus parts
Widely publicized a decade ago, the issue of bogus aircraft parts…remains as critical now as ever, even if it is not as visible as before.
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The problem of bogus parts
An airworthiness advisory circular from the Eastern Caribbean Aviation Authority underlining concern about unapproved parts finding their way onto aircraft, particularly helicopters.
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What’s SUP with parts?
How can you ensure that your shop is not accidently using bogus parts? Always use a supply chain that is reputable, be certain that all parts have the appropriate documentation and that the parts remain traceable throughout their existence. Even then, you may encounter a bogus part.
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