Criticality - American Society for Quality

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Criticality - American Society for Quality

Critical Safety Items (CSIs)

Jeffrey Allan

NAVAIR 4.1E

301-342-2246

Jeffrey.allan@navy.mil


Terminology

Approved

Source

Approved

Part

Critical

Characteristic

Prime

Part

Tracked

Part

Flight Safety

Part

Fatigue

Sensitive

Part

Critical Item

Code

Safety

Critical Item

Life Limited

Part

Critical Item

Procurement

Requirement

Document

Tested

Part

Qualified

Suppliers

List

Flight Critical

Part

Fracture

Critical

Traceable

Qualification

Frozen

Part

Qualified

Parts

List

Fracture

Critical

Item

Qualified

Manufacturers

List

Category I

Part

Critical

Application

Item

Flight Safety

Critical Aircraft

Part

Qualified

Item

Critical Safety

Item

Mission

Critical

Part

Durability

Critical

Part

Flight

Essential

Part

2


C-2 Nose Landing Gear Wheel Assembly Nut

FLAGWORD/NAVY BLUE/-//

TIMELOC/240935Z OCT 05/N2850.3 E04953.6/INITIAL//

GENTEXT/INCIDENT IDENTIFICATION AND DETAILS/C-

A/162158/VRC-40 DET 1/OPERATING FROM NTR ON A CARRIER

LOGISTICS MISSION. C2 AICRAFT SIDE 44 HAD A CATASTROPHIC

PORT NOSE WHEEL FAILURE, WHEEL EXPLODED AND SHRAPNAL

IMPACTED A VAW-124 SAILOR, INJURING BOTH LEGS. COMPOUND

FRACTURE TO LEFT LEG AND FRACTURE OF RIGHT LEG. SAILOR

MEDAVAC TO KUWAIT FOR TREATMENT. NEXT OF KIN HAVE BEEN

NOTIFIED.//

Mr. Allen,

…. I wanted to ensure that you were aware of the

recent incident of a bolt/nut failure that led to a

serious injury. Are these bolts/nuts Aviation

Critical Safety Items? Investigation has just

started. See the below email trail for details. Let

me know if I can assist.

MSGID/GENADMIN/USS THEODORE ROOSEVELT//

SUBJ/C-2 NOSE LANDING GEAR WHEEL ASSEMBLY MISHAP//

POC/HALEY/CO/CVN 71/-/TEL:757-443-6555//

RMKS/1. APPROXIMATELY 40 MINUTES AFTER TECHNICIANS

CHANGED NOSE LANDING GEAR TIRES ON VRC-40 AIRCRAFT 44,

THE PORT SPLIT RIM WHEEL ASSEMBLY EXPLODED, SEVERELY

INJURING A VAW-124 MAINTENANCE TECHNICIAN.

INVESTIGATORS DISCOVERED THAT THE THREADS ON ALL EIGHT

NUTS HAD FAILED. ALL RFI NUTS WERE PULLED FROM THE

AIMD TIRE AND WHEEL SHOP AND SUPPLY OFFICERS STOCK.

INVESTIGATION HAS REVEALED THAT FEDLOG CROSSES NSN

9Z5310-00-982-4908 TO MULTIPLE PART NUMBERS. THE PART

OF THE FAILED ITEM IS GR-714-624. THE AIMD TIRE AND

WHEELSHOP HAS BEEN USING A COMBINATION OF NUTS WITH …

CAPTs,

…., possible Class A due to severe injury to VAW-124

technician who was standing by as a "prop safety/daisy

chain observer"....may need to have his foot

amputated. Mishap occurred around 0930Z (0230L).....

SAFETY ALERT SA-05-FW-0009

25 October, 2005

1. NSN: 5310-00-982-4908

2. Nomenclature: Nut, Selflocking,

Hexagon

3. Manufacturer: Greer Stop Nut

CAGE: 27687 Part Number : GR-

714-624

4. DLA Contract Number.

DLA500-86-C-2701

5. Critical Item Code. Y

6. Navy nominated item Critical

Application in 1982

7. There are 118 weapon systems

identified to this NSN, which

crosses over …

3


C-2 Nose Landing Gear Wheel Assembly Nut

4


5

Aviation Critical Items

Aviation NSNs

DoD NSNs

4.9 Million

CAIs

DLA NSNs

3.9 Million

CSIs

3%

CSI =

Catastrophic or

Critical Consequences

(tailored MIL-STD-882

CAT I or II)

CAI =

Mission Loss

or Safety Impact


Critical Safety Item

Arresting Wire Socket and Pin

6


F-14 Nose Tow Launch Bar Pin

“DURING DROP CHECK OF NOSE LANDING

GEAR, MAINTENANCE PERSONNEL NOTED

LAUNCH BAR EXTENDED SLOWLY DURING NLG

EXTENSION. REMOVAL OF LAUNCH BAR

REVEALED LAUNCH BAR PIN CRACKED IN

HALF. LAUNCH BAR PIN WAS REPLACED

16JAN01 AND HAD ONLY 21 CATAPAULT

LAUNCHES. IT IS VERY LIKELY THAT THIS

DEFECT WOULD HAVE GONE UNDETECTED

HAD UNRELATED MAINTENANCE OF THE NOSE

LANDING GEAR DOOR/DROP CHECK NOT BEEN

PERFORMED. POSSIBLE LOSS OF

AIRCRAFT/POTENTIAL LOSS OF AIRCREW.”

(March 2001 VF-102, USS Theodore Roosevelt)

• Service Life … 2000 Catapults (Inspect Every 100)

• Failure Discovered ... 21st Launch

• 300M Steel Req’d

• 1018 Steel Used

• Full Hardening Req’d

• Case Hardened

• Markings To Be Vibra-Etched … No Markings

• Unapproved Source … Wrong Drawing

• 250+ Pins On-Hand … ½ Unmarked

• Bulletin, Red Stripe, Emergency Buy

7


Critical Safety Item

Holdback Bar Release Element

8

Crack

Holdback Bar

– Restrains Aircraft Prior To Catapult Firing

Release Element

– Calibrated “Weak Link” … Designed to

Break At Precise Pressure/Aircraft

• EA-6B Breaking Strength = 53,000 LBS

– 100% Magnetic Particle Inspection

Required

• Mag Particle Inspection Symbol

Stamped on Both Ends

– 32,000+ Procured


Boss Coupling

(Used In T/AV-8B, F/A-18, and T-45 Escape Systems)

9

Shavings

Seat

Interior of Mis-Manufactured Coupling, Showing

Improperly-Machined Seat and Machine-Shavings

Tip of SMDC Line Showing Seating Area Which Contacts Mis-Machined Seat of

Coupling Boss, Thereby Preventing Proper Installation of SMDC into Coupling

Boss and Leading to Excessive Tip-to-Tip Gap Between SMDC Lines and Impaired

Environmental Sealing

SMDC Connected to Mis-Manufactured Coupling, Showing

Uncompressed O-Ring Seal Which Degrades Environmental

Integrity of SMDC System


P-3 Barrel Nut

10


Surplus T-58 Turbine Baffle

(H-46 & H3)

11


Parachute Canopy Release (“Koch”) Fittings

• Problem:

– Canopy Release Assemblies Would Not

Remain Attached (Red Stripe ---Oct 2001)

• Synopsis:

– Koch & Sons’ Proprietary Design

– EPA Effort To Reduce Cadmium Plating …

Koch Declined To Convert to SS

– Koch Lost Proprietary Rights in 1991

– NAVAIR Reverse Engineered In 1993

– Alternative Design Tested in 1994

– ECP Implemented in 1997

– DLA Contracts For “Female” Release

Awarded to 2 Alternate Suppliers in 1998 &

1999 … Delivery 2001

• Neither Source Involved In The Reverse

Engineering or Original FAT

– DLA Contracts For “Male” Adapter To a

Different Source in 1997 (Delivery 2001)

• Findings:

– Tolerance “Build-up” Not Appreciated

During Reverse Engineering

– Koch’s Quality/Testing Process Not

Understood During Reverse

Engineering/Competitive Procurement

– Other Than Koch, No Supplier Made Both

the Male & Female Parts

Example of connected canopy release fittings (w/SEAWARS) on T-2 pilot

12


EJECTION SEAT STAPAC ROCKET MOTOR

BEARING SUPPORTS … S-3, A-10, F-15, F-16, B-1B

(NSN 1680-01-018-0960)

13

• STAPAC Provides Pitch Stability …Counteracts Force From Rocket Catapult

• Bearing Support 1) Mounts Rocket to Seat and 2)Allows Free Rotation of Rocket

• AF Approved Heat Treatment/Hardness Change Resulted in Cracks on S-3B Supports

• 4 Competitive Offers 1999-2002 (3 from Manufacturers, 1 From Surplus Dealer)

• Newly Manufactured Supports Failed Navy First Article Testing

• Only Surplus Offer Met Navy Functional Requirements

• CSI for Navy, AF Disagreed (“Haven’t Experienced Problems With The Support”)


SUU-63/BRU-32 Pylon Bolt

14

Bolts Attach Bomb Rack to Pylon

• Pylons Provided w/Bolts By Contractor

• “Forged” Bolt Heads Required

• 70 Pylons w/Machined Bolt Heads

Delivered (293 Bolts Total)

• Non-Approved Source

• No Supplier Eval Prior To Award

• QA Not IAW W/Requirements

• “New” Owners Reported Problem

• Useful Life < 3 Years vice 10 Years


Defense Criminal Investigative Service

Press Release

UNAPPROVED PARTS NOTIFICATION

SUSPECTED UNAPPROVED PARTS PROGRAM

OFFICE, AVR-20

45005 AVIATION DRIVE, SUITE 214

DULLES, VA 20166-7541

U.S. Department

of Transportation

Federal Aviation

Administration

UPNs are posted on the Internet at

http://www.faa.gov/avr/sups/upn.cfm No. 2002-00073

July 1, 2002

Published by: FAA, AIR-140, P.O. Box 26460, Oklahoma City, OK

73125

AFFECTED ENGINES

Honeywell/AVCO Lycoming LF507 series and ALF502 series turbine engines.

PURPOSE

The purpose of this notification is to advise all aircraft owners, operators, maintenance

organizations, manufacturers, and parts distributors regarding scrap parts reported stolen from a

repair facility.

BACKGROUND

Honeywell UK Limited, located at 65 President Way, Luton, Beds, United Kingdom

LU2 9NB, reported to the Federal Aviation Administration (FAA) that on January 18, 2002,

numerous scrap parts were stolen from the Honeywell repair facility. The following parts had

been determined to be scrap and were awaiting mutilation at the time of the reported theft.

Honeywell has indicated that the possibility exists that the parts may be offered for sale on the

open market.

Stolen Scrapped Engine Parts –

STOLEN SCRAP PARTS

Description Part No. Engine

Model

Applicability

Fan Disk 2-043-002-

11

Fan Disk 2-043-002-

11

Fan Disk 2-043-002-

11

Supercharger 2-043-004-

Disk

07

Supercharger 2-043-004-

Disk

07

Disk-4 th Stage 2-100-042-

Office 10 of Inspector General

Washington, D.C. 20546

Serial No.

507 & 502 6472 5122

507 & 502 6519 5153

507 & 502 M402537 5618

502 Only 201 5043

502 Only 335015 4025

Engine

Serial No.

/LFO-

NASA Office of Inspector General (OIG)

News Release

National Aeronautics 507 & 502 and Space SC53213 Administration 5332

July 29, 2002

RELEASE 2002-082

Improper Manufacture –

False Certifications

CALIFORNIA MAN INDICTED AND ARRESTED FOR AIRCRAFT PARTS SCHEME

The Office of the Inspector General (OIG) of the Department of Defense

(DoD) announced today that on July 8, 2002, Copeland Manufacturing

Corporation (CMC), Tulsa, OK, was sentenced in U.S. District Court,

Northern District of Oklahoma, Tulsa, OK, to 5 years probation and

ordered to pay $251,722 in fines, $68,048 in restitution and an $800

special assessment fee. Donald R. Copeland accepted the sentencing for

the corporation.

On February 14, 2001, CMC pled guilty to two counts of making false

statements to the United States Government. The charges resulted from

the CMC production of nonconforming spoiler-actuator attachment

fittings for the Teledyne Ryan Aerospace (TRA) Tier II+ Global Hawk, an

unmanned reconnaissance aircraft. The CMC also produced

nonconforming battery guides for operational use in the Space Station.

The investigation was conducted by the Defense Criminal Investigative

Service (the investigative arm of the OIG DoD) and the OIG, National

Aeronautics and Space Administration. Sentencing of the case was

handled by Assistant U.S. Attorney John Russell, Northern District of

Oklahoma.

NonConforming Parts –

False Certifications

Item:

Guilty Plea in Illegal Sale of Unapproved Aircraft Parts Case

Date: June 21, 2001

Type:

Summary:

Investigation

Sold Scrap Parts as FAA Approved

Rose Flores pleaded guilty in U.S. District Court in Houston to tax

evasion charges for failing to report income from the sale of scrapped

aircraft parts to an aircraft repair station and an aircraft broker.

Previously, Roger T. Sickler, co-owner of RTS Rework, Inc., an FAAapproved

aircraft repair station, and RTS Services, Inc., an aircraft

broker, were indicted in April, 2001 on charges of money laundering,

wire fraud, and conspiracy for their role in the scheme to sell the

scrapped parts for use as FAA-approved parts in commercial and

The point of contact regarding this press release is James S. Wray,

Resident Agent in Charge (RAC), Tulsa Resident Agency. RAC Wray can

be reached at (918) 581-6485.

military aircraft. This case is under investigation by OIG and the

FOR IMMEDIATE RELEASE CIV

To report suspected fraud, waste and abuse within DoD programs, contact

Defense Department’s Criminal Investigative Service.

FRIDAY, MARCH 7, 1997 (202) 616-2765

the Defense Hotline toll-free at (800) 424-9098, e-mail at

TDD (202) 514-1888

hotline@dodig.osd.mil or visit them on the World Wide Web at

http://www.dodig.osd.mil/hotline.

On July 25, 2002, Dale C. Henson, the President of Western Coupling Corporation, Mojave,

distribution to creditors. The government expects to receive

California, was indicted and arrested on 40 federal counts of mail fraud and ten counts of violating

about $840,000 for its allowed claim against SPECO.

the Aircraft Safety Act of 2000. Henson's company allegedly improperly manufactured hoses and

couplings for use with liquid oxygen systems and then shipped these hoses with fraudulent

certifications to contractors of NASA, the Department of Defense, and commercial companies.

One of the hoses was purchased for use on an experimental aircraft project with which NASA

was involved.

UNITED STATES SETTLES FALSE CLAIMS ACT LAWSUIT

FOR $7.2 MILLION ALLOWED CLAIM WITH OHIO COMPANY

WASHINGTON, D.C. -- SPECO Corporation, a bankrupt

Springfield, Ohio, company, has agreed to an allowed claim by the

United States of $7.2 million to settle allegations it

manufactured faulty transmission parts for Army helicopters, the

Department of Justice announced today.

The defective parts caused the crash of two helicopters in

Saudi Arabia and Maryland, the Department said. There were two

minor injuries.

Defective Parts - 2 Crashes

Assistant Attorney General Frank W. Hunger, in charge of the

Civil Division, and U.S. Attorney Dale Ann Goldberg of Columbus,

Ohio, said the settlement resolves SPECO's liability to the

government in a qui tam suit filed against SPECO Corporation and

The Boeing Company.

SPECO filed for bankruptcy under Chapter 11 in December 1995

and has liquidated its assets. Under bankruptcy law, creditors

with allowed claims may receive proportional payments from the

assets of the bankrupt company depending upon the classification

of their allowed claim and the amount of money available for

The suit alleged that SPECO violated the False Claims Act by

delivering transmission parts which it knew were defective for

use in the Army's CH-47D Chinook helicopter. The CH-47D Chinook

is the military's medium tactical heavy-lift transport

helicopter.

The investigation was conducted by Special Agents of the NASA Office of Inspector General's

The U.S. Bankruptcy Court of Dayton, Ohio, approved the

Office of Criminal Investigations, the Defense Criminal Investigations Service, and the

settlement on February 24, 1997, and the U.S. District Court in

Department of Transportation Office of Inspector General. The prosecution is being handled by

Cincinnati, Ohio, gave its final approval on March 6, 1997.

Jonathan Conklin, Assistant United States Attorney, Eastern District of California, in Fresno.

SPECO also agreed to provide the Department of Defense with

For more information on this release, please call Paul Shawcross, Executive Officer, NASA Office inventory and intellectual property to settle government claims

Item:

Three of Four Defendants Plead Guilty in SUPs Case

Date: August 19, 2002

Type:

Summary:

Investigation

Substandard, Untested

Counterfeit Parts

Thomas, Naomi, and Bradley Coffee (father, mother, and son,

respectively) pleaded guilty in U.S. District Court in Dayton, OH, in

connection with the attempted sale of suspected unapproved aviation

parts (SUPs) to undercover Federal agents. The three defendants, along

with Jeremy Coffee (another son) and The Centerville Marketing

Group, of Centerville, OH, were indicted in Philadelphia, PA, in July

1999 with conspiracy, mail and wire fraud, and trafficking in

counterfeit goods or services. The Coffees were selling substandard,

untested, or counterfeit aircraft parts, primarily avionics antennas, with

military and civilian applications. Bradley and Thomas Coffee

subsequently pleaded guilty to conspiracy to commit mail and wire

fraud, and Naomi Coffee pleaded guilty for failing to report a felony.

Sentencing is anticipated in January 2003. Jeremy Coffee is expected

to enter a guilty plea on October 18. This case was investigated by the

15


Business Week - 1997

WARNING!

Logistechs 2001

Bogus parts have turned up in commercial jets. Where's

the FAA?

One minute, Edward Zwig, an Atlanta periodontist on a trip to Miami, was

reading the paper in an aisle seat, waiting for takeoff from Atlanta's

Hartsfield International Airport. The next minute, he was fighting his way

to the emergency chutes amid screaming fellow passengers as the cabin rally of sp read w ith catastrop hic conseq uence.

the DC-9 filled with smoke. ``After we got out, we could see flames

dancing around the fuselage,'' recalls Zwig, who was one of 57 passenger

on a ValuJet flight last June when the No.2 engine exploded. ``We actually

p onsible for the crash.

stood on the runway and watched the plane burn.'' The explosion sent metal

fragments flying through the cabin. Flames and smoke quickly followed,

injuring several passengers as well as a flight attendant, who suffered

severe burns.

The cause: an engine that had been overhauled and later sold to ValuJet k nown. by

a repair station in Turkey that lacked FAA approval. The station denies

responsibility, but investigators found that the engine contained a cracked

and corroded compressor disk. The excessive corrosion had been plated

ht now," say s R uss Shreeve of the C anaan G roup.

over during the overhaul. ValuJet says the engine's documentation appeared

to be in order and the defect was undetectable. When the engine revved up,

the disk fractured, causing the engine to explode. Had that happened in

midflight or in a more crowded plane, the results could have been

st?," she say s, "A bsolutely , a b so lu tely , ab solutely ."

catastrophic.

The accident caused no fatalities--unlike last month's crash of ValuJet

Flight 592 into the Everglades. But in some ways, it was more ominous,

because it highlights a safety issue that affects every carrier in the air: the

growing stream of substandard or bogus parts that are finding their way into

commercial aircraft. In a porous and underregulated market, the selling of

substandard replacement parts for planes can be even more profitable than

re. B ut it's a d ifficult j ob."

trafficking in illegal drugs. Bogus parts are fast becoming an underworld

growth industry--and, many airline officials, FAA inspectors, and lawenforcement

officers fear, a catastrophe waiting to happen.

You will not find bogus parts listed as the cause of any accidents in the g ed and sold as overhauled for $1,200.

publicly available

National Transportation Safety Board database. But that's not because

they're not a problem. The FAA allegedly pressured the NTSB to stop

listing bogus parts Aerospace in its database Federation as a possible cause Condemns of crashes, according Use of Bogus Aircraft Parts

to four independent sources: a senior FAA official, as well as sources in the

Transportation Dept., the airline industry, and congressional staff. Instead,

the category has been changed to the more innocuous-sounding

``unapproved parts.'' The FAA says that it discussed the change with the

NTSB, but 5th did not October pressure 2000 the board. The NTSB denies it was pressured.

The sources say the FAA also changed its own database last year to show

The Federation of Aerospace Enterprises in Ireland (FAEI) responded to the

Garda investigation into bogus aircraft parts, which was carried out in

Limerick today.

Plane parts on black market plagues airline industry

Associated Press

When an American Airlines plane smashed into a Colombian mountainside last December, outlaw

salvagers didn't even wait for all 159 victims' bodies to be collected before they moved in.

Using sophisticated tools, they extracted engine thrust reversers, cockpit avionics and other valuable

components from the shattered Boeing 757 and then used helicopters to fly the parts off the steep ridge,

U.S. and Colombian sources say.

The parts were offered for sale in Miami, a hub of the thriving black market in recycled, stolen and

B ogus Parts - Trojan Horse of the Airline counterfeit Industry aircraft parts.

"They wanted to sell the whole lot, including the landing gear,'' a law enforcement source said, speaking on

g us p arts, the T roj an H orse of the airline industry . T h ey 're accep ted by airlines w ith the

p ression that they 're a b en ig n solution to a p roblem , nicely adorned condition with y ellow of tag anonymity.

s or

c um ents trum p eting their integrity. But once on an aircraft, the fire in a bogus part's belly can

a cking and rep lacing bog us p arts costs the airline industry millions of dollars annually ,

c ording to a n exp ert at the C anaan G roup, an aviation consultant firm . Param ount to that

n cern is the p otential hum an-loss factor that com es with bogus parts. Judicial history was m ade

t he US in m id-1999 w hen third-degree m urder charges w ere am ong 24 laid against form er

p loy ees of an aviation m aintenance com pany stem m ing from the 1996 ValuJet crash in Florida

t killed 110 p eop le. F alsely documented oxygen canisters installed on the aircraft w ere

ese are daunting issues for the m ore than 90 larg e air carriers op erating

re than 7,500 aircraft in the U S. The Federal A viation A dm inistration

y s there w ere about 26 m illion p art chang es in 1996 alone. A nd if the

A is correct in assum ing that only tw o p er cent of those p arts are

o wing l y chang ed as unapproved , th at's h alf a m illion p arts that are

h er counterfeit, substandard, falsely documented, undocumented, exp ired, rej ected, or

g us p arts have infiltrated the inventories of every m ajor airline in the U S, says a report done by

sinessW eek in 1996. N ot even A ir Force O ne w as exem p t. Fire exting uishers m eant for the

e sident's p lane carried false docum entation. "I think it w ould be foolish to assum e that there

e n't bog us p arts fly in g rig ht now. It can be almost imp ossible to catch them because of the false

p erw ork… I've talked to p eop le in th e ind ustry that susp ect there are bog us p arts on p lan es

e p roblem m ay j ust g et w orse over tim e, desp ite the FA A 's education efforts and industry 's

o wing awareness of the p roblem . A irline fleets are ag in g , req uiring more p arts chang es and

reby allowing m ore bog us p arts to creep in to th e sy stem .

v erly Sharkey, A viation Safety Inspector and attorney w ith the FA A , says that progress is being

de "As far as the aw areness and com p anies p utting forth efforts tow ards addressing th e issu e is

n cerned." There's a resounding "but"' in the p ictu re n everth eless: " D oes th e p rob lem still

1993, the Susp ected Unapproved Parts Prog ram was established by the FA A to coordinate

o rts in addressing issues p osed by the entry of bog us or "unapproved" p arts into the U S

ation sy stem . The FA A refers to bog us p arts under the broader term "susp ected unapproved

r ts" (SU Ps) to cover "the sp ectrum of p arts that m ay not m eet the req uirem ents of the Federal

iation R eg ulations in reg ard to manufacture and m aintenance," says Ken Reilly, manager of

Susp ected Unapproved Parts Prog ram O ffice in W ashing ton, D .C .

t he last three y ears, the FA A has had to add m ore than 400 insp ectors to its 2000 strong arm y

s tem the p roblem since "the numbers [of SUPs ] haven't decreased," says Sharkey.

nk Price, sp okesp erson for the FA A couldn't say if th e p roblem w as insurm ountable, but say s

continued existence calls for g reater vig ilance. "I think w e've done q u ite a bit in th e area of

approved p arts. W e n eed to co n tin u e to b e fastid iou s in ch eck in g th at th ese p arts a ren 't ou t

t im a tely , b o g us p arts are still p revalent. "The FAA is accused of not knowing how many

approved p arts are out there, but ask the averag e law enforcem ent official and they don't know

w many drug s are out there," say s Price. The com p arison is a valid one. The bog us p arts

s iness in the U S can be m ore lucrative than the drug trade. It w as docum ented by the FA A that

carded com p ressor blades for j et eng ines w ere bought at $1 apiece, sm oothed, coated, falsely

e airlines have a j ob on their hands. The FA A insists that in the end it's up to the airlines

mselves to sp ot bog us p arts. "M any air carriers, m anufacturers and repair facilities have

p lemented unapproved p arts p rog ram s that have enhanced their receiving insp ections, SU P

p orting p rocedures and supplier surveillance," say s R eilly .

W e allocate m ore resources to the p revention of unapproved p arts than any other single

mpany ," say s Dick Schleh. "Our unapproved p arts p rog ram is currently staffed w ith six fulle

em p loy ees." Boeing and its industry p artners work daily w ith fed eral au th orities in

v elop in g law s, p olicies an d p rocedures to elim inate unapproved p arts.

e thing all industry p eop le ag ree on is that chang e is necessary to co m b a t S U P s . Iro n ically ,

t hing in the U S C rim inal C ode directly addresses m anufacturing and distributing bog us p arts.

a rt of the crim inal p roblem is that rig ht now there's no law specific to dealing in unapproved

craft p arts," say s Sharkey of the FAA. All 136 convictions related to SUPs in the US since 1995

v e been m ade on wire or m ail fraud, or on falsify in g g overnm ent docum ents.

a rkey say s there's a p ending chang e to Title 18 of the US Criminal Code thst defines crimes and

m in al p rocedures. R ecently , a n in terag ency law enforcem ent/FA A w orking g roup was

a blished, the result being a draft leg islation to am end the title, m aking it a crim e to traffic

u nterfeit p arts. B u t it's still p en d in g says R oger W illiam s, an attorn ey w ith th e O ffice of th e

p ector G eneral at the U S D ep artm ent of T ransp ortation.

say s it's a necessary am endm ent. In July , 1999, the vice-president of a Florida manufacturer

d distributor of aircraft hoses, A ir-Pro Inc., pleaded guilty to falsifying records about the

ulatory conform ance of p roducts made by the firm . H e faced a p ossible sentence

ASSOCIATED

of 5 y ears

PRESS

p risonm ent and a $250,000 fine. But the real crim e w asn't falsely docum enting p arts, it w as th e

nufacturing and distribution of bog us p arts, a crim e that could be resp onsible for costing lives.

July 25, 2002

he leg islation is p assed it m ig ht be the best solution to the p roblem : "If an unapproved p art is

ectly resp onsible for a crash w here there's been loss of life, that could carry a possible penalty

l ife im p risonm ent," say s W illiam s.

Mr Conor O'Hara Chairman of the FAEI and Managing Director of Lufthansa

Airmotive stated that the Federation condemned without reservation the use

of bogus aircraft parts within the Aerospace Industry. He stated that the use

of bogus aircraft parts is a major international problem, which has developed,

in recent years. Earlier this year a senior representative from the Federal

Aviation Administration (FAA) addressed a seminar organised by the FAEI on

the very topic of bogus spare parts which was attended by Federation

member companies from all over Ireland. There is a need for vigilance in this

area and the Federation has worked closely with its member companies

together with the Irish Aviation Authority (IAA) and the FAA authorities to

ensure that this practice is effectively tackled.

Back to Press Releases

Parts illegally salvaged from crashes, counterfeit parts and other substandard components regularly find

their way into the world's air fleets, sold at bargain prices, often with falsified documents about their origin

or composition.

For the flying public, they are a growing peril.

"The whole system is contaminated,'' said Peter Friedman, director of quality at an aircraft repair station in

Oakland, Calif. "In my position, I find unapproved parts on a daily basis.''

"Unapproved parts'' is the Federal Aviation Administration's term for components not certified as airworthy

- from fraudulently produced knockoffs made from inadequate alloys to recycled pieces misrepresented to

hide defects, age or crash damage.

General Advice Suspected Unapproved Parts

AWB 01-11 Issue 1, 11 February 2002

Suspected Unapproved Parts

Parts distributed by

Panaviation s.r.l.

Effectivity

All parts distributed by Panaviation s.r.l.

Purpose

The purpose of this Bulletin is to alert all aircraft owners, operato

maintenance organisations, manufacturers and parts distributors

any part distributed by Panaviation s.r.l. may have been altered

misrepresented by a non-approved source.

Background

Panaviation s.r.l. based in Rome - Ciampino airport, is an Italian

distributor supplying aircraft components all over the world. They

never been approved nor have they had any sort of recognition b

Ente Nazionale per l'Aviazione Civile (ENAC), the Italian Civil Av

In the industry, they are known as "bogus parts.'' For people with no qualms about putting the flying public

Authority.

at risk, it's a lucrative market. The worldwide aircraft parts inventory is worth $45 billion.

Just how many unairworthy parts have claimed lives is not known. Internationally, no one keeps records. In

Colombian ENAC has alerted cocaine all National gangs Aviation linked Authorities to that ENAC ha

the United States, the number of cases is in dispute.

aircraft been requested parts scam to co-operate with an Italian prosecutor in a crim

The worst confirmed accident occurred on Sept. 8, 1989, when at 22,000 feet over the North Sea, the tail

section of a Convair 580 turboprop plane began vibrating violently and tore loose. The charter aircraft, investigation against this organisation. Following inspections of

Philip Willan in Rome and David Teather in New York

carrying 55 people from Oslo, Norway, to Hamburg, Germany, splattered over 3« miles of sea. Everyone Wednesday Panaviation January 30, s.r.l. 2002 facilities ENAC revealed the following technica

aboard died.

The Guardian

findings.

Norwegian investigators painstakingly dredged up 90 percent of the 36-year-old plane Investigations and found the into cause: a scam involving the sale of faulty, second-hand aircraft parts have widened to

bogus bolts, bushings and brackets. The charter company, Partnair, went out of business, Colombian and the drug origin cartels of after the US Congress heard reports that gangs were moving from

the parts was never determined.

cocaine trafficking to this more lucrative a. An line unapproved of business. workshop has been found to practice disassemb

assembling, measuring, cutting, grinding, cleaning, sheet metal

Most major international airlines have encountered unapproved parts - and the problem It emerged is more earlier serious this in week that as many working, as 10 recent and air altering crashes the could physical have been conditions caused of by the aviation pa

the developing world, where regulation is lax when it exists at all.

old parts being sold as new to unwitting Tools airlines. and equipment for counterfeit and fraudulent identificatio

"It's a real can of worms,'' said Michael F. Rioux, chief of engineering and maintenance at the Air Transport

documentation and metal data plates have been found.

Association of America, whose 20 member airlines carry 97 percent of U.S. commercial The FBI traffic. has reportedly sent its own investigators to look into links to the crash of the American

Airlines Airbus in New York in November, in which 265 people died.

Brian Wall, security chief for the International Air Transport Association, which represents more than 260

airlines, promotes seminars on bogus parts. "We view this as a potentially dangerous American situation. Airlines Who knows yesterday said it had double-checked the source of its aircraft parts and had no

if we know the whole picture?'' Wall said from IATA headquarters in Montreal. reason to believe itself a victim of the scam. John Hotard, a spokesman for the company, said:

Many industry executives refuse to discuss the issuee.

"Every part we buy has a paper trail and we only use vendors that we know and audit on a

Four family members indicted on fraud

regular basis."

Even officials

charges

at United, American and Federal Express, among air carriers widely praised for tightening up

their control of parts inventories, would not speak openly about their experiences with Information bogus parts. on the role that Colombian gangs might be playing emerged in evidence given to the

US Congress by an official of the department of transport, according to Italian investigators. The

tip was subsequently passed to investigators in Sardinia who have discovered a flourishing trade

in bogus aircraft parts.

SAN DIEGO – Four family members were indicted Thursday for

allegedly conspiring to defraud the Defense Department through their

suburban San Diego military parts business.

The four were accused in a 90-count indictment of selling the military

cheaper, inferior wire rope used on missile systems, helicopters and

aircraft including the B-1 bomber and F-14 Tomcat.

Through their Spring Valley-based business, Supply Depot, Inc., the

four also sold inferior casters that are used to move bombs and fuel

tanks to and from military aircraft among other things.

Indicted were Gerald Dillon, 53; his wife, Rosmarie Dillon, 47; and

their two sons, Jeffrey, 31; and Gerald Jr., 29. They face charges of

conspiracy to defraud the United States, making false statements,

fraud and filing false tax returns.

The indictment said that the Dillons omitted income of more than $1.4

million from their tax returns.

Criminal investigators with the Army, Air Force, Navy and the

Pentagon assisted the FBI and Internal Revenue Service in the

investigation.

"The official said the drug traffickers had given up cocaine smuggling in order to enter the aircraft

parts market," said Major Anselmo Mocci, an officer in the Sardinian finance police. "The

business was more profitable than cocaine traf ficking and obviously much less dangerous."

SUNDAY, JUNE 3, 2001

The US Federal Aviation Administration has issued a warning to 167 countries over the potential

dangers of the spare parts network. Much of the focus is on small airlines, which may try to

economise by buying used parts from brokers instead of ordering them new from the

O-rings manufacturers. prompt charges

tion targeted ex-Galena company

Alarms about the possible in volvement of the drug cartels in the aircraft parts market were raised

turgeon recently III in the Italian parliament. In a question to the minister for the secret services, the senator

Writer Aventino Frau said: "The international traffic in aircraft spare parts could be connected with or

used for purposes of terrorism or sabotage. I would like to know whether our intelligence services

Kan. have — been The activated." investigation of a Galena company that

old faulty O-rings to the U.S. Department of Defense

n There a Kentucky were raids Air by National Italian police Guard on cargo several plane warehouses started in Naples and Rome at the weekend,

el

which

during

led

preflight

to six arrests

preparations

and the seizure

in January

of a consignment

of 1999.

of aircraft parts.

Some of the parts - which may have been recovered from an earlier aircraft crash - were

tigation accompanied has led by to falsified the May certificates 14 charges vouching of mail for fraud their efficiency.

against the company, L&T Seals Inc., and its

Galena Investigators resident in Sardinia Elesa Brandenburg, have reportedly on uncovered May 14. four secret bank accounts in Austria which

they believe were used to handle bribes paid to airline employees and civil aviation officials. They

gs arrested supplied several by L&T people, were including designed Pietro to seal Paolo the Corrias, the acquisitions director of the Italian

airline Meridiana. He is accused of having demanded a 7% commission on purchases of used

16


FOR IMMEDIATE RELEASE CIV

THURSDAY, DECEMBER 15, 1994 (202) 616-2765 TDD (202) 514-1888

Defense Criminal Investigative Service

Press Release

Defense Criminal Investigative Service

Press Release

The Office of the Inspector General (OIG) of the Department of Defense

(DoD) announced today that on

May 16, 2002, Heinz Laumann, former president, Laumann

Manufacturing Corporation (Laumann Manufacturing), Ronkonkoma, NY,

was sentenced in United States District Court, Eastern District of

The Office of the Inspector General (OIG), Department of Defense (DoD), Pennsylvania, to 2 years probation and a $100 special assessment fee.

announced today that on April 11, 2002, Nestor "Dan" Lopez, director, Additionally, Laumann Manufacturing was sentenced to 2 years probation,

Damon Industries, Incorporated (Damon), Pompano Beach, FL, was arrested a $400 special assessment fee and a fine of $31,199.68. Sentencing was

based on the unsealing of a 54-count indictment handed down by a Federal imposed by United States District Court Judge Mary McLaughlin.

grand jury in the United States District Court, Southern District of Florida.

The indictment charged Lopez with supplying military spare parts to the DoD

Laumann Manufacturing manufactures various aircraft components for the

that did not meet the heat treatment specifications in DoD contracts.

DoD and the commercial aircraft industry, including critical products for

the F-14, F-15, and F-16 fighter aircraft.

The indictment stated that counts 1 through 26 related to false claims

submitted to the Defense Supply Center-Columbus, OH. Lopez was required

Laumann and Laumann Manufacturing previously pled guilty on February

to heat treat the spare parts per the military specifications, however, Lopez

failed to do so, in violation of the False Claims Act. The spare parts went

11,

into

2002, to one count of mail fraud as the result of an investigation that

DoD weapon systems such as the C-135 aircraft, M109 Howitzer, M2 .50

disclosed Laumann falsely certified that aircraft components passed

caliber machine gun, F-18 fighter aircraft, M224 60mm Mortar and numerous dimensional inspection requirements when, in fact, such products were not

other weapon systems. Counts 27 through 54 of the indictment related to inspected the or failed inspection. These parts were then sold to commercial

wire transfers of the money Lopez received from the submission of the false aircraft companies.

claims, in violation of mail fraud.

The investigation was conducted by the Defense Criminal Investigative

If convicted, Lopez faces a maximum term of 5 years imprisonment and Service a $1 (the criminal investigative arm of the OIG DoD), the Naval

million fine for each count.

Criminal Investigative Service, and the Federal Bureau of Investigation.

DEPARTMENT OF DEFENSE INSPECTOR The GENERAL prosecution was handled by Assistant U.S. Attorney Bernadette

DEFENSE CRIMINAL INVESTIGATIVE

This investigation was conducted by the Defense Criminal Investigative McKeon, SERVICE Eastern District of Pennsylvania, Philadelphia, PA.

WESTERN FIELD OFFICE

Service (DCIS) (the criminal investigative arm 26722 of PLAZA the OIG, ST., DoD). SUITE The 130

prosecution is being handled by Managing Assistant MISSION U.S. VIEJO, Attorney CA, 92691 Eileen The point of contact regarding this press release is Group Manager (GM)

O'Connor, Southern District of Florida, Fort Lauderdale, FL. Kenneth Maupin, Northeast Field Office. GM Maupin may be reached at

(610) 595-1900.

May 14, 2002

The point of contact regarding this press release is Alan W. White, Director,

Investigative Operations

REPORT

Directorate,

OF ALLEGED

Headquarters,

FALSIFIED

DCIS.

HEAT

Mr White

TREAT

may To AND

be report INSPECTION suspected fraud, waste and abuse within DoD programs, contact

contacted at (703) PROCESSES 604-8614. AT TEMPERFORM USA: On May 31, 2001, the Defense Criminal Hotline toll-free at (800) 424-9098, e-mail at

Investigative Service (DCIS), Western Field Office, initiated an hotline@dodig.osd.mil investigation of Hydroform or USA visit them on the World Wide Web at

To report suspected (Hydroform), fraud, 2848 waste East and 208 abuse th Street, within Carson DoD (Long programs, Beach), contact CA http://www.dodig.osd.mil/hotline.

90810 the and Temperform USA

Defense Hotline (Temperform), toll-free at 14425 (800) 424-9098, and 14365 Macaw e-mail Street, at hotline@dodig.osd.mil

La Mirada, CA 90638. The investigation

or visit them concerns the World falsification Wide Web of all at aspects http://www.dodig.osd.mil/hotline.

of the heat treat and quality inspection process, which -Endaffects

United States Department of Defense (DOD), and National Aeronautics and Space

Administration (NASA)-End-

and commercial aircraft aluminum components.

Hydroform, and its subsidiary Temperform, provided false certifications to DoD and NASA

contractors and commercial customers from May 1998 through at least September 2001.

According to witnesses, the most flagrant and consistent falsification of heat treat processes and

quality inspections occurred from July 1999 through March 2000.

BACKGROUND

On February 26, 1998, Hydroform purchased West Coast Aluminum Heat Treating Co.

(West Coast), La Mirada, CA. The West Coast business was renamed Temperform and is

operated as a subsidiary of Hydroform. Temperform and its predecessor West Coast specialized

in the heat treating and quality inspection of aluminum alloy parts. Both Temperform and

Hydroform are owned and operated by Kerry Jablonski. Hydroform specializes in the

manufacturing of airframe detailed parts, sub-assemblies and kits for the aerospace industry.

Hydroform’s manufacturing process includes part forming, fabrication and machining. Prior to

Hydroform’s purchase of West Coast, Hydroform sent all of its parts to West Coast and to other

heat treat companies for heat treating. After the purchase, Hydroform was able to process all of

its parts “in-house” at Temperform.

Temperform is a lower tier sub-contractor to its parent company Hydroform and other

U.S. SETTLES FALSE CLAIMS ACT CASE AGAINST EQUIPMENT & SUPPLY INC. AND ESI

PRESIDENT, ANDREW A. ADAMS

WASHINGTON, D.C. -- Equipment & Supply Inc. of Monroe, North Carolina, and the company's

president and owner, Andrew A. Adams, will pay the United States a settlement valued up to $1.4 million to

resolve allegations they sold aircraft parts and service equipment to the Department of Defense that failed to

meet contract specifications, the Department of Justice announced today.

Assistant Attorney General Frank Hunger, head of the Civil Division, said that under the settlement ESI

will pay the government $750,000; withdraw its claim seeking $163,372.33 from the Navy in another

contract dispute; pay a balloon interest payment at the treasury rate on today's settlement; and pay the

government up to an additional $500,000--contingent upon ESI's gross sales in the next five years.

The case was originally filed against ESI in U.S. District Court in Philadelphia, Pennsylvania, as a qui

tam false claims lawsuit by a former ESI employee. The qui tam provisions of the False Claims Act permit

a private citizen to file a suit on behalf of the federal government and collect a portion of the money if the

government's action is successful.

In May 1994 the government filed an amended complaint to intervene in the lawsuit and added Adams as

a co-defendant. The government also alleged in its amended complaint that ESI paid illegal kickbacks over

a period of more than 10 years to former Lockheed employee, Richard A. Pope, in violation of the Anti-

Kickback Act in order to obtain preferential treatment in transactions involving a prime government

contractor, Lockheed-Georgia. Shortly after, ESI and Adams filed for bankruptcy under Chapter 11 in

Charlotte, North Carolina. The federal bankruptcy court approved the settlement agreement on December

12, 1994.

ESI manufactured and sold aviation parts to many federal agencies and commercial customers. The

government alleged that, during the past 10 years, ESI fraudulently delivered more than 300 separate aircraft

parts and service equipment that did not meet contract specification requirements and provided falsified test

results to the government.

In January 1994, ESI pleaded guilty in federal court in Charlotte to conspiracy and making false

statements concerning ESI's delivery of critical parts used in the United States Army's UH-1 helicopter that

ESI knew did not conform to government contract specifications. At the same time, the company pleaded

guilty to altering cure dates to conceal the original manufacture date and age of rubber O-Rings in O-Ring

replacement kits used on aircraft and selling the kits in the commercial aviation market. ESI also pleaded

guilty to altering test certifications for a sling device used to cradle military aircraft engines on runways,

tarmacs, or aboard aircraft carriers and conspiring to pay kickbacks to a former Lockheed employee.

On November 22, 1994, Pope was convicted of 25 counts of conspiracy, kickbacks, and mail fraud

involving his receipt of gratuities from ESI in U.S. District Court in Atlanta, Georgia.

The civil fraud case was investigated by the Defense Criminal Investigative Service's office at Chapel

Hill, North Carolina, the Naval Criminal Investigative Service's office and the Army's Criminal Investigative

Command's Fraud Field Office at Raleigh, NC, and the Air Force Office of Special Investigations,

Detachment 115 at Smyrna, Georgia. Audit support was provided by the Defense Contract Audit Agency's

Eastern Regional Office at Smyrna, Washington Georgia. Post

94-704

#####

February 9, 2000

Pg. 4

Navy Tests Carriers' Spare Parts

Pentagon Warns of Possible Quality Problems, Accident Risks

By Steve Vogel, Washington Post Staff Writer

Quality control problems are forcing the Navy to inspect, test and possibly recall

nearly 80 types of spare parts that may have reached aircraft carriers and could cause

serious accidents, Pentagon officials said.

Most of the parts belong to catapults that launch jets from a carrier and cables that

hook jets as they land. "These are the most critical parts out there on these weapons

systems," said William Finkel, a senior official with the Defense Logistics Agency at

Fort Belvoir, which is responsible for acquiring the parts. "If they were to fail, they

could cause loss of an aircraft, injury or perhaps even death."

The Navy said the faulty parts, which may number in the thousands, have not been

blamed for any accidents. But the Defense Criminal Investigative Service is

examining the contracts for four types of parts that have been declared unusable, and

the Navy is testing dozens of other parts that may not meet quality standards. The

manufacturers' identities have not been made public.

The seriousness of the problem, and whether to disclose it to the fleet, has been a

subject of debate between the Defense Logistics Agency and the Navy. On Jan. 13,

17


Item:

Supplier Pleads Guilty to Selling Substandard Military Helicopter Parts

Date: March 4, 2002

Type:

Summary:

Investigation

Rebuilt Parts Sold As New

Gunter Kohlke, owner of Aircraft Components, Zurich, Switzerland,

pleaded guilty in U.S. District Court in New York, NY, to selling

substandard military helicopter parts to foreign countries in violation of the

Arms Export Control Act. A middleman, Kohlke purchased parts from

Mike Turner, president of Air Technology, in Naples FL, and resold them,

advertising the rebuilt parts as factory-new. In June 2000 Kohlke told an

OIG special agent that Turner sold him substandard aviation parts. In the

plea agreement, he agreed not to contest the forfeiture of $107,000, the cost

of the parts. Kohlke is scheduled for sentencing on May 14. OIG was aided

in this investigation by the U.S. Customs Service.

FOR IMMEDIATE RELEASE

Wednesday, March 11, 1998

Contact: Jeff Nelligan

(202) 366-6312

OIG 8-98

STIFF SENTENCES GIVEN TRAFFICKERS

IN STOLEN AIRCRAFT PARTS

The Department of Transportation’s Office of Inspector General (OIG) today announced

the sentencing of two traffickers in stolen aircraft parts, including some obtained by

armed robbery.

A 12-year prison term and a fine of $1.3 million were given to Jose Costales Jr., 32, a

resident of Davie, Fla., followed by 3 years of supervised release. Costales was convicted

by a U.S. District Court in Florida.

A second defendant, Guy Salom, who pleaded guilty prior to the criminal trial, was

sentenced to 18 months’ incarceration. Three other defendants await sentencing.

"These are some of the stiffest penalties ever given in an aircraft parts case," said

Inspector General Kenneth M. Mead. "The crime is of an extremely serious nature

because it is nearly impossible to verify the airworthiness of stolen parts. Parts that are

not airworthy could place air passengers at risk. The severity of the sentences underscores

how seriously the court viewed the crime."

Costales was convicted in September 1997 of conspiracy to communicate false

information endangering the safety of an aircraft, unlawfully transporting stolen aircraft

parts in interstate commerce, and committing mail and wire fraud by lying to unknowing

buyers about the origin of aircraft parts so as to disguise the fact they were stolen.

The federal jury also convicted Costales of the armed robbery of $1.5 million in jet

aircraft parts from two Federal Aviation Administration (FAA) certified repair stations,

Aerothrust Corporation and Aviation Enterprises International, Inc., both in Miami. The

robberies occurred in November 1994 and March 1995. Included in the robbery were

stolen aircraft jet engines, Allison turbine engine blades, and other engine components.

The stolen parts subsequently were sold or "laundered" by an FAA-approved repair

station, Nation’s Air Corp., and a parts distributor, World Air Sales and Services, Inc.,

both located in Miami and owned by Costales Jr. He falsely represented the parts’

traceability and airworthiness by issuing false vendor material certifications. Many of the

parts were then sold to co-defendant Thomas David Hinton, who in turn sold them to

various parts distributors and major airlines, including TWA and Delta Airlines.

The investigation was the joint effort of the department’s Office of Inspector General, the

Federal Bureau of Investigation, the Metro-Dade Police Department, the Drug

Stolen Parts –

Fake Certifications

Item:

FOR IMMEDIATE RELEASE

Wednesday, July 7, 1999

Contact: Jeff Nelligan

Telephone: (202) 366-6312

OIG 11-99

FIRM, VICE-PRESIDENT PLEAD GUILTY

IN SUBSTANDARD AIRCRAFT PARTS CASE

A Florida maker and distributor of aircraft hoses and its vice president have pleaded

guilty to making false representations about the regulatory conformance of products

made by the firm, the U.S. Department of Transportation's Office of Inspector General

announced today.

Air-Pro Inc. and John Wilson, its vice president, pleaded guilty on June 30, 1999 in U.S.

District Court in Miami. Though sentencing is set for September, the firm has agreed to

pay a fine of $200,000, offered to replace substandard parts and improve its quality

control program. Wilson, who also is the firm's operations manager, faces up to five

years' imprisonment and a fine of up to $250,000.

A federal investigation showed that the Florida firm, which sold hoses to both military

and commercial aviation customers, falsified manufacture dates on the hoses to make

them appear years newer than their actual age. To prevent hose failure, Federal Aviation

Administration and military standards bar purchase of hoses for use in aircraft

applications that are more than 6-8 years from the hoses' date of manufacture. Some

hoses carry aircraft fuel, oil or hydraulic fluid and are parts critical to flight safety.

The investigation also found that Air-Pro had substituted polyolefin for teflon in making

protective sleeves for certain hoses. Teflon is more abrasion-resistant and can withstand

temperatures of up to about 400 degrees, while polyolefin may fail at 250 degrees or

above. Hoses involving such sleeves are used in the landing gear of large commercial

jets.

Further, the investigation revealed that hoses made by Air-Pro for use in oxygen supply

for assisted breathing had not been properly cleaned and tested to prevent contamination.

The case was jointly investigated by the Department of Defense and the U.S. Department

of Transportation’s Office of Inspector General.

###

False Certifications –

Material Substitution

Aviation Parts Manufacturer and Owner Fined, Incarcerated

Date: February 2, 2001

Type:

Summary:

Untested Parts

Investigation

Briefing Room

Dan Massey, owner of RHIMCO Industries, Inc., was sentenced by a

U.S. District Court judge in Philadelphia to 5 months in a Federal

halfway house followed by 5 months' home confinement, 24 months'

supervised release and a $25,000 criminal fine for supplying untested

critical application aircraft parts to the United States military and

commercial aviation customers. RHIMCO was also sentenced to 12

months' probation and a $115,000 criminal fine. Untested RHIMCO

parts were traced through purchase orders to several commercial

aviation businesses, including Lockheed Aircraft Service. OIG

investigated this case with the FBI and the DCIS.

Item:

Counterfeit Aircraft Parts Dealer Ordered Jailed for 56 Months

Date: January 9, 2002

Type:

Summary:

Investigation

Incorrect Materials

False Certifications

Failed in Use

Counterfeit Parts Sold As OEM

Bo Baker, president and owner of 3D Industries, Dallas, TX, was sentenced

to 56 months in prison and ordered to pay $198,268 in restitution by a U.S.

District Court judge in Dallas, for misrepresenting counterfeit aircraft parts

as approved parts. Baker told the FAA that inner combustion shells for

Lear Jets were shipped directly to 3D by the authorized manufacturer,

General Electric Engine Services, when in fact, they were fakes. Baker

pleaded guilty in August 1999. A second defendant, Richard M. Teubner is

scheduled for sentencing on January 28, 2002. OIG investigated this case

with the FBI and Dallas Flight Standards District Office.

18


COMMERCE BUSINESS DAILY ISSUE OF JULY 10, 2001 PSA #2889

AWARDS

15 -- SKIN, RIB ASSEMBLY, AIRCRAFT

Notice Date

July 6, 2001

Contracting Office

Supply Directorate, Contracting Department, PSC Box 8018, MCAS, Cherry

Point, NC 28533-0018

ZIP Code

28533-0018

Point of Contact

United Aircraft and Electronics

Cherie Daniels, Contract Specialist, 252-466-7504, Kathy M. Rogers, Contracting

Officer, 252-466-3446

Award Number

M00146-01-M-9015

Award Date

July 5, 2001

Awardee JOHN S. GORDON

United Aircraft United States and Attorney Electronics, 1140 North Kraemer Blvd, Anaheim, CA 92806

Award Amount Central District of California

$64,973.00

Line Number(s) Thom Mrozek, Public Affairs Officer

N/A (213) 894-6947

thom.mrozek@usdoj.gov

Record

April 4,

Loren

2002

Data Corp. 20010710/15AWD002.HTM (W-187 SN50R0F5)

TWO ORANGE COUNTY MEN INDICTED

IN FRAUD SCHEME INVOLVING AIRCRAFT PARTS

Two men were arrested today on federal fraud charges that allege they made Item: materially

false certifications concerning aircraft parts that they sold.

A federal grand jury in Santa Ana yesterday indicted Amanullah Khan, 53, of Brea, and

Ziad Jamil Gammoh, 52, of Tustin, on charges of conspiracy and fraud involving aircraft

parts. Khan was arrested this morning by federal agents, and Gammoh was taken into

custody when he surrendered this morning at the United States Courthouse in Santa Ana.

Both men are scheduled to make their initial court appearance this afternoon.

Khan and Gammoh operated United Aircraft & Electronics in Anaheim, which Type: bought

and sold aircraft parts. The indictment alleges that Khan and Gammoh issued a series of

false certifications and other writings that represented that the accompanying parts were

something they were not.

Summary:

For example, the indictment alleges that United Aircraft sold Bell Helicopter grip

assemblies, a helicopter part that attaches the tail rotor to the rotor hub, after Khan and

Gammoh altered the grip assemblies by removing and replacing data plates. The grip

assemblies were then shipped with the new data plates and accompanying certifications

that represented that the parts were steel when in fact the parts were aluminum.

The indictment also alleges that United sold used jet engine parts called turbine blades,

representing the parts as new. Khan and Gammoh allegedly sold these turbine blades as

new even though they knew that the parts were used, that they bore counterfeit Pratt-

Whitney stamps and that they were packed in counterfeit Pratt-Whitney packaging.

Many of the parts sold by United Aircraft were flight-critical parts. False representations

about these parts could lead to improper maintenance or installation of the parts,

threatening the safety of any aircraft on which the parts were installed.

An indictment contains allegations that a defendant has committed a crime. Every

defendant is presumed innocent until and unless proven guilty beyond a reasonable

doubt.

If they are convicted of all 10 counts in the indictment, Khan and Gammoh each could

be sentenced to as much as 140 years in federal prison.

This case was investigated by the Department of Transportation, Office of the Inspector

Defense Criminal Investigative Service

Press Release

The Office of the Inspector General (OIG), Department of Defense (DoD),

announced today that on April 4, 2002, Amanullah Khan, a.k.a. "Wali

Merchant," was arrested subsequent to being indicted on April 3, 2002, by

a Federal grand jury within the Central District of California, Santa Ana,

CA. Fellow defendant, Ziad Jamil Gammoh, a.k.a. "Al Gammoh,"

voluntarily surrendered himself through his attorney on April 4, 2002, in

lieu of being arrested. The April 3, 2002, indictment charged each Khan

and Gammoh with one count of alleged conspiracy and nine counts of

allegedly misrepresenting material facts regarding the sale of aircraft parts

in violation of the Aircraft Safety Act of 2000.

On April 4, 2002, both Khan and Gammoh appeared before Judge Mark L.

Goldman for their initial bond and detention hearing. Judge Goldman

remanded Khan into custody until April 9, 2002, at which time he

intended to hear arguments regarding further detention and/or the level of

bond required upon Khan's supervised release. Judge Goldman ordered

Gammoh's supervised release, but set bond at $200,000. Judge Goldman

also prohibited Gammoh from engaging in any activities or employment

related to the manufacture and/or sale of aircraft components

The arrests of both Khan and Gammoh were the result of an investigation

that disclosed that Khan and Gammoh, while operating a company called

United Aircraft & Electronics (UAE), Anaheim, CA, allegedly made false

representations to various civilian and military customers, related to a

variety of aircraft components. Some of those aircraft components have

been determined to be potentially critical to flight safety. The

misrepresentations allegedly included the following: selling used or

surplus parts while representing the parts to be newly-manufactured;

selling used or surplus parts and supplying UAE's customers with altered

and/or counterfeit certificates of conformance (CoCs); intentionally selling

inferior or nonconforming parts; and misrepresenting to UAE's customers

claims about the company's manufacturing and quality assurance

capabilities. The investigation indicates UAE has done several million

dollars in business since the company's formation in February 2000, much

of that business conducted directly or indirectly with the U.S.

Government.

Aircraft Parts Owner Jailed for Violating Pretrial Order Regarding SUPs

Date: May 22, 2002

Investigation

Aman Kahn, also known as Wally Merchant, owner of United Aircraft and

Electronics, in Anaheim, CA, was arrested for a second time, in this

instance for violating a pretrial order not to conduct business concerning

the manufacture and sale of aircraft parts. Kahn was first arrested on April

4 for selling and distributing suspect unapproved aircraft parts used in

civilian and military aircraft. He was free on $1 million bail after being

jailed by a U.S. District Court judge in Santa Ana, CA, on charges

involving the alleged falsification of aircraft parts certifications. A thirdparty

defense contractor notified OIG special agents that Kahn sold them

unapproved lenses for a weapon system on U.S. Air Force F-15 fighter

aircraft. Kahn is now in jail, where he will remain until his scheduled trial

date of February 3, 2003.

The investigation also disclosed that Khan had

previously been convicted during the early 1990s and

served time in Federal prison for prior crimes involving

Defense contracting fraud and tax evasion. As a result of

that earlier conviction, the U.S. Air Force, in March

1995, officially debarred Khan from contracting with the

U.S. Government until July 21, 2010.

If convicted of conspiracy, Khan and Gammoh each face

fines of up to $250,000 and 5 years in prison. If

convicted of violating the Aircraft Safety Act of 2000,

Khan and Gammoh each face fines of up to $500,000 and

prison terms up to No. 15 years of Debar for each Transactions count. : 1

The investigation is being conducted jointly by the

Name: Defense Criminal Investigative United Service Aircraft (the& criminal Electronics, I

Class: investigative arm of the Firm OIG, DoD), the Federal Bureau

of Investigation, and the U.S. Department of

Exclusion Transportation. Type: Assistant Reciprocal U.S. Attorney Douglas F.

McCormick, Central District of California, Santa Ana,

Address:

1140 North Kraemer Ave, Anah

CA, is handling the prosecution.

Action The Date: point of contact regarding 16-OCT-2002 this press release is Chris

D. Hendrickson, Group Manager (GM), Western Field

Term Date:

07-JUL-2052

Office, Mission Viejo, CA. GM Hendrickson can be

contacted at (949) 643-4441, extension 223.

To report suspected fraud, waste and abuse within DoD

programs, contact the Defense Hotline toll-free at (800)

424-9098, e-mail at hotline@dodig.osd.mil or visit them

on the World Wide Web at

http://www.dodig.osd.mil/hotline.

-End-

19


H-53 Fluid Passage (Shoulder) Bolt

(Navy “D” Models & AF “J” Models)

H-53D Head SubAssembly

P/N 65111-07001-101

“This part is critical and needs to be made correctly. The part was not

made correctly and the H-53 FST is writing a bulletin to remove these

from service. … It is a concern and a bulletin is being prepared or has

been prepared to inspect for nonconforming bolts by manufacturer. We

are not going to play what if games or make different assumptions if the

bolts will or will not fail because of the nonconformances. If a bolt fails to

retain one tail rotor blade, the imbalance will rip off the tail rotor and tail

rotor gearbox and the aircraft goes into uncontrolled flight. Catastrophic

(category I) failure consequence: LOSS of aircrew/aircraft. We do not

want to make some assumptions about failures or not failing when the

consequences are catastrophic.”

20


21

AV-8B Butterfly Valve Gasket

Problem (April 2000):

• Gaskets Used in Reaction Control System

– 2 MAG-13 Failures

• 1 Detected Because of Fire Warning Light and

Other During Recurring Inspection

– No Evidence That Manufacturer Was

Approved/Qualified

• Wrong Material in 1 out of 3 Contracts

• Bulletin Issued -

– Visual Inspection .. Replace Within 1 Year

– Purge Inventory

“The one part of this issue that really crumbles my

cookies is that this appears to be the same vendor who

made other bad gaskets a couple years ago. We had

to purge the system then too. It appears that DLA

has gone right back to the same vendor. We just

don't have the resources to address the same problem

twice (nor the intestinal fortitude). … now, the AV8B

program has to wrestle with how to purge the system

and more importantly, our aircraft, of this "bad"

batch of gaskets. We'll continue to work that issue

with our program guys and I think there are ways to

mitigate our impact. We don't have a huge safety

problem here but it has to be fixed soon. It makes a

lot of extra work for our engineers and, especially, the

squadron maintenance guys who are already

overworked.


H-46 AFCS Piston

(P/N 114H4402-1 )

22

Used In Automatic Flight Control System (AFCS)

• 1 Unapproved Source For Piston

• 2400+ Items (1995-1997)

• Failed 19 Dimensional &

Surface Finish Characteristics

• Potential Seal Leakage

• Defects - Non “Flight Critical”

• AFCS Can Be Powered or Not

• Maintenance Burden

• PQDR Issued

• Screened Assets For 2-Year Supply

• Returned Remainder


Carbon Dioxide Fire Extinguishers

(NSN 4210-01-419-5562, P/N BBE2879A & BBE2879-1-A)

Problem:

• 9 CO2 Fire Extinguishers leaking at valve head

– Swollen O-rings & foreign material debris on

valve head seating surfaces

– Same Manufacturer … Poor Quality Control

Risk Assessment:

• In-flight Fire Occurrence Requiring a Portable

bottle - Both Bottles Have Low Charge

• Severity - Combination of Events … Catastrophic

• Probability - Combination of Events … Improbable

Actions:

• Bulletin (AYB 1093 TD, 06 JUN 05)

– Find & Replace Buckeye Fire Equipment Co.

Extinguishers with Metalcraft extinguishers

(NSN 4210-01-495-7617)

• Interim Rapid Action Change Notice:

– Remove P/Ns BBE2879-1-A & BBE2879A

From Tech Manuals - Incorporate Metalcraft

Fire Extinguishers Part Number 132-008

• Cancel NSN 4210-01-419-5562

Valve Head

seating surface

Application: All Navy H-60s

Compliance:

• Inspection: Next 28 days

• Remove/Replace: Next 175

flight hours after inspection

23


Army H-60 Planetary Carrier

“Hasn’t Failed Yet” … “Will Never Fail”

“Hasn’t Failed Yet”…

• Catastrophic Consequences Well

Understood, but because

• Low Failure Probability

• Tens of Thousands Hours of

Failure Free Use

• FSP/CSI Not Coded

“Will Never Fail” …

• CAT 1 QDR … Low Main

Transmission Oil Pressure

• CCAD Teardown Revealed

Cracked Planetary Carrier

• Abnormal Gear Loads

Damaged Internal Shim

• Shim Pieces Into Sump &

Clogged Filter

• 2 nd Failure Detected by

Subsequent Inspection/Teardown

• 2+ Year Engineering Investigation

• Poor Traceability/Tracking

“Although in this instance the failure was detected

prior to loss of main rotor drive, future planetary

carrier failures may not provide an impending

failure indication. If undetected, this failure mode

could result in loss of drive to the main rotor shaft,

which could result in loss of aircraft and/or

injury/death of crew. (Hazard Severity –

Catastrophic).”

(Army Risk Determination memorandum)

24


Aircraft Launch & Recovery Equipment

NSN: 1720-00-

476-0009

Water Brake

choke ring

Failed NDI

inspection…..

Cracks

3020-01-031-4008

chain assy. For

CROV. Made with

Cotter pins that

Break/fall out.

1720-00-151-4355

SEAL ASSY

Made and

assembled wrong

25


T64 Compressor Assembly Shouldered Studs

(P/N 4026T91 … NSN 5307-00-151-9238)

Waspaloy Req’d

Hastalloy Provided

Contract:

Correct Spec & Drawings cited

Critical Item – Source Inspection Req’d

Critical Application Item

26


C-130 Rigid Flap Actuator Connecting Link

P/N 340188-4, NSN 3040-00-096-4861

Low Hardness, Not Re-Heat Treated After Welding

Banking and Community Perspectives

Issue 1, 2001

Federal Reserve Bank of Dallas

http://www.dallasfed.org/ca/bcp/2001/bcp0101.html

E-Commerce Resource Centers

Theresa Chavez knows the benefits of e-commerce and the San

Antonio Electronic Commerce Resource Center. In 1991,

Chavez, her husband and brother-in-law started High Quality

Machine Shop in southwest San Antonio with two Air Force

contracts for airplane hardware. But the business struggled

with only eight full-time employees, and Chavez soon realized

the company needed greater operating efficiency—and more

business.

Five years ago, she heard about the San Antonio center's

services. With the help of several classes and one-on-one

technical assistance, Chavez's company now relies on the

Internet for securing government contracts. Today, the

machine shop has contracts with seven Air Force bases.

Chavez employs 16 people full-time and has doubled her

revenues, from $600,000 in 1991 to more than $1.2 million last

year. None of this would have been possible, she believes,

Defective Weld


E-2/C-2 Hydraulic Tubing

From: XXXXXX CIV NAVAIR

Sent: Friday, June 18, 2004 7:21

To: YYYY CIV NAVAIR 4.X.X

Subject: RE: Tube material from PPPPPP,

From: ZZZZ CIV NAVAIR DEPT

Sent: Tuesday, February 01, 2005 15:26

To: YYYY CIV NAVAIR 4.Y.Y

Subject: FW: PPPPPP

Below this email are the documents that the tubing was ordered

on. AAA is replacing the tubing we bought from them. BBBB states

that PPPPP should be responsible since they sold the defective

Firstly, the tubing material and hardness

where fine. They met exactly what they were

supposed to. The problem is from the drawing

process on the inside surface of the tubing.

It appears that the drawing process has

caused smeared streaks on the inner surface.

These become stress risers that lead to

premature failure. The smearing may be

caused by worn or dirty tooling, or the tube

being improperly annealed between the draws.

Either way, the defects are measurable, and

are below the MIL spec standard for surface

anomalies in high pressure tubing.

Attached are three photos taken under low

power optical microscopy. These are from 28 one


Critical Safety Item

H-53 Tailrotor Gearbox Bolt

29

4 Bolts Retain Tail Rotor Gearbox

• Improper Approval of Design Change

• Grip Length + Thread Length

Shortened ~ ¼”

• Only 1 Complete Thread Protruding

• Bolt Head Was 9/16” vs 5/8”

• 500 Bolts Purchased

• 223 In Supply Inventory … Purged

• Urgent Replacement Order

AF and NAVAIR Bulletins Issued

• Navy CH-53D AFB 311

• AF MH-53J/M ITCTO 947

• Grounding Not Warranted

• 25 Flight Hour … Inspect, Remove,

& Replace Unapproved Bolts

• 4 MH/Aircraft + 4 Shear Bolts


30

M/R Blade Expandable Pin … Army UH-60

Crack

Initiation

points


Jet Blast Deflector

31

JBD Module … P/N 422439-5 (NSN 1720-01-220-4591)

• 9 Quality Deficiency Reports … 3 years


EA-6B Flaperon Hollow Pin

P/N 1128CM42207-13 -- NSN 5315-01-240-7559

“VAQ-139 WAS UNABLE TO REMOVE WORN PIN

ATTACHED TO FLAPERON AND AS SENT TO WORK

CENTER 51A FOR REPAIR. UPON REMOVAL OF PIN

THE TECHNICIAN NOTICED PIN WAS TOO SOFT OF

A MATERIAL. AFTER TESTING THE PIN FOR

HARDNESS TESTING THE RESULTS SHOWED AN

ROCKWELL OF 10 INSTEAD OF ROCKWELL 39-45 OF

410 STAINLESS STEEL. THIS IS IAW GRUMMAN

PRINT FROM NATEC (GAC515 REV 21076 200M REV

076)”

Engineering Investigation: RCN N44329-04-0445, 23 Dec 04

PIN, HOLLOW P/N 1128CM42207-13 NSN 5315-01-240-7559

Contract# Clin CAGE SOURCE Date Unit Price Quantity Total Price

SP050003AB3120231 0001 5U074 DISC 2003-08-04 5.63 380 2,139.40

SP050003AB3120102 0001 5U074 DISC 2003-02-12 6.78 195 1,322.10

SP050002AB3523585 0001 1DAF1 DISC 2002-05-15 12.08 129 1,558.32

SP050000AA5711103 51792 DISC 2000-04-26 17.44 120 2092.80

SP054000MG441 66841 DISC 2000-03-22 11.25 125 1,406.25

SP050099AA6280715 06329 DISC 1999-05-28 20.45 100 2045.40

SP050098AB2181130 023T7 DISC 1998-08-26 21.50 100 2,150.00

SP050098AB2180183 023T7 DISC 1997-11-14 24.95 100 2,495.00

SP050096W4193MODF 5U074 DISC 1996-08-29 10.30 130 1339.00

DLA50093AA8610304 65811 DISC 1993-01-11 16.30 48 782.40

DLA50093AA8610305 65811 DISC 1993-01-11 16.30 134 2,184.20

DLA50093M8778MODF 5U074 DISC 1992-12-09 6.42 130 834.60

DLA50090MR046MODF 65777 DISC 1990-07-04 18.70 90 1683.00

DLA50090AA8610281 65811 DISC 1990-02-03 20.85 100 2085.00

DLA50090AA8610282 65811 DISC 1990-02-03 30.85 30 925.50

DLA50089W7337MODF 8N056 DISC 1989-05-03 17.75 38 674.50

32


Aircraft Launch & Recovery Equipment

Discovered during receipt inspection by Lakehurst….

• Terminals, Poured

Type 1-7/16” Diameter

Cable p/n 421404-1 Rev L

Problem: Magnetic

Particle Inspection

Indicates cracks……..

Undersized CSV

stem…. Not to spec.

CSV not indicate properly

LLLV body bushing

p/n 523891-1…too soft

for use…could bind the

LLLV on launch

33


H-60 Pushrod Rod End

34

• Problem: Rod Ends purchased from 4

unqualified sources (vast majority from

AGH Industries … 65 from Laumann Mfg

(convicted of fraud)).

• Location: 5 rod ends per aircraft. Four

connect torque shafts to pilot assist

servos. One connects yaw trim assy to

mixer assy.

• Failure Consequence: Loss of flight

control in affected channel

• Action: Expedite 1st Article Test (FAT)

on AGH Rod End for source approval &

conduct similar testing on 5% of spares.

Engineering review of existing inspection

requirements, rod end loading, reliability of

AGH rod ends to date, & AGH

qualification for similar H-1 parts, combine

to suggest that continued ops are safe in

interim. Perform Risk Assessment on

Laumann parts.

• Status: AGH rod ends determined to be

acceptable. Review of Laumann FAT

reports indicate minimal risk.

Mixer

Rod

Ends


H-3 Main Gearbox

(P/N 61350-24000-044/-045 … NSN 1615-01-331-5451/5450)

35

1997 Statement of Work:

For contract N00383-97-D-008G

Only Navy and OEM approved sources

allowed.

If unable, contact ASO for additional source.

Bracket Assy P/N S6135-20249-1

SPAR bought from ROTAIR

ROTAIR from S&S Precision

S&S not on approved source list


36

Critical Safety Item

H-1N & UH-1 Turnbuckles

• Main Rotor Pitch Change Link Assembly

• All “H-1 Series” Helicopters

• Thread Diameter is Critical

• Nonconforming Threads From 2 Manufacturers

• CAGE Code & Serial Number To Be Vibra Etched

• Multiple Suppliers “Ink-Stamped” or Did Not

Mark

• Army Safety of Flight Message & Navy Dynamic

Component Bulletin Issued

• Replace Parts Not Identifiable To Approved

Sources

• Remedial Costs … 6 MH/Aircraft + 2 Turnbuckles

+ Inspection Pin Gauge


H-46 Self-Locking Castellated Nut

(MS 21224-5)

Pilot & Copilot Cyclic Control Stick

• Common Nut Used in Various Applications

• On H-46 … Primary Use Is In Flight Control Systems

• Pilot & Copilot Cyclic Control Stick

• Assembled On Self-Retaining Bolts

• Installation Difficulties (Aug 2000)

• Engineering Analysis:

• Nuts W/Green Inserts Had Partial/1 Complete Thread

• All Others Had 2 ½ - 3 Threads

• Acceptable Material and Hardness

• 108,000 MS 21224-5 Nuts Procured Since 1987

• 22,000 From Source That Used Green Inserts

• Not All Deficient

Conforming Nut Discrepant Nut

2 1/2 Complete

Threads

Only 1 Complete

Thread

37


Propeller Bolts … C-12, T-34, T-44

(P/N B3339)

Lot 12

Screened Stock For Lot 56 Replacement

• Incomplete Machining

• Improper Plating & Pitting

• Head Not Perpendicular to Shaft

Lot 56

Bolt Head Yielded Upon Torquing

• ~ 4% - Improper Heat Treatment

• Hardness 13-15 HRC vice 39-45

38


Critical Safety Item

EA-6B Ejection Seat Drogue Gun Tip Rod

39

• Improper Painting …False Indication of Partial Seat Activation

Correct

Incorrect


CSI Deficiency Tracking

in NAMDRP

40

CSI Indicator

61 CAT I CSI PQDRs

323 CAT II CSI PQDRs

418 EI/HMRs on CSIs


CSI Timeline

Competition in

Contracting Act

Of 1984

10 USC 2319

(Qualification

Amended)

Defense

Authorization

Act of 1989

10 USC 2383

(Critical Parts)

Enacted

1992 1993

Federal

Acquisition

Reform Act

of 1996

10 USC 2383

(Critical Parts)

Repealed

Aviation

Safety Act

Of 2000

NAVAIR

Instruction

&

JACG

Guidance

On CSIs

18+ NAVAIR

Bulletins

Issued

On CSIs

DoD

4140.1-R

JALC

Handbook

SECNAVINST

5000.2C

DoD

Acquisition

Guide

Defense

Authorization

Act of 2004

Sec 802

Defense

Appropriation

Act of 2004

Sec 8143

Joint CSI

Instruction

DFARS

Rules

QPL

Policy

1984 1988

1996

1999

2000

2002

2003

2004

2006

Imperial Tooling

Protest

(UH-1 Yoke)

Silco Engineering

Protest

(F-16 Brake Pistons)

Phaostron Instrument

Protest

(Pressure

Indicators)

41


42

Phaostron Instrument & Electronic Company

(GAO B-284-456, 2000 CPD P 65)

• Background:

– Qualified Products List (QPL) For Critical Pressure Indicators

» 2 Firms Listed on QPL … Phaostron Was Listed

– DSCR Contract Award to Unlisted Firm (AIC) in November 1999

» Determined AIC Was Qualified And Should Be Added To QPL

– Phaostron Protested Award As Improper

• GAO Determination (April 20, 2000):

“… applicable statute, 10 U.S.C. 2319 (1998) is designed to encourage

competition … by providing prospective offerors an enhanced

opportunity to have their products qualified prior to award of a

contract. To that end, the statute affords contracting officers the

authority to find that a product meets (or will meet) a qualification

requirement by the time of contract award, regardless of whether

the item is listed on the QPL (10 U.S.C S 2319(c)(3); FAR 9.202(c).

Nothing in statute limits the contracting officer’s authority to

approve a product for a procurement based on whether the

product has been tested or approved by a particular entity.”


10 U.S.C. 2319 (pertains to qualification req’ts after Oct 19, 1984):

a) “… qualification requirement means a requirement for testing or other

quality assurance demonstration that must be completed by an offeror

before award of a contract”

b) “… The head of the agency shall, before establishing a qualification

requirement:”

1) Prepare written justification

2) Make all qualification requirements available to offers … limited to

least restrictive to meet purposes

3) Estimate costs of testing & evaluation

4) Prompt opportunity to demonstrate ability

5) If testing provided under contract, use contractor not expected to

benefit by results

6) Advise offerors of results promptly

c) ((3) “A potential offeror may not be denied the opportunity to submit and

have considered an offer … if the potential offer can demonstrate to the

satisfaction of the contracting officer that the potential offeror or its

product meets the standards established for qualification or can meet

such standards before the date specified for award of the contract”.

(d)(2)(f) “Except in an emergency as determined by the head of the agency,

whenever the head of the agency determines not to enforce a

qualification requirement for a solicitation, the agency may not therafter

enforce that qualification requirement unless the agency complies with

the requirements of subsection (b).”

43

10 U.S.C. 2319

“Encouragement of New Competitors”


Critical Safety Items (CSI)

Law, Regs, Policy, & Guidance Overview

Acquisition Reg

DFARS Case 2003-D101

Final Rule 9/05

Contract Req’s

Joint CSI Instruction

Multiple Policy #s

(SECNAVINST 4140.2)

25 Jan 06

Life-Cycle Management

JALC CSI Handbook

Signed 12 Aug 05

Common Procedural

Guidance

CSI “FAQ”

Industry Coord 1/06

Plain English Q&As

Public Law

P.L. 108-136 Sec 802

FY04 Authorization

Acquisition Reg

DFARS Case 2004-D008

Proposed Rule 8/05

Defect Notification

Specification Policy

DoD 4120.24-M

Revised 6/05

QPL Req’s

CSI Data Viewer

In-Process

Shared CSI ID & Source

Data

Public Law & OSD Report

P.L. 108-87 Sec 8143

FY04 Appropriations

Mat’l Mgmt Reg

DoD 4140.1-R, C8-5

5/03

Top Level Supply Req’s

DoD 5000 Acquisition

Desktop Guide

11/04

Top Level Awareness

Deficiency Tracking

Initiated

Quality Reporting

44


QUALITY CONTROL IN PROCUREMENT OF AVIATION

CRITICAL SAFETY ITEMS AND RELATED SERVICES.

(P.L. 108-136, Sec 802 … FY 2004 National Defense Authorization Act)

(a) QUALITY CONTROL POLICY.—The Secretary of Defense shall prescribe a quality control policy for the

procurement of aviation critical safety items and the procurement of modifications, repair, and overhaul of such items.

(b) CONTENT OF POLICY.—The policy shall include the following requirements:

(1) That the head of the design control activity for aviation critical safety items establish processes to identify and

manage aviation critical safety items and modifications, repair, and overhaul of such items.

(2) That the head of the contracting activity for an aviation critical safety item enter into a contract for such item

only with a source approved by the design control activity in accordance with section 2319 of title 10, United States

Code.

(3) That the aviation critical safety items delivered, and the services performed with respect to aviation critical

safety items, meet all technical and quality requirements specified by the design control activity.

(c) DEFINITIONS.—In this section, the terms ‘‘aviation critical safety item’’ and ‘‘design control activity’’ have the

meanings given such terms in section 2319(g) of title 10, United States Code, as amended by subsection (d).

(d) CONFORMING AMENDMENT TO TITLE 10.—Section 2319 of title 10, United States Code, is amended—

(1) in subsection (c)(3), by inserting after ‘‘the contracting officer’’ the following: ‘‘(or, in the case of a contract for

the procurement of an aviation critical item, the head of the design control activity for such item)’’; and

(2) by adding at the end the following new subsection:

‘‘(g) DEFINITIONS.—In this section:

‘‘(1) The term ‘aviation critical safety item’ means a part, an assembly, installation equipment, launch equipment,

recovery equipment, or support equipment for an aircraft or aviation weapon system if the part, assembly, or

equipment contains a characteristic any failure, malfunction, or absence of which could cause a catastrophic or

critical failure resulting in the loss of or serious damage to the aircraft or weapon system, an unacceptable risk of

personal injury or loss of life, an uncommanded engine shutdown that jeopardizes safety.

‘‘(2) The term ‘design control activity’, with respect to an aviation critical safety item, means the systems

command of a military department that is specifically responsible for ensuring the airworthiness of an aviation system

or equipment in which the item is to be used.’’.

45


Quality Control of Aviation Critical Safety Items

Final Rule DFARS Case 2003-D101

(30 Sept 2005 Federal Register)

46

DFARS 209.270 Aviation critical safety items

– Contracting activity contracts only with approved sources

– Design Control Activity …

• Identifies Aviation CSIs

• Approves Qualification Requirements for Aviation CSIs

• Qualifies & Identifies Approved CSI Sources and Products

– Contracting Officer …

• Ensures Design Control Activity Determines Acceptability of

Prospective Source & Product Prior To Contract Award Date

• Refer Offers from Unapproved Sources to Design Control Activity

• Refer Qualification Request to Design Control Activity

DFARS 217.75 Acquisition of Replenishment Parts

– Competition may be limited to original manufacturer or other qualified

sources where justified

DFARS 246.407 (S-70) … Nonconforming Supplies or Services

– Approval by Design Control Activity --- May Delegate Minors

DFARS 246.504 Certificates of Conformance …

– Design Control Activity Concurrence Before Issuance


DoD 4140-1R (23 May 2003)

DoD Supply Chain Mat’l Management

47


DoD 4140-1R (Cont)

(pages 156-161)

48


49

Joint Service/Agency CSI Instruction

(SECNAVINST 4140.2, AFI 20-106, DA PAM 95-9,

DLAI 3200.4, DCMA INST CSI(AV) … 33 pages)


• Approved Sources

– System/Subsystem Prime/OEM/Suppliers to Prime & OEM

– Fully Licensed Manufacturers/R&O facilities of Prime or OEM

– Dealers/Distributors of Prime With Acceptable Traceability

– Sources Listed on Source Controlled Drawings, QPLs, CIPRDs

– Alternative Sources Approved By ESA (Service Reciprocity)

• Organic Manufacture is Treated as Alternate Source

50

Joint Service/Agency CSI Instruction

• All DoD Aviation Programs, Except:

– FAA Certified/Maintained Aircraft/Equipment

– FMS Not in Active DoD Inventory/Customer Declines

• Engineering Support Activity (ESA) Determines

Criticality

• Failure Consequence is Primary Driver

• Highest Determination For Common-Use Items

– Whether/When To Update Legacy Drawings

– Approved Alternate Sources of Supply

– Serialization/Distinguishing Marking Requirements

– Material Review Board (MRB) Delegation


• Disposal

– Mutilate Defective, Life Expended, Unreliably Documented CSIs

51

Joint Service/Agency CSI Instruction

• Approval Conditions

– First Article Testing, Production Lot Testing, Site Visit, Process

Documentation, Procurement/Quality History

• Can Be Waived by ESA

– 3-Year Alternate Source Re-Evaluation, but

Quality Problems & Design/Mfg Changes Trigger Review

– Non-FAA Certificate Holders Are Not FAA Approved

– Surplus Offers Require Approval

– Local Purchase if Urgent, Compelling, & ESA Approved

Quality

– ECPs, Waivers, & Deviations Approved by ESA

• Delegation of MRB and Class II ECPs by ESA

– Government Contract QA Required

• Certificates of Quality Conformance When ESA Approved

– Reverse Engineering When ESA Approved

– “Make It Fit/Make It Work” When ESA Approved & Documented

– Discrepancy Reports on Quality Deficiencies


JALC Aviation CSI Handbook

12 August 2005

52


JALC Aviation CSI Handbook

12 August 2005

TABLE OF CONTENTS

Section 1 Introduction...........................................................................................................

Section 2 DOD Critical Safety Item and Critical Characteristic Identification Criteria.......

Section 3 CSI Common Use Item Coordination Process......................................................

Section 4 CSI Management Controls....................................................................................

Section 5 CSI Data Management..........................................................................................

Section 6 Manufacturing Source Approval Request (SAR) Content and Processing..........

Section 7 Source Management..............................................................................................

Section 8 Management of Repair, Overhaul, Maintenance, and Modification (ROMM) of

Aviation Critical Safety Items (CSIs)...................................................................

Section 9 Vendor Surveys.....................................................................................................

Section 10 Government Manufacturing of Critical Safety Items.........................................

Section 11 Reverse Engineering...........................................................................................

Section 12 Training...............................................................................................................

Section 13 Contract Requirements........................................................................................

Appendix I Joint Service CSI Instruction.............................................................................

Appendix II Acronyms .........................................................................................................

EXHIBIT A Points of Contact..............................................................................................

EXHIBIT B Critical Safety Item Critical Characteristics Checklist ....................................

EXHIBIT C Critical Manufacturing Process List.................................................................

EXHIBIT D Common Use Item Coordination Sheet And Instructions ...............................

EXHIBIT E Manufacturing SAR Review Checklist............................................................

EXHIBIT F CIM Websites...................................................................................................

EXHIBIT G Sample QALI Critical Items (w/instructions)..................................................

EXHIBIT H Manufacturing, R&O, and QA Site Survey Checklist.....................................

EXHIBIT I DCMA Pre-award Survey Request Form (SF1403)..........................................

EXHIBIT J Standard DoD Quality Clauses for Aviation CSIs............................................

EXHIBIT K Questionnaire for Companies Relocating Manufacturing Facilities................

EXHIBIT L Checklist for Surplus Procurements.................................................................

EXHIBIT M Addendum to FAR 52.212-4 Commercial Contract Terms and Conditions...

53


Notification Requirements for Critical Safety Items

DFARS Case 2004-D008 - Synopsis

(Comments Being Dispositioned)

• Contractor to notify PCO and ACO of nonconformances to:

– Replenishment parts identified as CSIs

– Systems, subsystems, assemblies, etc that impact safety

– Repair, maintenance, logistics, or overhaul that impact safety

• Notification within 72 hours after discovery/receipt of credible

information of situation

– Summary

– Chronology

– Potentially affected systems

– POC

– Other relevant info

• Flow down to Subcontractors

– Prime contractor responsible for notification

• Subcontract to provide notice to higher contractors

• Concurrently notify PCO/ACO if known to Subcontractor

• Facilitate communications between Gov’t and Sub

• Neither Admission of Responsibility nor Release of Liability

54


F/A-18 REPEATABLE RELEASE HOLDBACK BAR

Primary Lock Segment (PLS)

As the Catapult Officer returned my salute, I positioned my left

hand on the throttle and my right hand on the canopy bow handle

(towel rack). Looking down the catapult track, I kept the green

shirt that was going to press the catapult-firing button in my

peripheral vision. I felt the holdback fitting release as the button

was pushed; however, the sensation of the normal catapult

acceleration was absent. I instantly knew that I had suffered either

a "cold cat" or hold back fitting failure. Selecting ground idle with

both throttles, I threw the arresting hook down and stood on the

break pedals as if my life depended upon it. My Hornet stopped

accelerating down the cat track, but it was still sliding towards the

forward edge of the deck. In a final attempt to stop before pulling

the ejection handle, I drove the right rudder pedal down in an

effort to ground loop the aircraft. The jet rotated 90 degrees to the

right and continued to skid down the angle. I was now staring

straight at aircraft 310 on Cat #2 with both main mounts stuck in

the greasy cat track offering no friction whatsoever. The aircraft

finally came to rest with the port main mount a mere 15 ft from

the deck edge, and I was looking at nothing but water under my

left wingtip Lt. Smith VFA-83

PRIMARY LOCK SEGMENT

F/A-18 C/D RRHB FROM

CV 67, SN 0658

- E/Fs - 24 Chipped PLS

- A-Ds – 35Chipped PLS

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