Peter wrote:
So every screw, washer and nut needs this?
Sure, screws, washers and nuts are in a package. Paperwork comes with it. P/N and batch number on paperwork and package, done??
Now I would like to know how most of my panel was assembled in the factory with mostly secondhand avionics with intermittent faults. This of course didn’t happen, because it is impossible, because everything had an EASA-1 form. So, this post was never typed, so anybody reading is only imagining they are reading it. It exists in a special section of the EuroGA database which holds postings which never existed.
The warranty bill in the first year was best part of £50k. Air Touring quite enjoyed it, Socata didn’t…
What this all demonstrates is that EASA and the companies that work under it’s approvals have robust procedures in place for component traceability and most reputabe companies will comply to the Nth degree. You can’t govern for those who choose to ignore the rules!
My AN and MS hardware for my Part 91 aircraft come out of a cabinet, some of them new, occasionally some used, no paperwork required. Just like the American inventors of AN/MS hardware, Part 91 private operations and the aircraft itself intended.
I think what’s otherwise being described for private aircraft in this thread can only be described as a nightmare, and deserves creative destruction.
My AN and MS hardware for my Part 91 aircraft come out of a cabinet, some of them new, occasionally some used, no paperwork required.
That is exactly what every maintenance/avionics shop I have ever visited does, even though the result is that traceability is not maintained for trivial items. Most shops will keep the paperwork straight for major stuff e.g. whole radios, and anything else in general maintenance that has a serial number (which is basically large items e.g. landing gear legs, elevators, etc). I am told that in Germany, at Annual, the shop pulls out all the avionics and checks the serial numbers on the stickers match the logbooks.
Very few general maintenance items have a serial or batch number. I have just bought the complete Annual parts kit for the TB20, plus extra bits which need doing, and not a single item has any numbering on it (serial or batch). But I have EASA-1 forms for the whole lot. These forms are clearly meaningless. All one can do is stick them in an envelope with “2017 Annual” written on it, but they cannot be matched with any item which is on the aircraft. The individual items come in plastic bags with tags inside but those tags are not serially numbered either, so nothing matches to anything. And this is a gold plated 145 operation. I mean, how can you have traceability for this
I know the intent of this traceability process, of course (I am not stupid so I won’t pretend to be) but what exactly does it deliver? Nothing – because it is trivial to circumvent. You could supply any number of the above bush, and use the same Form 1 every time.
It doesn’t matter whether it is an EASA-1 form or an 8130-3 (from EASA145 or FAA145 company, respectively) in that you could run the same scam with both, but there is a huge practical difference: in the FAA system you don’t need the Form 1 for most items, so you don’t get the situation which we have in Europe which is that “Form 1 = genuine and perfect item” with no further questions asked.
And if someone wants to know how the hell you will get a bogus (or simply defective) part from a known reputable aviation parts supplier… well the way it is done is the same way it is done every day with Amazon, electronics component distributors, you name it. You buy some genuine items from the company, and return them for credit/refund (not needed, wrongly ordered, etc). But the items you actually return are not the ones you bought 
That is how you get fake Windows installation DVDs (from a MS distributor), fake chips (from a franchised Hitachi distributor), etc.
You have exactly the same with ISO9000. If you are an ISO9000 company, you are automatically accepted as an approved supplier to most big companies (meaning, any company where the management has been stupid enough to let the QA manager to build an out of control empire) even if the product is crap. I have had 20 years of this at work.
Peter wrote:
I know the intent of this traceability process, of course (I am not stupid so I won’t pretend to be) but what exactly does it deliver? Nothing.
If only that were true… What is actually delivers with a responsible licensed mechanic is less quality through inane rigidity, work that cannot be performed as the mechanic knows it safely and properly could be, while wasting money that could otherwise be spent on something useful for the guy spending his hard earned money.
If you don’t control batch traceability (including where the parts have been issued to), then it’s difficult to deal with ADs concerning faulty components:
http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/AWD-CN/documents/CF-2014-38-E.pdf
This one is only against one aircraft type but several FAA ADs have been issued just covering a range of part numbers of nuts. If such an AD was issued and you had no tracking system, what would you do – change every nut on every aircraft that comes through your maintenance shop? It also doesn’t make and difference whether it’s a private aircraft or AOC (so Part 91, 121 or 135), you still need to be able to capture these problems if they arise.
What would you do, wigglyamp, in that case? It’s a locknut, a standard part, no markings. You could rely on your paperwork system, but if it was me I would just replace any I see. I am sure the client would agree. FWIW, I advise anybody with any damage to the elevator (especially its far corners) to NDT the elevator bearing brackets before any further flight.
That said, locknuts on the elevator hinge are not exactly the sort of part which would be fished out of a bin containing hundreds of parts going back to WW2…. Firstly, they are almost never changed. Secondly, if they are cheap (AN or MS) then why not just change them? You have to detach the elevator anyway to grease the elevator bearings at every Annual.
My point was that the MS21042 is a widely used standard part, not particular to the instance shown in that AD. So if your shop uses that nut, it could be on loads of aircraft types that you maintain. How would you address that if you had no traceability of the parts? In our business, we do have full trace from initial purchase (with manufacturer trace C of C) to each individual aircraft that the part’s been used on, and we’re both internally and externally audited against the requirement. Because we use bar-code scanning for issuing against job numbers, it’s a simple process to run a report and find where all of the bits from one batch of a standard part have been issued, just as we would do with serialised rotable components.
ADs generally consider the real world issue of their application, particularly if a public (i.e. owner) comment cycle is incorporated. I’m not familiar with MS21042 nuts in relation to MS21044 nuts but based on the AD text it appears there is a visual difference. So you just replace any MS21042 with new nuts. If I received that AD in the mail for my aircraft (as per FAA practice) I’d call an A&P friend, then do it myself in my hangar with nuts ordered through the mail, then have the A&P inspect it prior to his log book entry.
The idea of tracing the elevator nuts through paper records on an up to 70 year old aircraft (the Beaver was first flown just post war) is silly – for one thing all those records could have been lost and as long as the plane has current maintenance records there is no issue. Most of the people and shops who once worked on my aircraft are long since dead or out of business, and their records are also long gone.
