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Counterfeit aircraft parts

The implications of installing counterfeit aircraft parts onto aircraft could be life threatening. Sadly, unscrupulous bad actors, motivated by greed, are willing to do unscrupulous things while chasing high-margin dollars. The problem has many elements: Counterfeit parts, like buying a Rolex knockoff watch for pennies on the dollar; forged paperwork (like Form 8130-3); used components purported to be new; Original Equipment Manufacturer (OEM) components installed without Federal Aviation Administration (FAA) paperwork; and used OEM parts returned to the OEM under warranty, but in fact are no longer under warranty. 

The most high-profile accident involving fake parts occurred on Sept. 8, 1989, when Partnair Flight 394 carrying 55 people from Oslo to Hamburg crashed into the sea. Investigators determined that three counterfeit bolts and sleeves where installed, which were incorrectly heat-treated during their manufacturing. The bolts caused the tail section of the Convair CV-580 turboprop to vibrate violently and eventually tear loose, causing the vertical fin and fuselage to separate. The counterfeit bolts and sleeves had excessive wear, causing the tail to vibrate for the previous 16 flights and the accident flight. An outcome of the tragedy was the U.S. introducing reforms in the aviation parts industry and more aggressively pursuing prosecutions leading to over 150 criminal convictions and US$47 million in restitutions and fines.

FAA investigating how titanium parts with falsified records wound up in Boeing and Airbus planes

The aviation industry relies on the honesty and trust of the supply chain participants. However, the adage of Trust but Verify ensures that discrepancies caused by bad actors are caught before the parts or components are installed on an airframe. Since 2010, major OEMs have seen that some bad actors have used rotable parts repair and overhaul facilities to launder suspect parts. OEMs and the FAA have been working together to deal with these challenges both from a regulatory and enforcement perspective. Embargoed countries have forced Russian airlines to find spare parts on the black market or from grounded aircraft.  

Based on analysis of customs records, Reuters reported: “All told, at least US$1.2 billion worth of aircraft parts flowed to Russian airlines from May last year – when most U.S. and European trade curbs and export bans over Ukraine were in force – to the end of June this year (2023).” With OEMs and the FAA cooperating, some supply company’s business licenses have been revoked.

Transport Canada (TC), FAA and European Union Aviation Safety Agency (EASA) are all aware of this problem, with bad actors using different schemes to cheat the system.  The FAA has setup a Suspected Unapproved Parts (SUP) program and website (faa.gov/aircraft/safety/programs/sups), which has been tracking SUP since 1996 and is using FAA Form 8120-11.   

In 2002, TC issued alert AL2002—01, advising all owners, operators, maintenance shops and parts distributors of the possibility of agencies trafficking in unapproved parts. TC had received information from the Italian Civil Aviation Authority, Ente Nazionale per l’Aviazione (ENAC), that Panaviation s.r.l., an unapproved organization based in Rome, has supplied aeronautical parts worldwide, that may have been altered and/or with their history misrepresented. ENAC has advised TC that any part originating with Panaviation should be considered unairworthy. Canadian Aviation Regulations (CARs) require that aeronautical products conform to their design standard, have proper certification, and be in a safe condition for use. 

TC strongly recommends that the Canadian aviation community should inspect their aircraft records, parts receiving records and/or parts inventories to determine if parts originated from Panaviation have been received or installed. TC advises that it has been reported that Panaviation is commercially linked with other unapproved organizations distributing parts from Italy, allegedly New Tech Italia and New Tech Aerospace. If any parts linked to these organizations are found installed on an aircraft, appropriate action should be taken in relation to the safety implications associated to their operation. If these parts are found in existing parts inventories, TC recommends that they be quarantined until a determination can be made regarding their eligibility for installation. TC advises that these parts have been sold by Panaviation to various entities in the United States and Europe.

EASA encourages the reporting of any information concerning discovery of subject parts. EASA was tasked with the establishment of a mandatory reporting system, based upon Article 4(4) of regulation 376/2014 of the European Parliament.  Regulation 2015/1018 requires that “the use of products, components or materials, from unknown, suspect origin, or unserviceable critical components (SUP)” must be reported. 

A reported SUP case may not be resolved by EASA and the National Aviation Authorities mainly due to the lack of required information: a SUP with an allegedly forged EASA Form 1 comes from a non-EU maintenance organization, supplier or distributor and it is difficult to obtain feedback from the local aviation safety authority; the origin of the SUP is impossible to determine; an allegedly forged EASA Form 1 has been sent to a potential buyer of a part (not in the supply chain yet) for pre-assessment, indicating that an SUP case might exist for the concerned part; and a part was unlawfully removed, e.g. from a maintenance facility, and it can be expected that it will appear on the market with forged documentation or untraceable history. 

The goal of SUP information provided by operators and repair stations to EASA’s reporting website is to raise awareness within the European aviation industry of SUPs which they might encounter. In addition to mandatory reporting required under local airworthiness regulations, EASA requests that operators report direct via the ECCAIRS reporting portal (e2.aviationreporting.eu/reporting). 

As an example, EASA has become aware of an unapproved part with a forged FAA Form 8130-3.

An Italian approved maintenance organization received from a supplier a new DUKES Pump Fuel Booster with P/N 4140-00-17 (P/N CESSNA C291504-0101) and the related authorized release certificate FAA Form 8130-3 with Form Tracking Number 1534369 dated 20-Apr-2018. The FAA-approved aircraft manufacturer, that supposedly had issued the authorized release certificate, has confirmed that the FAA Form 8130-3 certificate provided with this part is not an authentic document. 

Bloomberg’s investigative journalists have been reporting on a case starting in the spring of 2023, when engineers at TAP Air Portugal’s maintenance subsidiary found a replaced damper with signs of wear in a CFM56 turbine engine. The paperwork had identified the part as new from Safran SA, the manufacturer of the engine. Safran determined that the paperwork had been forged.  The signature was not of a Safran employee and the purchase order numbers were not in their system. Since October 2023, Safran and General Electric have found more than 90 other certificates that have been falsified, with fake parts found in 126 engines.  

These parts are linked to a London UK distributor, AOG Technics Ltd. While engineers are trained to spot components of dubious origin, “it’s always shocking when we have one in front of our eyes,” a person familiar with the revelation, who asked not to be identified, told Bloomberg, as shared in its report entitled Ghost in the Machine. “In some cases, AOG allegedly sold refurbished used parts with paperwork claiming they were brand-new, potentially netting huge profits in the process. And the company may have done so by exploiting what critics say is a decades-old blind spot in the aviation regulatory system” reported Bloomberg. GE and Safran are litigating AOG in a London UK court. The CFM International engine-making partners have sought a court order for the documents relating to every single sale of products. AOG produced the records on October 4,2023, providing CFM new potential leads. EASA said that it has no regulatory power to investigate AOG as suppliers are not regulated.

EASA has implemented a system to track and report on counterfeit aircraft parts, with accompanying forged documentation. Aircraft owners, operators, maintenance organizations and distributors are requested to inspect their records to determine whether aircraft or engine parts have been obtained from AOG Technics, either directly or indirectly. For each part obtained, contact the approved organization identified on the Authorized Release Certificate or ARC (e.g. FAA  8130-3 or EASA Form 1) to verify the origin of the certificate. If the approved organization attests that the ARC did not originate from their organization, then any affected parts should be quarantined to prevent installation until a determination can be made regarding their eligibility for installation. If a part with a falsified, ARC is already installed, then it is recommended that the part be replaced with an approved part.

The FAA will issue Unapproved Parts Notification circulars (UPN) which can be found at faa.gov/aircraft/safety/programs/sups/upn.  The latest UPN number 2024-AAE-EHL-20230608-303 documents “Articles manufactured and/or distributed by Southern Aero, LLC, for installation on Franklin Aircraft Engines, articles such as cylinder liners, valve springs, piston rings, hardware for cylinders and overhaul gasket kits. Information discovered during an FAA Suspected Unapproved Parts (SUP) investigation revealed that between June 2010 and present, Southern Aero, LLC, produced and sold numerous articles for installation on Franklin Aircraft Engines without the approval and authorization of the FAA and FAA design holder.”  

The FAA UPN further states: “FAA regulations require that type-certificated products conform to their type design. The FAA encourages aircraft owners, operators, manufacturers, maintenance organizations, and parts suppliers and distributors to inspect their aircraft and/or aircraft parts inventory for any articles produced and/or sold by Southern Aero, LLC. If these articles are found in existing inventory or installed in an FAA type-certificated aircraft, the FAA recommends that they be quarantined to prevent installation or use until a determination can be made regarding their eligibility for installation or replaced with FAA-approved articles.”

In a general aviation (GA) context, the problem of using uncertified aircraft parts and components takes on a different complexion.  With some GA aircraft dating back to the 1940s, 50s and 60s, some parts are no longer manufactured and the OEM no longer in business. For owner operators who need a part which is deemed unobtainable, the owner working may choose to use an uncertified part.  John Leggat, Vice President, Leggat Aviation Ltd, reports: “Some owners may choose to purchase undocumented aviation parts from sources like e-Bay or salvage yards.  

“Upon review, the two parts appear to be identical, however, without paperwork, understanding the history of the part (i.e. hours in service, when it was removed and the aircraft it was removed from) will be challenging and the part is not eligible for installation on a certified aircraft,” continued Leggat. “Should the part be installed, the owner bears the responsibility and the Certificate of Airworthiness for the aircraft is not valid. Realistically these aircraft should be moved to the owner-maintenance category, removing the responsibilities of airworthy certification for all.”

In the U.S., shady tree A&Ps have no regulatory obligation to use certified and traceable parts. The FARs 43.13-a and -b describe how an A&P will perform maintenance, alteration or preventative maintenance on an aircraft and does not specify the use of certified aircraft parts. FARs 43.13(c) discusses the obligations of air carriers operating under the provisions Part 121 or 135 and Part 129 operators. Mike Busch, CEO of Savvy Aviation Inc., reports: “A&Ps providing services may choose to only use certified parts to ensure that they are not carrying contingent liability, thereby pushing responsibility for the part to the supplier. An A&P can use an uncertified shop to create or repair a part, under their supervision, but again, the A&P will hold the liability, which is something they are usually not keen about.”

It is challenging to determine just how widespread is the contamination of aircraft with counterfeit parts and documentation. A determination of a counterfeit part may occur during routine maintenance when purported new parts are seen with excessive wear. This requires that the AMEs (or A&Ps) have eagle eyes and have been educated on this issue of counterfeit parts. With millions of parts in a modern jetliner, finding counterfeits is like finding a needle in a haystack. The outcome, however, can be obviously deadly. | W