Transcription

Guidance Material and Best Practicesfor Life-Limited Parts (LLPs)TraceabilityiGuidance Material and Best Practices for Life-Limited Parts (LLPs) TraceabilityEdition 1 – June 2020

Table of ContentsList of Figures . ivList of Tables . vAbbreviations . viBackground . xiScope. xiiiIntroduction . xiv1.Need for Establishing Industry Standard of Trace Paperwork for LLPBTBT . 152.What Activities will Trigger an Entry into the Template . 173.Documentation Required to Establish Life-Limited Part’s (LLPs) Back-to-Birth (BtB) Traceability . 183.1 LLP Supporting Documentation Requirements (Summary) . 204.Guidelines for Dealing with Some Specific Issues . 255.Template (Life-Limited Part Movement History Sheet) to Capture Information and Track LLP throughits Lifecyle . 285.1 Background and Scope of Template . 285.2 Implementation Targets . 295.3 Template (Life-Limited Part Movement History Sheet). 305.3.1 Definitions and Instructions on How to Fill out the Template . 315.3.2 Definitions of Reason-For-Record-Entry Activities. 335.3.3 Some Additional Guidelines to Complete the Template . 355.4 Responsibility for Supporting Documentation of the LLP . 365.5 Responsibility for Record Keeping of the LLP . 366.Regulatory Framework . 387.References . 468.Appendices . 478.1 Appendix 1 – Operational History Record . 488.2 Appendix 2 – EASA Form 1 & FAA Form 8130-3 . 498.3 Appendix 3 – Incident/Accident Clearance Statement . 518.4 Appendix 4 – LLP Back-to-Birth (BtB) Records Trace Template . 53Acknowledgements . 56iiGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

NoticeDISCLAIMER. The information contained in this publication is subject toconstant review in the light of changing government requirements andregulations. No subscriber or other reader should act on the basis of anysuch information without referring to applicable laws and regulationsand/or without taking appropriate professional advice. Although everyeffort has been made to ensure accuracy, the International Air TransportAssociation shall not be held responsible for any loss or damage caused byerrors, omissions, misprints or misinterpretation of the contents hereof.Furthermore, the International Air Transport Association expresslydisclaims any and all liability to any person or entity, whether a purchaserof this publication or not, in respect of anything done or omitted, and theconsequences of anything done or omitted, by any such person or entity inreliance on the contents of this publication. International Air TransportAssociation. All Rights Reserved. No part of this publication may bereproduced, recast, reformatted or transmitted in any form by any means,electronic or mechanical, including photocopying, recording or anyinformation storage and retrieval system, without the prior writtenpermission from:Senior Vice PresidentSafety and Flight OperationsInternational Air Transport Association800 Place VictoriaP.O. Box 113 Montreal, QuebecCANADA H4Z 1M1iiiGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

List of FiguresFigure 1: Document Structure . xivFigure 2: LLP Supporting Documentation Schematic . 20Figure 3: LLP Movement History Template Implementation Targets . 29Figure 4: LLP Movement History Sheet Template. 30Figure 5: AMO & CAMO Record Keeping . 42ivGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

List of TablesTable 1: Glossary of Terms . ixTable 2: Records’ Requirements Summary Related to Life-Limited Parts (LLPs) . 40vGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

AbbreviationsAACAdvisory CircularACMIAircraft, Crew, Maintenance and InsuranceADAirworthiness DirectiveAIRAircraft Inspection ReportALSAirworthiness Limitations SectionAMCAcceptable Means of ComplianceAMMAircraft Maintenance ManualAMOCAlternate Means of ComplianceAMPAircraft Maintenance ProgramAOGAircraft-On-GroundAPUAuxiliary Power UnitARAuthorized RepresentativeARCAirworthiness Review CertificateARLAircraft Readiness LogASLAircraft Serialization ListingATCAir Traffic ControlAWLAirworthiness LimitationBBAABilateral Airworthiness AgreementBtBBack-to-Birth traceabilityCviCAACivil Aviation AuthorityCAMOContinuing Airworthiness Management OrganizationCASSContinuing Analysis and Surveillance SystemCFRCode of Federal RegulationsCICCorrosion Inhibiting CompoundCMMComponent Maintenance ManualCMRCertification Maintenance RequirementCofACertificate of AirworthinessCoRCertificate of RegistrationCPConditions PrecedentCPC(P)Corrosion Prevention and Control (Program)CRSCertificate Release to ServiceCSNCycles Since NewCTCCape Town ConventionGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

DDAHDesign Approval HolderDARDesignated Airworthiness RepresentativeDERDesignated Engineering RepresentativeDOADesign Organization ApprovalDMData MatrixEEADEmergency Airworthiness DirectiveEASAEuropean Aviation Safety AgencyEDSEngine Data SubmittalELTEmergency Locator TransmitterEOEngineering OrderEoDEvents of DefaultEOLEnd of LeaseETAEstimated Time of ArrivalETOPSExtended-Range Twin-Engine OperationsEUEuropean UnionEWISElectrical Wiring Interconnection SystemEMMEngine Maintenance ManualFFAAFederal Aviation AdministrationFCFlight CycleFDIUFlight Data Interface UnitFDRFlight Data RecorderFHFlight HourFMGCFlight Management Guidance ComputerFODForeign Object DamageGGMGuidance MaterialHHILHold Item ListHMVHeavy Maintenance VisitHTHard TimeIATAInternational Air Transport AssociationICAInstructions for Continued AirworthinessICAOInternational Civil Aviation OrganizationICSIncident/Accident Clearance StatementIviiGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

IDERAIrrevocable De-registration and Export Request AuthorizationIILIndustry Item ListILSInstrument Landing SystemIOCInstalled Original ComponentsIPCIllustrated Parts CatalogueLLDNDLast Done / Next DueLLPLife-Limited PartLLPBTBTLife-Limited Part Back-to-Birth TraceLLPMHSLife-Limited Part Movement History Sheet (an Excel Template)LOCLetter of CreditLOILetter of IntentLOPALayout of Passenger AccommodationLRULine-Replaceable UnitMMISMaintenance Information SystemMLGMain Landing GearMPDMaintenance Planning DocumentMRBRMaintenance Review Board ReportMROMaintenance, Repair and Overhaul OrganizationMSG3Maintenance Steering Group-3MODModificationNNAANational Aviation AuthorityNDTNon-Destructive TestingNLGNose Landing GearNPRMNotice of Proposed Rule MakingNRCNon-Routine CardOOC/CMOn Condition/Condition MonitoringODAOrganization Designation AuthorizationOEIOne-Engine-InoperativeOEMOriginal Equipment ManufacturerOMPOperator’s Maintenance ProgramOpSpecsOperations SpecificationsPP/NPart NumberPADProposed Airworthiness DirectivePASVPay At Shop VisitviiiGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

PAYGPay As You GoPBHPower By the HourPMAParts Manufacturer ApprovalPPEPay Per EventRRAPRepair Assessment ProgramRIIRequired Inspection ItemRNAVArea NavigationRVSMReduced Vertical Separation MinimaS/NSerial NumberSBService BulletinSELCALSelective CallingSIInternational System of Units (Système International)SRMStructural Repair ManualSSIDSupplemental Structural Inspection DocumentSSIPSupplemental Structural Inspection ProgramSTCSupplemental Type CertificateSTTCCTime Controlled ComponentsTCDSType Certificate Data SheetTermExplanationTSNTime Since NewUUNIDROITInternational Institute for the Unification of Private LawUSUnited StatesVVHFVery High FrequencyVORVHF Omnidirectional RangeVSLVital Statistics LogWWDMWiring Diagram ManualWFDWidespread Fatigue DamageWOWork OrderTable 1: Glossary of TermsixGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

Notes: In the document the terms ‘Operational History Record’ and ‘In-service History Record’ mean the same andcan be read interchangeably.As the supporting documentation/paperwork for BtB traceability of LLPs is expected to be captured in anelectronic format (in the form of record(s)), as per the guidelines set out in this standard, the terms‘documentation’ and ‘paperwork’ can be read as ‘record(s)’.[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]xGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

BackgroundIn the past few years, the focus on life-limited part (LLP) documentation has increased significantly, due to the factthat more LLPs are exchanged/replaced with used material. Airlines are now facing more and more requirementsfrom the Industry (MROs, Airlines, Lessors/Owners and Part Traders), therefore this is now a topic of discussionbetween the parties.Aircraft documentation is inspected meticulously during the delivery and redelivery process of an aircraft. A criticalaspect of aircraft records is the documentation associated with LLPs and their trace to birth (manufacture). Airlinesare ultimately responsible for the safety of flight and they need to ensure that documentation meets airworthinessstandards. Additionally, such documentation is considered very important by the Industry, including lessors andaircraft owners, because it can have a significant impact on the asset value and marketability of the aircraft or, asapplicable, on the standalone engines or the LLP itself.The commercial value of LLPs is related to their remaining life. This value has created a unique market thatspecializes in trading these parts. Airlines and lessors/owners are the ultimate consumers of these parts, however,for both these parties, trading LLPs is not a core business. Many part traders and brokers have developed withspecialization around trading these parts. Due to lack of industry technical standards, each of the various partiesinvolved in the LLP market, has created a set of its own requirements that many times contradict the basic principleof fairness; i.e. having the same requirements when someone is selling a part and when purchasing a part. Thisguidance attempts to provide a simple standard for trading such parts and their back-to-birth (BtB) traceability.An LLP is a part with a hard limitation. LLPs can be found on aircraft or on engines. At the time the aircraft or enginewas designed, the design approval applicant identified certain parts as having limits, and those limits were approvedby the certifying authority. When the LLP has reached its limit, the part may no longer be used (absent a change, suchas a life-extension program). The limit is normally given in cycles, hours or calendar days. Whilst landing gear (LG)and auxiliary power unit (APU) have LLPs, the majority of LLPs are in engines, which is why this document mainlyfocusses on the engine LLPs. LG and APU LLPs will be covered separately.Aviation regulations typically require an operator to know the current life status of its LLPs. But industry practice hasdeveloped in which merely knowing the current life status of an LLP is considered to be commercially inadequate foran LLP transaction. Most LLP transactions will feature back-to-birth traceability for the LLP (“LLP BtB”). Generally,this means documentation that shows the provenance of the accumulated cycles or time, since the first operationof the LLP.There is a lot of confusion around what exactly constitutes sufficient LLP BtB, and different parties have differentcommercial requirements regarding LLP BtB. This makes it very difficult for airlines to manage their fleet when itcomes to replacement of LLPs and lease redeliveries.This document, which is developed in close coordination with industry stakeholders, covers in detail the keychallenges associated with LLP BtB Trace, as well as provides a methodology/solution to address those challengesin an efficient and effective manner.Finally, it should be noted for simplification, that the regulatory requirements for operators are to keep records ofhours and cycles flown and the remaining life according to the current status of operations. The industry has gonemuch further, requiring supporting documentation to prove these records. This document provides guidance to thexiGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

record keeping and highlights the non-adding value of the ever-increasing documentation requirements – stemmingfrom commercial interests.[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]xiiGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

ScopeIATA’s Guidance Material and Best Practices for LLPs Traceability covers all topics that play a role in back-to-birthtraceability of aircraft life-limited parts (LLPs). The document is primarily written for a technical audience (engineersworking at the airline technical/engineering departments as well as technical representatives from leasingcompanies, parts providers & distributors) that are involved in the handling of LLPs in some manner. Whilst thedocument explores some key challenges facing the industry with regards to capturing data/information andgathering support documentation to enable tracking of LLPs, it provides a methodology for ensuring accuratetraceability of LLPs through their lifecycle, including when such parts are transferred between operators. It tacklessubjects from a broad practical perspective, taking into account technical, regulatory, legal and commercialconsiderations. Additionally, the document can be used by data transfer format standards groups (e.g. ATA ebusiness) and IT professionals, asked to build or link such databases.For the purposes of this document, LLPs are considered parts that have time limited usage restrictions in terms offlight cycles (and rarely flight hours or calendar times). In addition, such LLPs have significant monetary value andcan be traded commercially. In most cases, these LLPs refer to parts being operated on engines, landing gears (LG)and auxiliary power units (APUs). On most occasions, this document refers to engine LLPs. Whilst the wording mayapply to other LLPs, such as LG and APU, this document strives to focus on engine LLPs.The document first captures some key issues and/or challenges with regards to LLPBTBT, followed by a proposedsolution, which is a template for capturing data/information and support documents for accurate tracking of LLPs. Inaddition, to ensure common understanding of various data/information items appearing on the template amongststakeholders, a clear set of definitions along with guidelines on how to complete the template are provided in thisdocument. Note that the template represents a visual depiction of the fields that need to be reported. In a fully digital(electronic or paperless) world, this information should flow between systems. The use of the ATA e-businessstandards is recommended for electronic data transmission between any interested parties.IATA’s Aircraft Leasing Technical Group (ALTG 1) is the owner of this document, which is under continuous review byairlines and IATA Strategic Partners 2 who can provide their input during regular meetings. Other comments are alsowelcome at: iiGuidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

IntroductionGiven the increased emphasis on capturing and maintaining information for back-to-birth (BtB) traceability of LLPs,and the absence of any standard industry templates and guidelines to support the BtB evidence, IATA’s AircraftLeasing Technical Group (ALTG) have developed this document to provide guidance on what information needs tobe captured, the documents where this data can be found, and how it can be recorded on a standard template in aconsistent way. This document not only provides a standard template where the information pertaining to LLPs isexpected to be recorded but also provides a set of accompanying guidelines on how to fill out the template.This document may be used by airlines, lessors, parts’ providers and any other related entities engaged with thehandling and managing of LLPs. The document is laid out in a logical and easy-to-follow manner. It first explores keychallenges facing the industry in the realm of BtB traceability of LLPs. It then looks at the type of documentationneeded to underpin the BtB traceability of LLPs, which is further elaborated by means of a schematic, outlining thesupporting documentation requirements of trace paperwork for LLPs under three distinct scenarios: (1) when a newpart is introduced to the market; (2) when a part moves from one operator to the next; and (3) when the host engineof an LLP undergoes a shop visit. This section is followed by another section detailing the background and scope ofthe template (developed to enable smooth and easy transfer of LLP information between owners/operators); atimeline for its implementation; and guidelines for completing the template.The document presents the topics in the following methodical order.Guidance Material and Best Practices for LifeLimited Parts (LLPs) TraceabilityChapter 1Need for EstablishingIndustry Standard ofTrace Paperwork forLLPBTBTChapter 2What Activities willTrigger an Entry into theTemplateChapter 3DocumentationRequired to EstablishLLPs BtB TraceabilityChapter 3.1LLP Supporting DocumentationSchematicChapter 4Guidelines for Dealingwith Some SpecificIssuesChapter 5Template to CaptureInformation and TrackLLP through its LifecycleChapter 5.1Background & Scope ofTemplateChapter 5.2Implementation Targets(Timeline)Chapter 5.3Template(LLP Movement History Sheet)Chapter 5.4Responsibility for SupportingDocumentation of the LLPChapter 5.5Responsibility for RecordKeeping of the LLPFigure 1: Document StructurexivGuidance Material and Best Practices for Life-Limited Parts (LLPs) TraceabilityChapter 6Regulatory Framework

1. Need for Establishing Industry Standard of TracePaperwork for LLPBTBTLLP BtB trace has become a sensitive subject in aviation asset management and, as a consequence, within the airlinecommunity.This is because it affects a lot of different parties within the aviation industry whose interests do not always align,from airlines to lessors, to OEMs, to parts’ traders, to MROs to CAMOs. The airline’s core business is to fly aircraft in the most cost-effective way. Although an airline’s primaryfocus is to assure passengers a safe flight, the airline’s interest is to reduce its costs. There are several waysto achieve savings. One of them is to reduce parts’ cost to the minimum while keeping the assets inacceptable condition to the owner. Another one is to meet certain engine built workscope requirements withspecific run times lower than the full life of a new LLP. Hence airlines prefer installing used LLPs, providedthey are acceptable to the lessor or to the potential buyer. Considering that the number of leased aircraft isconstantly increasing, airlines have to maintain an accurate system for BtB.The lessor’s core business is to lease the asset in the most cost-effective way. Leased assets may becomplete aircraft and/or engines but lessors may also lease components that include LLPs like landing gearor APUs. The lessor’s interest is to spend as little time and money as possible on transferring the asset andto maximize asset value for later sale. Hence the lessor prefers the use of LLPs that do not present anydocumentation (trace) issue.The OEM’s core business is to manufacture safe products and to sell parts in the aftermarket, which is themarket for spare parts. The OEM’s interest is to ensure their products are safe and in compliance with thedesign regulations, and to maximize sales of new OEM parts. Competition between OEMs to sell new aircrafthas never been so intense. Consequently, OEM revenues derived from new products have decreasedsignificantly. At the same time, used parts are now commonly used by airlines and part out companies haveflooded the secondary market. Because of these market conditions, the OEMs have been critical of theaftermarket as a matter to counteract their loss of revenues.The parts traders’ core business is to buy used assets at the lowest possible price and sell the piece partsat the highest possible price. Hence their interest is to negotiate a low buying price of used assets (normallypurchased from airlines or lessors) while keeping the sales price as high as possible.The MROs’ business is acting on behalf of their customers (mainly airlines and lessors) to ensure that LLPsmeet their requirements. In certain cases where MROs provide “power by the hour” type agreements, MROsmay have their own commercial interest.The CAMOs’ (Part M) business (and equivalent or other EASA following regulatory systems) is to act onbehalf of its customers when it comes to managing the airworthiness of the aircraft; LLPs are an integral partof managing this activity.While respective regulatory authorities have required airworthiness standards for record keeping in relation to lifelimited parts, the industry standard has moved way beyond the requirements of the airworthiness regulations.Owners of LLPs have to comply with the changing industry standard in order to ensure the commercial liquidity ofsuch parts that have useful life remaining when removed from a host engine. This industry standard originallyfocused on measures to verify the stated TSN/CSN of a part with backup documentation and requirements toconfirm that such part has not been excluded from continued operation due to incident and/or accident.15Guidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

These earlier measures adopted by the industry to maintain part liquidity had their basis in events that related tocalculation errors or dubious provenance of parts. However, in recent years additional requirements have beenadopted with increasing regularity, many of these appear to have no obvious logic or root justification for theirintroduction, but once adopted they quickly become the new baseline for all market participants who becomereluctant to accept anything less than this because it may decrease liquidity or value in a very competitive market.The result has been a decrease in remarketability of parts in the aftermarket, primarily because the paperworkrequired for the additional technical requirements cannot be obtained retrospectively.In order to enable the traceability of LLP and to support the back-to-birth evidence, the followingdocumentation/paperwork is required and should be reviewed and assessed for completeness and accuracy: birthdocuments; operator documents; and shop visit documents. All these are explained in the succeeding chapters,along with the type of information expected to be captured in each of these documents.[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]16Guidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

2. What Activities will Trigger an Entry into theTemplateWe envision that the LLP traceability will be tracked using what we call the “LLP Traceability Template”. This templateis an electronic file (can be called a digital twin) that follows the part throughout its life. Each operator/owner isresponsible to keep up with the various activities occurring on the LLP during its operational life, under the specifictimeframe that the part was under their custody. This template can be depicted as an Excel spreadsheet (shown insection 5.3); however, other systems can create a similar file. The first LLP records in the electronic file are insertedby either the part manufacturer or the airframe manufacturer that signs off the delivery of it to the first operator.Then, it becomes the operator’s responsibility to continue adding to the file as activities happen to the part. Whenthe part moves to a different operator, it is signed off and the new operator is responsible to continue capturing theactivities from the time the part enters its own operation.The following activities will trigger an entry into the template:1. Production2. Installation3. Removal4. Change of operator5. Change in operational parametersAll these represent cases that have to be supported with proper documentation. The definitions of the items, as wellas the list of supporting documentation needed for each item are covered in detail in section 5.3.2.[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]17Guidance Material and Best Practices for Life-Limited Parts (LLPs) Traceability

3. Documentation Required to Establish Life-LimitedPart’s (LLPs) Back-to-Birth (BtB) Traceability1. Birth DocumentsThese documents relate to paperwork or electronic records provided at the manufacturer of the LLP and what isprovided depends on how the part is first introduced to the market, for example on a new aircraft, a new engine, anew module or as a new spare part. While it is normal for individual certification to be provided for LLPs delivered asnew spare parts, many of these parts have been manufactured for the OEM by subcontractors and have beendelivered to the OEM in batches and therefore do not have individual certification tags. Therefore, other deliverydocumentation from the OEM is considered as acceptable provided it specifically identifies the part (part numberand serial number) and includes confirmation that the part has been delivered in new (and therefore TSN/CSN Zero)condition.In many cases, LLPs or their host engines may not have an identified customer at the time of manufacture, thereforethe identification of the owner/operator on the Engine Data Submittal/Vital Statistics Log (or equivalent) is not amandatory requirement as it will not always be noted on the documents issued.2. Operator DocumentsThese documents are required for each operator of the LLP extracted from the records of its host engine(s). Thesedocuments should also include LLPs that can be replaced during other maintenance operations. All documentsprovided by an operator should include all thrust ratings operated by each LLP and the operator’s logo or some othermeans of

Dec 31, 2020