Traceability – Defined
Traceability: What does it mean?
“The Parts Traceability Puzzle” is an article written up in Aviation Maintenance Magazine (Aviation Maintenance / avm-mag.com / April 2013) by Jason Dickstein, an attorney with the Washington Aviation Group, PC (http://www.washingtonaviation.com/).
(Link to article: The Parts Treceability Puzzle by Attorney Jason Dickstein)
In the article, the author points out a little-known fact in our industry about the FAA’s requirements for aircraft parts traceability: there are none! That’s right, the FAA has NO general requirements about parts traceability, and as Dickstein points out, although there are requirements for maintenance records, requirements for delivering a completed aircraft, and requirements for installers regarding what parts can and cannot be installed on an aircraft, “there is no requirement under U.S. law that ANY document follow the aircraft parts from one owner to the next.”
(Link to FAA letter confirming that there is no Federal Aviation regulation that requires traceability of an aircraft part to its origin: here)
On occasion we have a client that will tell us that we have provided “insufficient traceability” for a part that was purchased, and that “back to birth” traceability is required, or some other “requirement” that they’ve picked up over the years and adopted as “law.” The truth is no such traceability mandate exists; even for life-limited parts, Federal courts have upheld that “current life status” is the only required proof.
It is because of the misinformation and confusion surrounding Traceability that we have created this page on our site. It is our hope that, by describing our Quality standards, our clients and potential clients will have all of the information they need to make a purchasing decision.
One industry-accepted standard that defines traceability is FAA AC 00-56A (Voluntary Industry Distributor Accreditation Program), and many parts distributors use this standard as the basis of their Quality Management System. It is important to note that this, too, is only a guidance document, not an FAA mandate. In this document, traceability is defined as the “ability to track parts, processes, and materials to the original manufacturer or other acceptable source to meet the requirements of the installer…” (emphasis added).
The bottom line is that the installer of an aircraft part, not the seller or anyone along the supply chain, has the obligation to make a determination of airworthiness under Part 43 of the Federal Aviation Regulations. Because of this, the installer’s requirements drive whether or not the part is acceptable for installation. The truth is that, in the aviation industry, companies that operate, maintain and/or repair aircraft have their own standards and guidance documents that regulate their operations, and the FAA holds them accountable to maintain those standards. Since we cannot be expected to know every client’s requirements, we can only commit ourselves to providing traceability information and copies of any and all documentation, upon request, before a purchase is made.
In summary, we at Zenith Aviation are committed to selling only the highest quality parts at the best possible pricing, but we make no assumption that the part we have for sale complies with the various different requirements for each of our thousands of clients! Likewise, our potential clients should not make these assumptions, either, but should make sure the part we are selling meets (or exceeds) their specific requirements and expectations. We are happy to provide full disclosure about our parts, but we count on our clients to ask the necessary questions about traceability and part conditions specific to their requirements BEFORE THE SALE.
DISCLAIMER & EXPLANATION
Zenith Aviation is a purchaser of bulk surplus parts (parts that are purchased from companies that close their doors or airlines and corporate operators that retire an aircraft), and as such sometimes the only trace document we can provide is from the company from where we purchased the parts. In the case of bulk purchases, Zenith Aviation’s Quality system excludes a requirement to trace further than the seller, although many times that company does have copies of trace attached to the part. When further trace is available, we provide those documents to our clients. This said, parts listed for sale by Zenith Aviation have no guarantee at the time of listing, expressed or implied, that trace documentation beyond from where we purchased the part exists. It is the sole responsibility of the BUYER to insure the part they are considering for purchase meets their specific quality and traceability requirements.