Last year, our Fearless Leader Sherry Chaput was asked to contribute to the IATA committee responsible for producing a Best Practices document for aircraft documentation.
This is important because the safety and financial well-being of airlines and other operators depends on the ability to trace the history of any life limited part.
The regulations and guidance, as well as requirements among various entities, has become confusing and frustrating for people interested in ensuring the compliance of their equipment and documentation.
IATA Aircraft Leasing Technical Group (ALTG)
Guidance Material and Best Practices for Life Limited Parts (LLPs) Traceablility
Excerpt from the document
In the past few years, the focus on life-limited part (LLP) documentation has increased significantly, due to the fact that more LLPs are exchanged/replaced with used material. Airlines are now facing more and more requirements from the Industry (MROs, Airlines, Lessors/Owners and Part Traders), therefore this is now a topic of discussion between the parties.
Aircraft documentation is inspected meticulously during the delivery and redelivery process of an aircraft. A critical aspect of aircraft records is the documentation associated with LLPs and their trace to birth (manufacture). Airlines are ultimately responsible for the safety of flight and they need to ensure that documentation meets airworthiness standards. Additionally, such documentation is considered very important by the Industry, including lessors and aircraft owners, because it can have a significant impact on the asset value and marketability of the aircraft or, as applicable, 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 that specializes 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 with specialization around trading these parts. Due to lack of industry technical standards, each of the various parties involved in the LLP market, has created a set of its own requirements that many times contradict the basic principle of fairness; i.e. having the same requirements when someone is selling a part and when purchasing a part. This guidance 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 engine was designed, the design approval applicant identified certain parts as having limits, and those limits were approved by the certifying authority. When the LLP has reached its limit, the part may no longer be used (absent a change, such as 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 mainly focusses 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 has developed in which merely knowing the current life status of an LLP is considered to be commercially inadequate for an 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 operation of the LLP.
There is a lot of confusion around what exactly constitutes sufficient LLP BtB, and different parties have different commercial requirements regarding LLP BtB. This makes it very difficult for airlines to manage their fleet when it comes to replacement of LLPs and lease redeliveries.
This document, which is developed in close coordination with industry stakeholders, covers in detail the key challenges associated with LLP BtB Trace, as well as provides a methodology/solution to address those challenges in an efficient and effective manner.
Finally, it should be noted for simplification, that the regulatory requirements for operators are to keep records of hours and cycles flown and the remaining life according to the current status of operations. The industry has gone much further, requiring supporting documentation to prove these records. This document provides guidance to the record keeping and highlights the non-adding value of the ever-increasing documentation requirements – stemming from commercial interests.