March 26, 2025

Steven Bentley

Sofema Aviation Services (SAS) reviews the current FAA Suspected Unapproved Parts (SUP) Program and considers key features.

Introduction

The FAA Suspected Unapproved Parts (SUP) Program Office, initiated in November 1995, continues to be a critical initiative for maintaining safety and integrity within the aviation industry.

  • The program aims to proactively identify, address, and remove unapproved parts from the aviation system to ensure airworthiness and operational safety.

The FAA SUP Program remains vital in maintaining the safety and integrity of the aviation system. Enhanced technology, global collaboration, and a focus on supply chain management are critical to addressing emerging SUP threats. Organizations must strengthen their internal processes, adopt best practices, and foster a culture of reporting to mitigate SUP risks effectively.

Updated Developments – Enhanced Technology for Identification and Reporting

  • The FAA has implemented digital tools and databases for Suspected Unapproved Parts (SUP) Reporting System to streamline reporting, tracking, and investigations.

Global Collaboration

  • International cooperation has strengthened under agreements with EASA, Transport Canada, and ICAO, fostering cross-border data sharing and enforcement.
  • Joint investigations and initiatives aim to address global SUP issues as parts often circulate internationally.

Improved Regulatory Policies

    • FAA Advisory Circulars (e.g., AC 21-29D) provide more clarity on approved parts classifications, requirements for certification, and the consequences of violating regulations.

Focus on Supply Chain Oversight

  • Growing reliance on outsourced manufacturing has made supply chain oversight a priority. The FAA is emphasizing the role of Part 145 repair stations and Part 21 manufacturers in preventing SUP infiltration.

Industry Programs and Self-Regulation

  • Programs like Voluntary Industry SUP Disclosure have encouraged repair stations and operators to self-identify unapproved parts before being flagged by enforcement agencies.

Key Challenges – Complex Global Supply Chains

  • The aviation industry’s global nature complicates the traceability of parts. Parts may originate from various suppliers across multiple regions, increasing the risk of counterfeit or unapproved parts.

Rise in Counterfeit Parts

  • Technological advancements in 3D printing and materials manufacturing have made it easier to produce counterfeit parts, which may look identical but lack proper airworthiness approvals.

Inadequate Reporting and Awareness

  • Despite mandatory reporting requirements under 14 CFR Part 21, some organizations still fail to report SUP incidents, either due to ignorance of the process or fear of repercussions.

Limited Resources for Investigations

  • Resource constraints in terms of manpower and funding can slow investigations into suspected unapproved parts, particularly in cases requiring complex technical verification.

Gray Market Challenges

  • The used parts market and unauthorized distributors pose a significant risk. Without proper documentation, even repaired or salvaged parts can enter the system as unapproved.

Supply Change SUP Best Practices

Strengthened Supplier Vetting Processes

  • Conduct comprehensive supplier audits and ensure adherence to FAA/EASA-approved quality management systems (e.g., ISO 9001, AS9100).

Training and Awareness Programs

  • Implement mandatory training for aviation maintenance personnel to recognize and report SUP.

Robust Documentation Practices

  • Require Certification of all parts entering the system (Know your supplier program)
  • Verify all suspect documentation with official FAA or EASA databases.

Use of SUP Alerts and Databases

  • Subscribe to FAA Unapproved Parts Notices and monitor alerts for any suspected or  identified unapproved parts.
  • Regularly cross-check supplier-provided data with FAA Aircraft Certification Systems and OEM-approved vendor lists.

Encourage Reporting without Fear of Retaliation

  • Promote a “just culture” within organizations where reporting suspected unapproved parts is encouraged without fear of punitive actions.

Supply Chain Best Practices

  • Strengthened Supplier Vetting: Conduct rigorous audits and ensure suppliers comply with FAA/EASA-approved QMS standards (ISO 9001, AS9100).
  • Mandate Training for all Stakeholders : Educate personnel to recognize and report SUP incidents.
  • Documentation Practices: Implement certification verification (FAA/EASA databases) and “Know Your Supplier” programs.
  • SUP Alerts: Monitor FAA SUP Notices and use official databases to validate supplier claims.
  • Just Culture: Promote open reporting without fear of retaliation.

Next Steps

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EASA, ICAO, Part 145, FAA, Part 21, SAS blogs, 14 CFR part 21, Unapproved Parts (SUP), Updated Developments, Global Collaboration, FAA Advisory Circulars, SUP Best Practices, Alerts and Databases, Encourage Reporting, QMS standards (ISO 9001, AS9100)