Are you familiar with Spec 106? It is a specification written by the air carrier community that details how suppliers should handle and document aircraft parts. One of the problems with this specification is that it has not been updated in over 15 years.
Many people in the aviation industry are familiar with the Spec 106 Form. This form is an appendix to the specification and is used throughout the aviation industry to provide commercial documentation to parts. It is often known as the ‘Parts and Material Certification.’ But fewer people in the industry realize that the form is just an appendix to an industry standard.
A friend wrote to me with a Spec 106 question. It is a question that I have heard before. At its root, the question is, “What does block 13C on the ATA Spec 106 form (“Last Certificated Agency”) mean and whose name do we put into that block?”
In the case that was presented to me, a distributor was planning on purchasing aircraft parts from a non-US air carrier. The carrier in question is a foreign regional carrier (FRC) with no Part 129 certification from the FAA (it does not fly to the United States). The distributor was wondering whether the FRC could be Last Certified Agency of Block 13C of their ATA-106? The answer to that question depends on whether the FRC has performed a maintenance activity on the part.
The Spec 106 instructions for block 13C very simply say:
“Name the last certificated agency and its certificate number who last performed maintenance on the part.”
This simple explanation is often ignored by parties who have not read the instructions. As a consequence, one can see Parts and Material Certifications completed with a wide variety of information in this block.
The block 13C instruction sentence likely anticipated FAA-certificated agencies, because it was written over 20 years ago by U.S. air carrier representatives. But that limitation is not specified in the instructions, so the block can include any certificated party bearing a certificate from any airworthiness authority.
Something that is specified in the instructions is that suppliers of surplus parts that have been inspected shall include a document from a FAA 121, 135, 129 or 145 certificate holder indicating condition. This would be in addition to the Spec 106 form. This is not a regulatory requirement, but it is a requirement of the specification in section 3-7, and it shows us what was considered appropriate when the specification was developed.
Back to our fact pattern; the distributor indicated that the FRC employs certified inspectors. These inspectors perform inspection at the time of receipt (receiving inspection) and issue documentation stating that the part is considered airworthy. Inspection is typically considered a maintenance activity that must be reflected in an approval for return to service or other maintenance release. Typically receiving inspections are not considered to be maintenance activities in their own right, but are part of the maintenance organization’s activities. But if receiving inspection is treated as a separate maintenance activity in this FRC, and receiving inspection is documented as such, then this activity coul dbe a maintenance activity performed by a certificated agency.
So now we have to look at what kind of parts are being transacted in this case.
If the parts are new parts that are surplus to the FRC’s needs, then the inspectors could inspect them to new condition, issue appropriate approval for return to service verifying that the parts have been inspected to new condition, and then the Spec 106 form could list the FRC as the last certified agency in block 13C. This may be subject to the same section 3-7 caveat mentioned above if the parts are received by a company with a Spec-106 compliance receiving inspection system.
The idea of issuing an air carrier approval for return to service is not a new one. Northwest Airlines used to issue 8130-3 tags for their surplus parts indicating that the parts had been inspected to verify the condition in which they were sold. For new surplus parts, this meant that their new, unused, status has been confirmed. An FRC could use whatever maintenance release form they typically use (such as the ANAC SEGVOO-003, CAAC AAC-038, EASA Form One, TCCA Form One, etc.) in order to document the inspection. They should be careful to describe what inspection was performed in the remarks block of the maintenance release form.
But what if we are talking about parts in ‘as removed’ condition? In such a case, the FRC could still be the last certificated agency if it performed an activity like an inspection. For example, a post-removal inspection that verifies that the part is unairworthy could be a maintenance activity. In this case the activity would be the inspection, and the unserviceable tag could be the record of the work performed (to meet this requirement, it typically needs to state what work was performed, e.g. the inspection).
Just because the part is not serviceable does not negate the fact that an inspection was performed and documented. But of course, the FRC must have appropriate maintenance capabilities to perform the inspection in question – if they do not (e.g. because all of their maintenance work is performed by contractors) then their ‘inspection’ might represent unauthorized maintenance – in such a case the maintenance contractor might be the appropriate party to perform and document the inspection in question. In that situation, the maintenance contractor may be the last certificated party.
Opportunity for Improvement
One of the issues with the Spec 106 form is that the instruction set is not very well suited to non-US operations (it was written by the US air carrier community in the 1990s). In today’s industry, global operations and global sources of supply have become the norm.
The Aviation Suppliers Association (ASA) has been working on proposed revisions to Spec 106. ASA is working with both A4A and IATA on this project.
If you have any interest in participating in this process, then please let ASA know; we are currently working on this project, and plan to have our proposals ready quite soon.