Maintenance and Manufacturing Staff Instructions (MSI) No. 50

From: Transport Canada

Subject: Number: MSI 50
Instruction for Follow-Up activity regarding Suspected Unapproved Part Report Revision No: 1
  Number of Pages: 9
File No: AARP-5009-3-50 Issue Date: 22 July, 2004

1. Purpose

1.1 The purpose of this instruction is to clarify the procedures applicable to all Maintenance and Manufacturing personnel involved in co-ordinating, follow-up and processing of suspected unapproved part report. It further outlines the roles and responsibilities of: Aircraft Certification, Continuing Airworthiness Division; Maintenance and Manufacturing, Standards and Procedures Division HQ; and Aircraft Maintenance & Manufacturing Regions. 

2. Background

2.1 Suspected Unapproved Parts (SUP) are reported through the Service Difficulty Reporting (SDR) system. The SDR Program is monitored and maintained by Aircraft Certification, Continuing Airworthiness Division in Headquarters. The issue of Suspected Unapproved Parts is a maintenance or manufacturing concern. Therefore, Maintenance & Manufacturing (M & M) HQ have been identified as the Office of Technical Interest (OTI) and the coordinator for SUP cases in Canada.

2.2 The following definitions apply to this Staff Instruction:

Suspected Unapproved Part (SUP): "unapproved part" - Any part, component or material that has not been manufactured in accordance with the approval procedures in Chapter 561 of the Airworthiness Manual, or repaired in accordance with CAR 571, or their foreign equivalences, that may not conform to an approved type design, or may not conform to an established industry specification for standard parts.

Note: Examples of unapproved parts include, but are not limited to: 

  • "Counterfeit", or fraudulently marked parts, components, or materials;
  • Parts shipped directly to users by a manufacturer, supplier, or distributor who does not hold, or operate under the authority of a manufacturer approval for the part (e.g. production overruns); or
  • Parts that have been maintained or repaired and returned to service by persons or facilities not authorized under CAR 571 or CAR 573.

Note: Example of what is not considered an unapproved part for the purposes of Suspected Unapproved Part (SUP) reporting: 

  • Parts that have been maintained or repaired and returned to service by persons or facilities which are authorized under CAR 571 and CAR 573, but have been subjected to sub-standard maintenance, i.e. incorrect or missing process etc. Although considered an un-airworthy part, these parts should not be reported as SUP's. These parts should be treated, as un-airworthy and appropriate action taken.

Report: the initial SDR and all supporting information or investigation and actions to completion;

Source: the person or organization where the part(s) were obtained. There may be several sources in a chain of supply;

Origin: the Source where part(s) were certified. There should only be one and it is the focus of follow-up activities;

OPI: for the purpose of this MSI, Office of Primary Interest will be coordinated by M&M HQ (AARPE), this changes as the source is followed up the chain of supply to the origin, but will be the Region or Foreign Civil Aviation Authority (FCAA), if outside of Canada, responsible for the source;

Corrective Action: any action taken to correct a situation with an origin or source. This may vary from, simple removal of part from service to certificate and/or enforcement actions;

Enforcement Action: action taken on the part of the Enforcement Division. This is at least establishing a file number, when the investigation is handed over, but may vary from counseling, fines, and/or Canadian Aviation Document suspension.

3. Related Publications

3.1 Canadian Aviation Regulations (CARs), Part 591; Airworthiness Manual (AWM) chapter 591;

3.2 Aircraft Certification Staff Instruction number 44 (ACSI # 44).

3.3 http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/CAWIS-SWIMN/logon-wsdrs-cs16101.asp?Lang=E (Web Service Difficulty Reporting System)

3.4 M&M's SUP OPI has full access to all SUP SDR's-all Regional M&M CASI have access to update a SUP SDR.

4. Objectives

4.1 To prevent further usage of unapproved parts by identifying the origin of the parts, correcting the cause, and removing any identified unapproved parts from the system.

4.2 To enable Civil Aviation Safety Inspectors (CASI) to perform appropriate follow-up action regarding SUP reports.

4.3 To provide co-ordination of efforts with the circulation of appropriate information for CASI use.

5. Policy

5.1 RESPONSIBILITIES

  1. The industry and Civil Aviation Safety Inspectors M&M are responsible for reporting SUP's as SDR's in accordance with CAR's 591, AWM 591, and ACSI #44. SUP SDR's submitted are identified through the use of a "U1" code in block 7(b) of the SDR Form # 24-0038 by the submitter, and the electronic form in WSDRS.
      
  2. The Continuing Airworthiness Division (CAW) receives and tracks all SDRs. All SDR's identifying SUP require action and are assigned as a "special investigation" - as per ACSI #44 and forwarded to M&M HQ. Should M&M HQ require notification to the industry of unapproved parts, then the appropriate method will be determined by Continuing Airworthiness Division with respect to M&M HQ recommendations and could include publishing a Feedback Article, Service Difficulty Alert/Advisory, Airworthiness Notice, or Airworthiness Directive.
       
  3. M&M HQ coordinates the follow-up activity as per Appendix A attached to this MSI. This may include: forwarding information to appropriate Regions using a request for follow-up; determining if notification of the industry is required; Originating files, such as a sub file (i.e.-AARD5009-22-####), for the cases that warrant an individual file and placing of work packages for smaller follow-up activity on the AARD5009-22 general file; When the source of a SUP is outside of Canada it is the responsibility of M&M HQ to forward the detailed report and supporting investigating material to the appropriate Foreign Civil Aviation Authority (FCAA). M&M HQ will ensure follow-up action is completed, and inform CAW of all closures, the reason for closure, through Web Service Difficulty Reporting System (http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/CAWIS-SWIMN/logon-wsdrs-cs16101.asp?Lang=E), and where warranted provide recommendations to CAW to issue a notice to the aviation public. File closure will occur as a result of either: corrective action being confirmed; the transmittal to a FCAA; initiation of enforcement action; or a lack of further information being available. When requested by M&M HQ, Regional Aircraft Maintenance & Manufacturing is responsible to carry out follow-up activities on all SUP's in their region, documenting their findings and actions taken in regard to the finding; initiating Regional Enforcement action where warranted to bring about compliance and corrective action; and advising M&M HQ of the outcome. Should the source be identified as a foreign Civil Aviation Authority (FCAA) responsibility, the information must be sent to M&M HQ for reporting to the appropriate FCAA. A copy of the gathered information may be kept on regional files with the originals being sent to M&M HQ for forwarding/ filing and case closure.
      
    Refer to the appendices for flow charts giving a quick reference for the procedures to be carried out.

5.2 FORMS AND REPORTS

  1. Refer to the appendices. The sample forms are for convenience purposes. Instructions may vary somewhat depending on the situation and there is no requirement to use the report form when other reporting methods are preferred as long as the following information is covered in the report with supporting information attached:
      
    (i) Submitter contact information (name, address and phone number); (ii) Source or Origin, as applicable of part (name, address and phone number); (iii) File number; (iv) Maintenance & Manufacturing CASI assigned to case; (v) Date assigned; (vi) Date and signature for closing the case; (vii) Action taken in relation to findings; (viii) Disposition of parts in question; (ix) Indication of final result or location of Sources outside Region; (x) Recommendation by the Maintenance & Manufacturing CASI.

6. Appendices

7. Effective date

7.1 This instruction comes into effect immediately

8. HQ Contact

8.1 The responsible officer indicated below may be contacted for information regarding this MSI:

Ganesh Pandey, AARPE 
Aircraft Maintenance & Manufacturing
E-mail: pandeyg@tc.gc.ca
Phone: (613) 952-4424
Facsimile: (613) 952-3298

D.B. Sherritt
Director,
Maintenance and Manufacturing

Appendix A - Headquarters Procedures

 

Abbreviation:

CAW = Continuing Airworthiness Division
M&M = Maintenance & Manufacturing
SDR = Service Difficulty Report
SUP = Suspected Unapproved Parts
HQ = Headquarters

Appendix A - Headquarters Procedures

  1. Suspected unapproved part is discovered. This could be by an operator, AMO, manufacturer, AME, or by a Civil Aviation Safety Inspector.
  2. A service difficulty report is completed and submitted in accordance with Airworthiness Manual 591.
  3. Continuing Airworthiness Division receives the service difficulty report. A control number is assigned when the SDR is entered into the SDR database by the submitter or HQ.
  4. If in paper format a copy is directed to the regional office for distribution.
  5. A Continuing Airworthiness Division inspector reviews the service difficulty report for completeness and any need for further corrective action.
  6. Makes a decision on whether it is a suspected unapproved part or if there is an immediate threat to aviation safety.
  7. If it is decided, at step 6, that it is not a suspected unapproved part, then Continuing Airworthiness Division carries out actions according to Aircraft Certification Staff Instruction number 44.
  8. After all actions are completed regarding follow-up and/or investigation, the information resides in the service difficulty database. http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/CAWIS-SWIMN/logon-wsdrs-cs16101.asp?Lang=E
  9. Continuing Airworthiness Division monitors and evaluates the information within the database of service difficulty information.
  10. If it is decided, at step 6, that the SDR is identifying a suspected unapproved part, then Continuing Airworthiness Division will direct a copy of the report electronically via wsdrs, with any supporting information to M&M HQ (AARPE) for coordination of the follow-up activities.
  11. The M&M HQ (AARPE) SUP OPI will review electronic record Web Service Difficulty Report (WSDR) and the SDR status will be changed to "R" as reviewed. Result of any investigation will be inserted into the supplemental text block as required, and by selecting any or all of the radio button, the following will receive email notification if selected: Notify PMI, Notify Submitter, Forwarded to TCH(Type Certificate Holder). This must be done IAW AARDE procedures RDIMS#40742, personal & company references must be removed from text, text is available to public.
  12. At this point the appropriate Region or FCAA will be identified from the supporting information.
  13. If the SUP's SDR is identified as a domestic issue or information is required from a domestic site, then the M&M HQ (AARPE) will create a request for information and forward it to the appropriate Regional Manager.

(steps 14 thru 26 form part of the regional procedures contained in Apppendix B)

27. After the region has gathered all of the information associated with the case, that is - within its area of responsibility, a report with the supporting information will be sent back to M&M HQ (AARPE).

28. The SDR database (http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/CAWIS-SWIMN/logon-wsdrs-cs16101.asp?Lang=E) will be updated and the package of information added to the correct file.

29. The case will be reviewed to determine whether more investigation is required.

30. The SUP's SDR information package will be reviewed for the need to involve other FCAA.

31. If other FCAA are involved the M&M HQ (AARPE) will send a report with supporting documentation to the FCAA.

32. After the SUP's SDR information package has been completed or transferred to a FCAA, M&M HQ (AARPE) will report back to Continuing Airworthiness on the final results; make recommendations regarding any required notification of the industry; and update the database WSDRS (# 28).

Appendix B - Regional Procedures

 

Appendix B - Regional Procedures

13. The Regional Manager Maintenance and Manufacturing receives a request for information regarding a SUP SDR case.

14. The Regional Manager ensures the SUP is tracked as required and assigns to a TCC. The TCC Superintendent assigns to an M&M CASI for the appropriate company.

15. The first issue is to identify whether the part is an immediate threat. That is, is it in service?

16. If the part is in service, then it needs to be determined that appropriate corrective action for the part has taken place. If appropriate corrective action, that is, inspections and certification as required, has not taken place then the M&M CASI is obligated to take or direct action in this regard (e.g. part(s) removal, quarantine etc.).

17. At this point there should not be a concern of immediate safety regarding the parts in question and the issue is a matter of follow-up to ensure there are no other possibilities of problems elsewhere.

18. The M&M CASI will have to establish that there are records for the parts in question.

19. A review of the records will have to be carried out to determine the how, when, why, who, what, and where of the part certification and history.

20. If it is determined that there are no records in step 18, or the part was not properly certified in step 22, then the M&M CASI will not be able to establish any information regarding the part itself.

21. Should the investigation lead to a certificate holder, then the appropriate CASI will have to deal with the individual or organization itself on how the part was used in the first place. This will require some form of corrective action for the organization to be determined by the CASI.

22. In reviewing the records in step 19, it must be determined whether the part has proper certification.

23. After determining that a certification was issued for the part(s), the Source of the part must be identified.

24. At this point the follow-up may return to step 18, or referred back to M & M Headquarters with the new Source. This process may continue to cycle until the Origin can be located to determine how certification was obtained.

25. After tracing the part back to the Origin, a determination must be made as to how the certification was made in the first place. Essentially we will either have a legitimate error being made or intent to deceive.

26. Any intent to deceive will have to be dealt with through the Enforcement Division and the gathered evidence would be forwarded to the Enforcement Division with a detection notice.

27. All information and documentation gathered, including any enforcement reference and case number, will be sent back to M&M HQ, for appropriate updating and actions.

Appendix C - Sample text for follow-up request

Service Difficulty Report (SDR) number ****, was reported to Continuing Airworthiness as a Suspected Unapproved Part (SUP). As the Office of Technical Interest (OTI) for Suspected Unapproved Parts, M &M HQ is responsible for tracking the progress of this report.

The company submitting the SDR is **** which was identified through NACIS as being the responsibility of the **** TCC. The SDR should have been already forwarded to your office and follow-up action may have already taken place. Therefore, I am forwarding the form on this memo as a request for a report on the CASI's follow-up. Further instructions are available in MSI 50. A copy of the SDR is attached and also can be reviewed on the SDR website at v
  
Please have the appropriate CASI complete the report and forward it with any supporting information to this office. After we are informed, we will carry out appropriate updates and any actions required from headquarters.
  
In order to close this file a response would be appreciated within 30 working days from the date of this memo. If this time is insufficient, please contact this office with an acceptable time frame.

Appendix D - Sample reporting Form

Suspected Unapproved Part Request for Follow-up Report

SDR Number:   Submitted by:  
Date Assigned:   CASI:  

(Attach supporting documents)

Step Task Circle One
1 Is the part in service? Yes / No
If Yes, what action was taken?
 
2 Is the part available? Yes / No
If Yes, what action was taken?
 
3 Are the records available? Yes / No
If No, what action was taken?
 
4 Is there a certification? Yes / No
If No, what action was taken?
 
5 Is the source of the part outside your Region's responsibility? Yes / No
If Yes, then indicate the name address and phone number of the source and the appropriate Region or Foreign Authority.
 
If No, what action was taken?
 
6 How did the part become certified? __By Error __By Intent __Other __Unknown
If by intent, what is the enforcement case reference ______________________________?
If by Error, what action was taken?
 
If Other, explain:
 
7 NOTES:

Inspector Signature

Date

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