The History of SUPs (Suspected Unapproved Parts)
by Salvatore Scalone
Article reprinted with permission of FAA Aviation News
On November 15, 1995, the Suspected Unapproved Parts (SUP) Program Office (AVR-20) opened for business as a result of recommendations made by a special task force earlier that year. This office is responsible for promoting a cohesive, consistent, aggressive approach to SUP and has been extremely successful in identifying unapproved parts and removing them from the aviation system.
After the program was established, AVR-20 immediately started a nationwide aviation safety inspector and law enforcement agent training program to explain the details of this new SUP program from initial notification to final case closure. This training also includes the investigative process and is now a permanent curriculum at the FAA Academy in Oklahoma City. Only an approved part would meet the airworthiness requirements of the Federal Aviation Regulations and provide the confidence necessary to assure the integrity of a system and operational safety. Aviation safety inspectors would consider this a basic part of understanding the concept of airworthiness, therefore an unapproved part would not meet regulatory requirements.
The SUP program extends beyond the FAA and into a very active and diverse aviation community. Conversations with parts suppliers, distributors, owners/operators, and legal enforcement authorities revealed (and often still reveal) that there are many people who do not understand the importance of installing only approved aircraft parts. To combat this, seminars with the aviation community were (and still are) being held. As a result of the increase of public awareness of SUP, there has been a significant increase in SUP notifications and investigations.
Adding strength to FAA's SUP efforts is the strong support of other government agencies. A Letter of Agreement-which was signed by FAA, Department of Transportation's Office of the Inspector General (DOT/OIG), FBI, Defense Criminal Investigation Service (DCIS), and U.S. Customs-provides for an exchange of information relevant to SUP investigations. The primary objective of the agreement is to promote the highest level of safety in the U.S. aviation system by facilitating the investigation and processing of SUP reports. These legal enforcement authorities have become an effective partner in the battle to stop unapproved aircraft parts and those individuals who profit from their manufacture and/or sale.
An aircraft is considered safe when it is in airworthy condition. Airworthiness means the aircraft conforms to its type certificate and is in condition for safe operation. Risk is increased when an aircraft part cannot perform its design function. Unapproved aircraft parts may not consistently perform their intended function. When an aircraft part does not conform to its approved design (consistent with the drawings, specifications, and other data that are part of the type certificate, supplemental type certificate, or field approved alterations), it is uncertain how the part will perform when installed. An installed unapproved part increases risk, reduces safety, and could introduce an unexpected threat to an operating aircraft.
If this sounds a little confusing, think of the mechanic who installs a brake master cylinder on your car. If the master cylinder is an approved part (properly designed and manufactured) and was properly installed, you would have reasonable assurance that it will consistently perform its intended function. Your vehicle will stop each and every time you want it to stop. The installation of an unapproved master cylinder increases risk, reduces safety, and could introduce an unexpected threat to the safe operation of the vehicle.
Because of the inherent danger of unapproved aircraft parts, they must be kept out of the system and off the aircraft. The SUP program has demonstrated the most effective approach to dealing with SUP parts. The entire industry must continuously be proactive in identifying and removing them. Additionally, we must stop those individuals who attempt to profit from the intentional manufacture and/or sale of unapproved parts. Their priorities are not safety first.
Anyone can report a Suspected Unapproved Part. AVR-20 is the focal point and notification can be as simple as a telephone call. The FAA Aviation Safety Hotline may be called at 1-800-255-1111 to report any conditions affecting aviation safety, which includes SUP reports. In addition to the Safety Hotline, any FAA office can take SUP information and forward it to AVR-20 or an individual can call AVR-20 directly to make notification. Dedicated AVR-20 specialists review each SUP notification, which often results in an official SUP investigation. The identity of the individual reporting a SUP can be kept confidential. You only need to ask.
FAA Form 8120-11, Suspected Unapproved Parts Notification, includes instructions for completion and identifies the information needed to initiate a SUP investigation. This form is commonly referred to as "The Most Important Form in the SUP Process." This is because it contains the information on the part or material that the people in the field have found to be in a questionable state. It must be noted that the information transmitted on this form will assist the Technical Specialist at AVR-20 to determine what the reporter has found. If the information is incomplete, it may result in the loss of an investigation allowing the parts or materials to saturate the industry until all the information is reported. The form is included in Advisory Circular 21-29B and can also be found at FAA Offices or on the SUP Program website :
Completed forms should be sent to the SUP Program Office at:
FAA, SUP Program Office, AVR-20
45005 Aviation Drive, Suite 214
Dulles, VA 20166-7541
Phone: (703) 661-0580
FAX: (703) 661-0113
Salvatore Scalone is the SUP Coordinator for FAA's Eastern Region. Article reprinted with permission of FAA Aviation News.