Opinion: Unapproved Aircraft Parts May Be More Of A Problem Than You Realize

As a pilot, I never really thought twice about where the parts on my aircraft came from. Perhaps I should have.

Eighteen months ago, an eagle-eyed technician at TAP Air Portugal spotted an aircraft engine part that appeared to be used—not the new part that the airline had ordered. He contacted the engine manufacturer, where it was determined that the paperwork was falsified. Further investigation led to an aircraft parts distributor in London that allegedly had sold thousands of aircraft parts, including turbine blades, with falsified documentation. The majority of these unauthorized parts involved engines manufactured by CFM International, a joint venture between GE Aerospace and Safran. The company, AOG Technics, advertised itself on its website as being a “leading global aircraft support provider” and referenced its global network of warehouses. Faced with an untenable situation, airlines across the world were forced to ground airplanes to verify those unapproved parts were not on their engines.

While the number of engines affected was ultimately determined to be relatively small, this situation, once again, demonstrated vulnerabilities in the aviation supply chain. Unapproved parts come in different flavors—they could be stolen, counterfeit or parts being represented as new when they are, in fact, used. Whatever they are, anytime you are dealing with unapproved parts on an aircraft, you are increasing the safety risk factor.

Given that this AOG Technics situation most severely affected CFM International engines, early last year GE Aerospace formed the Aviation Supply Chain Integrity Coalition. Former U.S. Transportation Department Deputy Secretary Hon. John D. Porcari and I were named as coalition co-chairs, which included industry partners Airbus, American Airlines, Boeing, Delta Air Lines, GE Aerospace, Safran, StandardAero and United Airlines. For the next nine months, the coalition interviewed subject matter experts to discuss challenges and to seek solutions. In October the coalition released its report containing 13 recommendations. Although the coalition’s recommendations were focused on the aviation propulsion supply chain, many, if not all of them, can be applied to the overall aviation/aerospace supply chain.

The threat of unapproved parts goes back decades. In 1957, the Flight Safety Foundation published a paper that warned of safety issues associated with unapproved parts. In 1989, a chartered Convair 580 crashed off the coast of Denmark, killing 55 people. Tom Haueter was NTSB’s accredited representative to that crash, and later head of all of NTSB’s aviation investigations. He told me that crash was the first commercial aircraft accident with significant loss of life that was due, in part, to suspected unapproved parts.

In the early to mid-1990s, the U.S. Transport Department’s inspector general’s office ramped up investigations into unapproved parts, which resulted in 160 criminal convictions. Between then and 2000, investigations by multiple federal agencies, including the FBI and U.S. Customs, resulted in approximately 500 criminal indictments for the manufacturer, distribution or installation of unapproved parts. Between 2012-17, FAA closed 118 reports and investigations of suspected unapproved parts, resulting in 63 indictments and 51 convictions.

Two Florida residents pleaded guilty in 2023 and were sentenced to 12-30 months in federal prison for conspiring to sell aircraft parts with counterfeit airworthiness approval tags. Their scheme involved obtaining “as removed” parts and falsifying documentation to wrongly show the parts had been overhauled, tested or inspected, and found to be airworthy.

To help improve integrity of the aviation supply chain, the GE Aerospace-backed coalition’s recommendations spread across three categories: strengthening vendor accreditation, document traceability and verification, and improving non-serialized parts traceability. Each category has actions that can be implemented over the short term, medium term and long term. The coalition stopped short of calling for regulatory action. Adoption of the recommendations is voluntary, and they are intended to supplement efforts by regulatory authorities.

For vendor accreditation, one short-term recommendation is that air carriers, MROs and OEMs use only suppliers (vendors) that have been accredited through the FAA’s Voluntary Industry Distributor Accreditation Program or EASA’s Quality Management System (OMS) Standards. In the U.S., for example, there are two organizations that FAA recognizes as accrediting bodies, Aviation Supplier Association and SAE Industry Technologies Consortia. EASA has similar accrediting organizations. These accrediting bodies periodically audit parts suppliers to ensure quality standards are met and that vendors have rigorous training programs. “Utilizing accredited distributors will help ensure that vendors supplying the aviation industry are held to the highest standard when providing parts critical to the safety of our skies,” the coalition’s report stated. The coalition also recommended the establishment of a feedback channel to those accreditors so that when a bad actor is suspected, this information can be shared with a wider community.

Document traceability and verification is a key element for validating the provenance of aircraft parts. Known as an Authorized Release Certificate (ARC), the FAA 8130.3 form and the EASA Form 1 are used to certify the parts conformance or airworthiness. Whenever aircraft parts are presented for trade, that part is accompanied by an ARC. However, as seen in the AOG Technics case, with the current paper-based system that is predominately used, there is potential for fraud and counterfeiting. Therefore, the coalition recommended that all industry stakeholders adopt digital ARCs that include use of encryption algorithms and digital signatures. “By digitizing these documents and employing robust authentication tools, the industry can better secure the integrity of its supply chain and streamline compliance and documentation processes, ultimately enhancing overall effectiveness and safety standards,” the coalition’s report said.

In the category of recommendations pertaining to non-serialized parts traceability, longer-term recommendations center around use of technological solutions such as digital twins and blockchain. Digital twins are virtual replicas of real objects, created by combining data, machine learning and software. They allow for real-time tracking throughout their lifecycle, from manufacturer to shipping, installation and decommissioning. Blockchain technology forms a digital ledger of an object and captures transactional data, maintenance records, ARCs and other crucial data.

There will always be criminal enterprises that try to defeat the system and make a quick buck. These recommendations, along with eagle-eyed parts receivers like the one at TAP Air Portugal, will make it more difficult for bad actors to distribute unauthorized parts. For those bad actors, there is a special place in hell—and hopefully in prison—for those who distribute unapproved aircraft parts. 

Robert L. Sumwalt is executive director for the Boeing Center for Aviation and Aerospace Safety at Embry-Riddle Aeronautical University. He was a member of the NTSB from 2006-21, where he served as chairman from 2017-21. Before that, he managed a corporate flight department for a Fortune 500 company, and previously was an airline pilot for 24 years. He recently co-authored the third edition of Safety Management Systems in Aviation, with Alan Stolzer and John Goglia.