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Background
Whilst it is common practice for owners of aircraft parts to dispose of scrap parts and materials by selling, discarding, or transferring such items. Using unapproved parts, uncertified parts or incorrectly maintained parts is potentially life-threatening, unfortunately, certain unscrupulous persons will engage in these practices. Parts which should be permanently removed from the supply chain have in some instances, reappeared for sale in the active parts inventories of the aviation community.
Persons disposing of scrap aircraft parts and materials should ensure appropriate actions and to consider the possibility of such parts and materials being misrepresented and sold as serviceable later.
Disposal of scrap aircraft parts and materials
Disposed scrap parts and materials may, in some instances, reappear for sale in the serviceable parts inventories within the aviation community.
Such misrepresentation of the status of parts and material and the practice of making these items appear serviceable could result in the use of non-conforming parts and material. The owner’s/operator’s permission should be sought prior to the disposal of scrap parts and materials.
Caution should, therefore, be exercised to ensure that the following types of parts and materials are disposed of in a controlled manner that does not allow them to be returned to service:
(a) parts with non-repairable defects;
(b) parts that are outside the specifications set by the approved design and cannot be brought into conformance with the applicable specifications;
(c) parts and materials where further processing or rework cannot make them eligible for certification;
(d) parts subjected to rework or unacceptable modification that is irreversible;
(e) life-limited parts that have reached or exceeded their life limits or have missing or incomplete records
(f) principal Structural Elements removed from a high-cycle aircraft for which conformity cannot be accomplished by complying with the mandatory requirements applicable to ageing aircraft.
Persons disposing of scrap parts and material should, when appropriate, mutilate those parts and materials prior to disposal. Mutilation should be such that the parts and materials become unusable for their original intended use. It should also not be possible for them to be reworked or camouflaged to provide the appearance of being serviceable for example by re-plating, shortening and re-threading long bolts, welding, straightening, machining, cleaning, polishing or repainting.
Mutilation
Mutilation may be accomplished by one or a combination of the following procedures, but not limited to:
(a) grinding;
(b) burning;
(c) removal of a major lug or other integral feature;
(d) permanent distortion of parts;
(e) cutting a hole with cutting torch or saw;
(f) melting;
(g) sawing into many small pieces.
The following are examples of mutilation that are often less successful since they may not be consistently effective:
(a) stamping (such as a stamped ‘R’ on the part);
(b) spraying with paint;
(c) hammer marks;
(d) identification by tag or markings;
(e) drilling small holes;
(f) sawing in two pieces since it may be possible to attempt to restore parts cut in two pieces in such a manner that the mutilation proves difficult to detect.
For the disposal of scrap aircraft parts and materials for legitimate non-flight uses, such as training and education, research and development, or non-aviation applications mutilation is not appropriate and the following methods should be used to prevent misrepresentation:
(a) permanently marking or stamping the parts, subparts and material as ‘NOT SERVICEABLE’. Ink stamping is not an acceptable method;
(b) removing original part number identification;
(c) removing the data plate;
(d) maintaining a tracking system, by serial number or other individualised data, to record transferred scrap aircraft parts and material, and
(e) include written instructions concerning disposition and disposal of such parts and materials in any agreement or contract transferring the parts and materials.
Next Steps
Sofema Aviation Services www.sassofia.com and Sofema Online www.sofemaonline.com provide regulatory training compliant with EASA, FAA & OTAR requirements. For details please email [email protected] or [email protected]
