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Aircraft Parts, FAA, News, Policy, Unapproved Parts

New FAA Guidance on SUPs Processing

The FAA has published new guidance on how to process reports of Suspected Unapproved Parts (SUPs). FAA Notice 8120.16, “Processing Reports of Suspected Unapproved Parts,” was published July 15th.

The reason this revised guidance is necessary is because the SUPs office (AVS-20) was closed over a year ago, but there still remains considerable confusion about how the SUPs process is supposed to function under the post-AVS-20 protocols. The notice clariifes for the field offices the way that the SUPs investigation system is now supposed to function.

The Notice explains how to open and conduct a SUPs investigation. It includes the important guidance “Do not attempt to seize parts or require parts to be surrendered.” This guidance has been breached in the past by FAA employees who were apparently unaware of the fourth amendment’s requirements associated with search and seizure. Adherence to this guidance, though, helps to make sure that parts under investigation that might turn out to be “approved parts” do not become “unapproved parts” by virtue of having been removed from a quality system before they are eligible for appropriate approval.

In the past, relations with law enforcement had been ably managed by AVS-20. But now that AVS-20 has been closed, better guidance for field offices on interaction with law enforcement was necessary. That guidance is provided in this Notice.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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