The quest for quality components is sometimes difficult and, for sure, unending, as Aircraft maintenance often involves sourcing parts that are either hard to find (due to contingencies, like high demand or high raw materials prices) or no longer in production.
In such cases, aviation professionals can turn to New Surplus (NS) parts, a term that carries a unique set of quality challenges and considerations. In this blog post, we'll delve into the complexity of NS aviation parts and the certifications that accompany them, with a focus on the ATA Spec. 106 Part or Material Certification Form.
Additionally, we'll shed light on the distinctions between FAA and EASA regulations regarding the airworthiness of these parts.
New Surplus parts refer to components that are unused, have never been installed, and are typically in their original packaging. These parts may be remnants of an aircraft production run, discontinued models, or simply excess inventory. While these parts can be a lifesaver for maintenance teams dealing with aging aircraft, ensuring their airworthiness is a critical aspect.
New Surplus parts are produced on conformity, with approved data, and released as stock surplus by the Government Agencies, Operators, or even the OEM (Original Equipment Manufacturer) itself and sold then by a third-party Company.
NS parts are New, so will carry no operating time or cycles; the original Owner had the potential to install these parts, so some may also name this special parts category as New-Unused.
NS parts are sometimes provided with an OEM Certificate of Conformity (CofC), when available; most of the time, NS parts are sold with a reseller CofC, or an ATA Spec. 106 Part or Material Certification Form.
This is not intended that the ATA Spec. 106 should be filled out just for NS parts; rather, it is a valuable tool for ensuring traceability of a component in whatever condition it is.
What exactly is the ATA Spec. 106 Part or Material Certification Form?
It is still called “ATA” for ease of identification, even if the ATA (Air Transport Association of America) is now A4A (Airlines for America); it is not only a form, but a Spec., a 50-pages set of instructions, definitions and documentation of which 8 are dedicated only to the issue of the final ATA Spec. 106 Part or Material Certification Form.
With its first release in the early 90’s, this Form consists of a commercial document giving true information about traceability and adding another important element in its Remarks section, which has born together with the Form: the famous NIS or Non-Incident Statement, required to identify parts which might (or might not) have been obtained from Government agencies (non-military) or non-FAA certificated aircrafts or again Aircrafts or engines subjected to extreme stress or heat, major failure, accident, or fire.
But again, a question arise: can I accept a New Surplus part, and therefore install it on my Aircraft during maintenance operations?
To answer this question, it is essential to carefully consider the regulatory landscape, especially in the context of airworthiness. The Federal Aviation Administration (FAA) and the European Union Aviation Safety Agency (EASA) are two major authorities governing aviation in the United States and Europe, respectively.
In the FAA world, the airworthiness of such parts is evaluated by the installer, like a Part 145 or a Part 121 for example; one important requirement is a trace to the OEM, like the OEM CofC or, at least, the original package with an OEM label showing P/N, S/N (when applicable), Cure Date (when applicable), Lot or Batch, Manufacturing date, name and Cage Code of the OEM. This is mandatory to exclude Suspected Unapproved Parts / Bogus Parts.
In the EASA world, a label or original package with above information may not be sufficient, as the OEM CofC is the minimum requirement in terms of traceability for expendable parts.
We have already discussed the topic related to Supplier Evaluation by a Part 145 in this article here.
The role of New Surplus parts in aircraft maintenance will become increasingly significant. The careful evaluation of certifications, such as the ATA Spec. 106 Part or Material Certification Form, is essential in guaranteeing the traceability of these components; additionally, a better understanding of the intricacies of FAA and EASA regulations further ensures that aviation professionals can confidently integrate new surplus parts into their maintenance practices while maintaining the highest standards of Quality, Safety and Reliability.
About Horix Aerospace
Horix Aerospace is an horizontally integrated aerospace company, strongly focused in Spare Parts Management solutions for the Business Aircraft Market. Horix has developed both the Trust Consignment Program and the Trust Dismantling Program to offer clients a unique opportunity becoming the Swiss Trusted Solution for Aerospace Components Management. With over $30M in assets under management, Horix Aerospace has become a disruptive force in the Aerospace Industry with both its Trust Dismantling Program and unique Business Model.
Strongly capitalized and managed by a team of industry veterans, Horix Aerospace is proud to be a Swiss owned and operated company.