Scenario: You are a distributor, and you have an MMR (Multi Mode Receiver) in your Quarantine Cage because the MRO- Maintenance Repair & Overhaul shop returned the part to you as BER- Beyond Economical Repair due to an unrepairable power supply. There is a customer who is looking for a cover whose part number is the cover for the MMR in the Q Cage. You simply remove the 10 screws to disassemble the cover from the MMR assembly, and voila, you have an AR- As Removed condition part and you’re a hero to your customer because this part was not to be found on the market.
Certainly, this is a simple example, but the concepts we’ll go over in this article can be applied to this small assembly (the MMR) or to major assemblies such as Landing Gears, APUs, and Air Cycle Machines. This brings to mind many details we’ll cover in this article including the following:
Background USM Do I need to be Certificated by an AA- Aviation Authority? AFRA intro
Forms and procedures to considerProcedures in your manual Tags andDo I need a certificated Technician to perform the disassembly? Who can issue an ‘Inspected’ 8130-3 or equivalent for removed parts during a disassembly of an aircraft? Removal log Capping, bagging, packaging Trace considerations/representations Records Royboy’s Parting Counsel BACKGROUND:
USM or Used Serviceable Material is increasingly popular as an alternative to factory new parts whose prices have soared, and lead times extended. Besides those well-known supply chain issues there are in some cases a challenged aftermarket environment due to certain OEM behaviors as explained in this blog article:
https://www.aviationsuppliers.org/AIRLINE-MX-COSTS-WILL-GO-UP
An increasingly popular source of USM parts is from aircraft and engines which have been disassembled.
Before we go any further, we need to point out that the ‘S’ in USM means Serviceable (Inspected, Tested, Repaired, Overhauled). Nearly all parts disassembled from a NHA- Next Higher Assembly are at that moment in AR- As Removed condition. That AR part will have to be sent to a Repair Station/AMO- Approved Maintenance Organisation which will reestablish the part’s airworthiness before it can be installed on an aircraft. I only mention this because the USM moniker is bandied about for a broad range of parts in the aftermarket including these AR unserviceable parts, so its ok to continue to use USM if this is kept in mind.
Do I need to be Certificated by an AA- Aviation Authority? As long as you are not declaring any of the disassembled parts as airworthy, then the answer is no. This is neatly articulated in Jason Dickstein’s blog article:
https://aviationsuppliers.wpcomstaging.com/2014/08/28/no-aircraft-disassembly-is-not-a-maintenance-activity-under-the-faa-regulations/
AFRA Intro . For firms whose core business is disassembly of entire aircraft, engines, or any subcomponents, there is likely an affiliation with AFRA, Aircraft Fleet Recycling Association.
https://afraassociation.org/
AFRA has established disassembly and recycling standards whereby compliant firms can be accredited for Disassembly, Demolition, and Recycling; see the Directory tab at the noted website. With a certainty this article is not suggesting that any of your limited disassembly activates as a distributor be accredited by AFRA, but you should be made aware of their standards and activities in case you want to step up your game. It is interesting to note the synergies between the ASA and AFRA which are quite natural considering the overlapping activities of each other’s members. For example, many AFRA accredited firms are ASA-100 and vice versa. You’ll also notice that the ASA and AFRA annual conferences have been held concurrently now for many years.
FORMS AND PROCEDURES TO CONSIDER.
Procedures in your manual . The ASA-100 paragraph 1.A.1) states:
The quality system, including procedures and operations, shall be described in detail in a quality manual, or other appropriate documents. If you’re selling parts from your disassembly operation under your accredited name and enjoying the business benefits of your ASA-100 accreditation therein, then there is the expectation that your Quality Manual will describe your disassembly operations (exception: you are also AFRA accredited and disassembly procedures are described in the AFRA manual). Consider some of the items presented here for inclusion. Consider placing this in your manual:
A description of what you’re doing. Blank samples of the Tags or Logs in the forms section of your manual, and in your procedure describe their use. A description of any technical data you may be using and whether you have access to Manufacturer’s online data or use of For-Reference-Only manuals. Tags : Perhaps one of the most important documents to implement which facilitates the sale of the part and establishes the trace trail (more on that later), is the use of the Removal or Identification Tag. Here is a blank sample and a filled-in example:
Currently, use of such a tag is dominant in the industry and is sometimes supplemented by, or replaced by a Manifest of removed parts, but the current best practice is the simple tag. It should be affixed immediately upon removal. This is just a sample, and variations of it are common.
Do I need a certificated Technician to perform the disassembly ? There are certainly advantages to using a Certificated Aircraft Technician to perform your disassembly operations. Generally, they are familiar with Technical Manuals, tools, and proper handling of aircraft parts. Some firms also feel that having a Technician exercise their credential on the removal tag, for example “A&P Joe Smith” is added value or adds credibility to the process. To be certain, however, this is not required. Royboy’s recommendation is then to use someone with attention-to-details, and who is mechanically inclined.
Who can issue an ‘Inspected’ 8130-3 or equivalent for removed parts from a disassembly of an aircraft? If you are a Repair Station or Approved Maintenance Organisation, and you have a written procedure in your manual to do so, you’re the one who can issue an Inspected tag (8130-3 or equivalent). I have written procedures accepted for this process, and these should always have a document number, for example WI-1501. Here’s a quick summary of the logic. An aircraft arrives at your hangar for disassembly. For it to have flown there it must have been Airworthy, and the Airworthy Certificate carried on board. Except for any open write-ups in the logbook, you can reasonably assume that the aircraft (and its parts and components) are airworthy. If there are any open write-ups, they will be found in the logbook with its ATA chapter noted. Let’s say you want to start to remove all the radios. You look in the logbook and there are no ATA Chapter 23 write-ups. Next you go to the AMM- Aircraft Maintenance Manual and find in chapter 23 where it typically requires a visual inspection of the system during operational checks or troubleshooting. You perform the visual check and find nothing untoward. You remove the radio, cap it, and the resulting 8130-3 says Inspected as its condition. I highly recommend that the remarks block transparently and plainly state the circumstances involved, for example, “Removed from MSN 12345”. Of course, the remarks must also contain a reference to the AMM and cite your written procedure. For example, “Visually Inspected per AMM 23-15-44 paragraph 23-14, and (Company Name) Procedure WI-1501.”
Regarding this process, some customers will accept such parts, and some won’t What!
https://www.aviationsuppliers.org/Cannibalizing-Robbing-and-Swapping-Aircraft-Parts
The following is a simple and generalized flowchart regarding tagging options for a disassembly I have presented in the past at conferences. Apologies if it seems small for the posting.
Removal Log . If you have a complete assembly of any kind and you start to harvest parts from it, Royboy highly recommends that you have a method to track the parts removed from this Next Higher Assembly. Why? The reason is that if for any reason you are now presented with a PO (Purchase Order) for the entire assembly, you’ll have to restore or provide the parts removed in order to sell it as a complete assembly. If you have a Removal Log entry for every part that was removed, you now have a simple listing to facilitate the process. The Removal Log would always stay with assembly.
I distinctly recall my airline days whereby we had spare engines at a few major bases, and those engines were always tempting targets to harvest parts which were not in stock. The written procedure included posting a Removal Log so anyone would instantly know what parts were missing and on order.
Tooling, Capping, Bagging, Packaging . In addition to a wide assortment of tools it is recommended that you also have a wide assortment of caps and plugs for electrical, pneumatic, fuel, oil, and hydraulic connections upon disassembly. This must include a reasonable assortment of ESD caps and bags for such parts. Depending on the size and type of part being disassembled, consider hoists, drip pans (for parts with oil, fuel, or hydraulic fluids which will leak), or stands made for major assemblies such as engines and APUs, see below.
Trace Considerations/representations . If you have heard me speak or read many of my articles, you’ll have taken notice of my repeated use of the word ‘transparency’, and so it is with parts that have been disassembled from a NHA. Our customers continue to require clear and transparent trace as stated on their T&Cs- Terms and Conditions on their Purchase Orders. For the example given for the MMR cover, providing the removal tag (or copy) is important. Next is what is the trace for the MMR? Unless you’re selling the part in AR condition, then of course your documentation package would include the Airworthiness Release Certificate from whomever you used to perform the Overhaul, Repair, or Inspected/Tested.
Records: As with any activity occurring in your distributorship, and as required by the ASA-100 and nearly all Quality Standards and Aviation Regulations, keep precise records which are reasonably accessible upon request.
Royboy’s Parting Counsel :
Don’t let your disassembly area turn into a junk yard! Keep it neat and tidy which is a positive reflection of your operation. Say what you do and do what you say. Put it in your manual. Just because you have AR parts does not give one license to treat aircraft parts any different than you would Serviceable parts; properly cap, protect, and tag the parts. This too is a positive reflection of your operation. This article was written without the use of any AI apps or programs.
Over ‘n out
Roy ‘Royboy’ Resto
www.AimSolutionsConsulting.com
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