CAVU Café: Royboy’s Prose & Cons
By Roy Resto
It’s time once again to dive into the murky world of undefined terms with my professor’s hat properly donned. By undefined I mean the that the term is not clearly ensconced in regulations or standards.
AS REMOVED:
With the rise in popularity of aircraft and engines being disassembled to harvest parts for a supply-chain starved market, the use of the term ‘As Removed’ has come into effect, and this is really the genesis of the term. The moment the part is removed from its next higher assembly, its condition is deemed As Removed or AR.
AR Infers that the part is being represented as an unserviceable part whose airworthiness must be reestablished before it can be installed on an aircraft. Discussion:
- The term also infers that it is known what the next higher assembly is from which it was removed. Ask the seller of such parts to provide trace to its next higher assembly it was removed from. This is because you should:
- Beware that some sellers who have trace issues or gaps in trace or condition, and who should be selling such parts in As-Is condition (see below), have instead taken to using the more palatable term As Removed.
- If purchasing As-Removed parts, consider placing a clause or Term and Condition in the PO which binds the seller to guarantee the part to be repairable. This provides a means for your company to recover its cost of the purchase in case a repair station says the part is BER.
- Interestingly, the term ‘Repairable’, meaning the part is able to be repaired, has fallen into disuse due to the rise of the term AR. In theory, every AR part is Repairable, and every Repairable part is AR.
- By the way, on your documents I see a few of you using ‘RP’ or ‘REP’. This is potentially ambiguous since it can mean either ‘Repaired’ or ‘Repairable’. Consider spelling out the entire word to remove any possible confusion.
- FYI: In very few cases, a disassembler who is a Repair Station or AMO, may have it in their manual to issue an Airworthiness Certificate for the removed part stated to be in ‘Inspected’ condition.
AS IS:
Implies the part is being sold in whatever condition or state it’s in. In the aviation industry this usually means there are trace and/or documentation issues and/or condition issues. Note that it is not contrary to any regulations to buy or sell parts in As-Is condition as long as the known circumstances are clearly represented. The installer has ultimate responsibility to determine the part’s airworthiness and suitability for installation. As stated in the As Removed paragraph, the term As Is appears to have fallen into disuse in favor of the more palatable AR term. If so, Royboy thinks this is unfortunate since in some cases it appears the seller is trying to cloak something…there, I said it and I meant it!
SERVICEABLE:
The term has come to have two meanings:
- The broadest, widest recognition of the term means that the part is airworthy and ready for installation. In this sense every New, Overhauled, Repaired, Inspected, or Modified part is strictly serviceable.
- In the aftermarket however, some persons in sales and purchasing have come to narrow its use (Serviceable) to cover only Repaired, Inspected, or Modified conditions. The most visible manifestation of this practice is on ATA Spec 106 forms. For example, if an EASA Form 1 states its condition is Repaired, the ATA Spec would state its status is SV, for serviceable. Note that while this technically does not violate anything, it is not a best practice. For harmony of documentation, the ATA Spec 106 should perfectly match the corresponding Airworthiness document.
FACTORY NEW:
This term does not have any regulatory definition. Its de-facto use in the industry, however, implies that the part was recently obtained directly from the OEM. Discussion:
- If parts were indeed obtained directly from the OEM, but some have remained in stock unsold for 7 years is the part still FN? Lack of guidance on this could lead to disagreements on the use of the term. A rule of thumb is to ask whether the part is still covered by the OEM’s warranty, if not, consider the part New, but not FN.
Some of this comes from a document I make available for sale titled “Trace And Airworthiness Training Manual” (a shameless plug).
Over ‘n out
Roy Resto