oversight

Improved Surveillance Needed Over Production of Critical Parts for Civil Aircraft

Published by the Government Accountability Office on 1971-02-25.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

    Improved Surveillance Needed
    Over Production Of Critical Parts
    For Civil Aircraft B         76449717)




    Federal Awatlon Admtnlstratlon
    Department of Transportation




    BY THE COMPTROLLER GENERAL
-   OF THE UNITED STATES
                                L
                      ”     *



             COMPTROLLER            GENERAL   OF   THE       UNITED     STATES
                                WASHINGTON     D C       20548




B- 164497(    1)




To the    President           of the Senate     and the
Speaker     of the         House   of Representatives

        This      1s our report     on the need for the Federal                          Avla-
tlon Admmlstratlon,          Department      of Transportation,                        to lm-
prove    surveillance      over production      of crltlcal     parts                   for
clvll  alrcraft        The review      was made    pursuant     to the                    Bud=
get and Accounting         Act, 1921 (31 U S C 53), and the                             AC-
countmg      and Auditing       Act of 1950 (31 U S C 67)

           Copies     of this report     are bemg    sent to the Director,
Office      of Management        and Budget,     the Secretary      of Trans-
portation,         and the Admmlstrator,        Federal    Avlatlon
Admmls        tratlon




                                                                       Comptroller     General
                                                                       of the United   States




              -       5OTH      ANNIVERSARY               1921-       1971                       -
                              Contents
                                                                         Page

DIGEST                                                                     1

CHAPTER

   1        INTRODUCTION                                                   4

   2        IMPROVED SURVEILLANCE NEEDED OVER PRODUCTION
            OF CRITICAL PARTS FOR CIVIL AIRCRAFT                           7
                Expanded productlon          surverllance     needed
                   for crltlcal     alrcraft      parts                    8
                Quality    control    systems approach would
                  benefit     expanded production         survell-
                   lance                                                  11
                Agency comments and our evaluations                and
                   conclusrons                                            14
                Recommendatron to the Admlnrstrator                       16

   3        SCOPE OF REVIEW                                               17

APPENDIX

        I   Letter   dated September 28, 1970, from the
               Department   of Transportation to the Gen-
               eral Accounting    Office                                  21

   II       Principal      officials      of the    Department  of
               Transportation         responsrble     for the ad-
               mrnlstratron         of activities     discussed  in
               this report                                                24

                                ABBREVIATIONS

FAA         Federal Avlatron       Admlnlstratlon
GAO         General Accounting       Office
PC          production   certificate
    COMPTROLLERGENERAL'S                          IMPROVED SURVEILLANCE NEEDED OVER
I   REPORTTO THE CONGRESS                         PRODUCTION OF CRITICAL PARTS FOR
                                                  CIVIL AIRCRAFT
I
                                                  Federal Aviation  Admlnlstratlon
                                                  Department of Transportation
                                                  B-164497(1)
I

I
    DIGEST
    ------
    WHYTHE REVIEW WASMADE
            The Federal Aviation    Admlnlstratlon       (FAA) 1s required         to prescribe
l           standards,  rules, and regulations        to promote flight        safety of clvll
I           aircraft.   Toward this end FAA promulgates            standards governing         air-
I           craft design, materials,    workmanship,        construction,       and performance.
I           It also provides surveillance        over manufacturers        which it certificates
I
I
            as capable of producing aircraft,         parts, and equipment.            These manu-
I           facturers  are commonly referred       to as production        certificate      holders
I
I
I            The General Accounting Offlce         (GAO) reviewed this surveillance           pro-
             gram because of the program's         significance  in assuring flight          safety
I
I
             of civil  alrcraft
I
I
I
I   FINDINGS AND CONC'LUSIONS
i
I            Certain parts critical      to the flight       safety of clvll       aircraft,      which
I            are furnished    by suppliers    to aircraft      manufacturers,       aIrline     com-
I
I            panies, and other aircraft       owners, generally        are not subJected to pro-
I            duction surveillance     by FAA or by the production           certificate       holders
             The parts not presently       under surveillance       are known as proprietary
             parts because neither      FAA nor the certificate         holders have design con-
             trol over them, and inspection        ordinarily      1s restricted        to verlflca-
             tion, at receiving     points,    that they function       properly          (See p. 8.)

I            FAA officials     in Washington had been aware of this lack of surveillance
             but had not determined the scope or magnitude of the problem.                   They in-
             dicated that some critical         aircraft parts classified       as proprietary
             parts, previously        not subJect to production   surveillance,       were under
             production    surveillance     at the time of GAO's review.
             In these instances the parts had been placed under surveillance        subse-
             quent to the occurrence of an aircraft     accident or incident   that had
             been caused by the malfunction    of the part      One accident had been fa-
             tal to the pilot of the aircraft.      (See p, 10 )

             In October    1967, FAA in-r-t-rated a comprehensive        program to reexamine,        on
             a one-time    basis3 the overall     quality control       systems of production

    Tear   Sheet
                                                                                                               I
                                                                                                               I
                                    l   -   c
                                                                                                               I
                                                                                                               I
     certlflcate    holders   The reexam7natlon,  however, d7d not Include                                     I
                                                                                                               I
     proprietary    parts not previously  under FAA surveillance.  (See p. 7.)                                 I
                                                                                                               I
                                                                                                               I
     In April 1970, shortly        before GAO completed its review,    the Aerospace                           I
     Industries      Association   of America, Inc ) agreed to undertake,     at FAA's                         I
     suggestion,      a study to evaluate    on a natlonal   basis the control over                            :
     critical     proprietary    parts    An FAA official  stated that the assocla-
     tlon's    study would be completed by the spring of 1971.         (See p, 10.)                            I
                                                                                                               I

                                                                                                           i
     Under the FAA's existing           program fan* productlon     surveillances      a number
     of standard conformity          inspections   are made covering        numerous manufactur-           I
     lng control    areas, such as heat treatment,           laboratory      testing,   and                I
                                                                                                           I
     metal surface treatment.             The FAA program provides      comparable levels                  I
     of production      surveillance       over the manufacturing      activities     of both              I
                                                                                                           I
     production    certificate       holders and their suppliers,        except for manufac-               I
     turing of proprietary          parts
                                                                                                           I

     Surveillance    coverage under this program            1s llmlted by the avallabll-                   ;
     lty and location     of FAA lnspectlon       staffs     and the continued    increase                 I
                                                                                                           I
     in the number of manufacturing        fac7'llQes        subJect to surveillance.                      I
     (Seep       11)
     One of the FAA regional      offices      has proposed that the production       sur-
                                                                                                       I
     veillance   be dlrected   or llmlted       on the basis of an evaluation      of the              I
     adequacy of manufacturers'        quality    control systems over critical       air-             I
     craft parts     GAO believes      that the proposed system could provide the                      I
                                                                                                       I
     expanded production     surveillance       capability     necessary to cover critical             I
     aircraft  parts, such as proprietary          parts, that do not now receive such                 I
                                                                                                       I
     coverage by FAA or by the production           certificate      holders.  (See p. 12 )            I
                                                                                                       I
                                                                                                       I

RECOMMENDATIONS
              OR SUGGESTIONS                                                                           I
                                                                                                       I

    The Administrator       of FAA should       provide    for                                         I

                                                                                                       I
       --Immediate    action to ensure that all critical            proprietary   aircraft             I
          parts are subJected to production        surveillance        by either FAA or                I
                                                                                                       I
          the responsible    production certificate        holders.       (See p. 14 )                 I

                                                                                                       I
       --Modlflcatlon    of the existing      production  surveillance       program to pro*
          vlde for greater reliance       upon the adequacy of production          certlfi-        I
          cate holders'   quality    control   systems as the basis for directing                  I
                                                                                                   I
          or limiting   FAA surveillance     over production      operations.                      I

                                                                                                   I
                                                                                                   I
AGENCYACTi-ONSAND UNRESOLVEDISSUES
                                                                                                   I
                                                                                                   I
    The Department of Transportation             advlsed    GAO that it was aware of the           I
    problems noted by GAO during its             review      The Department advised GAO            I

                                                                                                   I
                                                                                                   I
                                                                                                   I
                                                                                                   I
                                                                                                   I
                                                                                                   I

                                            2                                                      I
                                                                                                   I
                                                                                                   I
                                                                                                   !
      that, upon completion         in July 1971 of its overall           revlew currently
      In process, specific         procedures will be established            to ensure that all
      critical     proprietary     aircraft    parts will be subJected to production
      surveillance       and that FAA plans to place greater reliance              on the ade-
      quacy of production         certificate     holders'   quality     control  systems.     The
      actions planned by the Department,              if effectively      Implemented,    should
      improve the surveillance            over the production       of aircraft   and related
      aircraft     parts       (See p. 14 )

       GAO believes,    however, that, sfnce the Department IS aware that the
       production    of certain   parts cntlcal   to alrworthlness    of aircraft  IS
       not now under surveillance       and since in the past similar    parts have
       contributed    to accidents and incidents,    prompt action should be taken
       to bring the production      of such parts under surveillance


MATTERSFOR COiUSIDERflTIONBY TBE CONGRESS
       This report IS being issued to advise the Congress of the need for
       lmmedlate measures by FAA to implement production    surveillance      over
       cntlcal    proprietary aircraft parts and of the corrective      action being
       taken by FAA




Tear Sheet




                                             3
COMPTROLLERGENERAL'S                      IMPROVED SURVEILLANCE NEEDEDOVER
REPORTTO THE CONGRESS                     PRODUCTION OF CRITICAL PARTS FOR
                                          CIVIL AIRCRAFT
                                          Federal Avlat~on Admlnistratlon
                                          Department of Transportation
                                          B-164497(1)


DIGEST
------
WHYTHE REVIEW WASMADE
    The Federal Aviation    AdminIstratIon      (FAA) IS required      to prescribe
    standards,   rules, and regulations      to promote flight      safety of clvll
    aircraft.   Toward this end FAA promulgates        standards governing         air-
    craft design, materials,    workmanship, construction,          and performance.
    It also provides surveillance       over manufacturers     which It certlflcates
    as capable of producing aircraft,        parts, and equipment.         These manu-
    facturers  are commonly referred       to as production    certjflcate      holders.

    The General Accounting Office          (GAO) reviewed this surveillance            pro-
    gram because of the program's          slgnlflcance  in assuring flight           safety
    of civil  aircraft


FINDINGS AND CONCLUSIONS
    Certain parts critical       to the flight      safety of clv11 aircraft,              which
    are furnished    by suppliers     to aircraft      manufacturers,        airline     com-
    panies, and other aircraft        owners, generally        are not subJected to pro-
    duction surveillance      by FAA or by the production            certificate       holders.
    The parts not presently        under surveillance       are known as proprietary
    parts because neither      FAA nor the certlflcate          holders have design con-
    trol over them, and Inspection          ordlnanly     IS restricted          to verifica-
    tion, at receiving     points,     that they function        properly.         (See p. 8 )

     FAA offlclals     in Washington had been aware of this lack of surveillance
     but had not determined the scope or magnitude of the problem.                   They In-
     dicated that some crltlcal        aircraft  parts classified       as proprietary
     parts, previously        not sUbJeCt to production   surveillance,       were under
     production    surveillance     at the time of GAO's review

     In these Instances the parts had been placed under surveillance         subse-
     quent to the occurrence  of an alrcraft     accident or Incident   that had
     been caused by the malfunction   of the part        One accident had been fa-
     tal to the pilot of the aircraft        (See p. 10 )

     In October    1967, FAA lnltlated       a comprehensive      program to reexamine,            on
     a one-time    basis, the overall       quality  control     systems of production




                                            1
     certificate    holders   The ueexamlnation,  however, did not Include
     proprietary    parts not previously  under FAA surveillance.  (See p. 7 )

     In April     1970, shortly    before GAO completed its     review, the Aerospace
     Industries      Assoclatlon   of America, Inc , agreed to undertake,     at FAA's
     suggestion,      a study to evaluate    on a national   basis the control over
     critical     proprietary    parts.   An FAA off-rclal  stated that the assocla-
     tlon's    study would be completed by the spring of 1971.          (See p, 10.)

     Under the FAA's existing         program for production      surveillance,      a number
     of standard conformity        InspectTons   are made covering numerous manufactur-
     ing control   areas ) such as heat treatment,         laboratory      testing,   and
     metal surface treatment.          The FAA program provides       comparable levels
     of production    surveillance       over the manufacturing      activities     of both
     product-ron certlflcate       holders and their suppliers,        except for manufac-
     turing of proprietary       parts

     Surveillance    coverage under this program             IS llmlted by the avallabll-
     Ity and location     of FAA inspection       staffs      and the continued increase
     in the number of manufacturing       facilities          subJect to surveillance.
     (Seep       11)
     One of the FAA regional      offlces      has proposed that the productton        sur-
     veillance   be directed    or limited      on the basis of an evaluation        of the
     adequacy of manufacturers*        quality    control     systems over crltlcal    air-
     craft parts     GAO believes      that the proposed system could provide the
     expanded production     surveillance       capablllty      necessary to cover crrtical
     aircraft  parts, such as proprietary          parts, that do not now receive such
     coverage by FAA or by the production           certificate       holders.   (See p. 12 )


RECOMMENDATIONS
              OR SUGGESTIONS
    The Admlnlstrator       of FAA should      provide     for

       --Immediate action to ensure that all        critical      proprietary   aircraft
          parts are subJected to production      surveillance        by eTther FAA or
          the responsible  production certlflcate        holders.       (See p. 14 )

       --Modlflcatlon    of the existing     production  surveillance        program to pro-
          vtde for greater    reliance   upon the adequacy of production           certlfl-
          cate holders' quality control systems as the basis for directing
          or limittng  FAA surveillance     over productIon      operations.


AGENCYACTIONS AND UNRESOLVEDISSUES
    The Department of Transportation            advlsed     GAO that it was aware of the
    problems noted by GAO during tts            revJew.      The Department advised GAO




                                           2
    that, upon completion         in July 1971 of its overall           review currently
    In process, speclflc         procedures ~111 be established            to ensure that all
    critical     proprietary     aircraft    parts ~111 be subJected to production
    surveillance       and that FAA plans to place greater reliance               on the ade-
    quacy of production         certificate     holders'   quality    control   systems.     The
    actions planned by the Department,              if effectively      implemented,    should
    improve the surveillance            over the productIon       of aircraft   and related
    aircraft     parts.      (See p. 14.)
    GAO believes,    however, that, since the Department IS aware that the
    production    of certain   parts cntlcal   to airworthiness    of aircraft  1s
    not now under surveillance       and since in the past similar    parts have
    contributed    to accidents and incidents,    prompt action should be taken
    to bring the production      of such parts under surveillance.


MATTERSFOR CONSIDERATIONBY THE CONGRESS
    This report IS being Issued to advise the Congress of the need for
    lmmedlate measures by FAA to implement production    surveillance      over
    critical   proprietary alrcraft parts and of the corrective      actlon being
    taken by FAA




                                           3
                                       CHAPTRRl

                                    INTRODUCTION

         The General Accounting          Offlce has reviewed          the Federal
Aviation      Admlnlstratlon's        surveillance         program concerning
the production         of parts for civil         aircraft.        Cur review
evaluated      the effectiveness         of the existing         production    sur-
veillance      program In meeting FAA objectives                 for air safety.
We did not make an overall             evaluation       of all aircraft       cer-
tiflcatlon       programs,      nor drd we make any determinations               con-
cerning     the airworthiness        of aircraft        affected     by the sur-
veillance      program.        The scope of our review is discussed                on
page 17.

       The Federal Aviation        Act of 1958, as amended (49 U.S.C.
14211, authorizes       the FAA Administrator           to prescribe      mini-
mum standards,     rules,     and regulations       to promote safety of
flight   of ~1~x1 aircraft.           To accomplish       thrs objective
with respect to the auworthiness              of aircraft,        FAA pre-
scribes   minimum standards        governing     aircraft      design,    mate-
reals,   workmanship,      construction,      and performance          and pro-
vides surveillance        over manufacturers        engaged in the produc-
tion of aircraft      and/or related       aircraft       parts and eqyuip-
ment
       Responsiblllty          for the aircraft     certificatzon       program
has been delegated           by the Administrator        to the eight FAA
regional      offices,     five of which are within           the continental
United States where almost all Jet transports                     that must be
approved as airworthy             by FAA are manufactured            In the re-
gional    offices      the responsibility       for this program has been
assigned,      in most cases, to the Flight            Standards Dlvlslon.

         Under the aircraft         certlficatlon        programs,      FAA issues
three categories          of certificates;          they are (1) type cer-
tificates,       which are normally            issued to manufacturers              for
new aircraft,        aircraft     engines,        and propellers       after      FAA
determines       that the parts included              in these items are of
proper design and material               and that the parts meet FAA
specifications         for safe operation;            (2) production        certifi-
cates,     which    are   discussed      below;     and   (3)  airworthiness
certificates,        which attest        to the fact that an aircraft

                                            4
conforms to the approved                  type design          (type     certificate)          and
is In condition for safe                  operation.

        The production            certification            program LS intended              to
provide      approval        of and confxnued              surveillance          over manu-
facturers'        facilities         for duplicating             aircraft        parts that
have been included              in aircraft,           aircraft       engines,       or pro-
pellers      previously         type-certificated               by FAA. Under this
program FAA issues production                       certlfrcates          to manufacturers
that intend         to produce in volume a part to be included                                in
type-certificated             aircraft,          aircraft       engines,       or propellers
after    the manufacturers'                facilities,          methods, personnel,
and procedures            are found by FM to be adequate to duplicate
such parts.           In addition          FM provides           continual        surveillance
over these manufacturers                   and their        suppliers        In order to
review the quality              control       maintained         by the manufacturers
of these parts.              The actual          surveillance         work is performed
by FAA manufacturing               inspectors          generally       located       In Engl-
neerlng      and Manufacturing               District       Offices       within     a re-
gion's      geographic        area of responsibility

         In the past FAA relied    mainly on two methods of sur-
veillance      over production   certificate     holders    and their
suppliers--     surveillance   by FAA triennial      Production    Certl-
flcatlon      Boards and by Manufacturing       Control   Area Surveys

        TriennialBoardsusually               are comprised of several             FAA
inspection       teams, supervisory            inspectors,      and the Chief of
the region's        Engineering         and Manufacturing        Branch who is
Chairman of the Board                 The Boards are convened periodi-
cally    to determine        whether manufacturers            that have been
issued production           certlfxates          have continued       to comply
with FAA's certification                rules and are eligible           to retain
their    production        certificates           The Boards are responsible
for making broad reviews of manufacturers'                       quality     assur-
ance efforts        rather      than comprehensive         in-depth      investiga-
tions of the manufacturers'                 production     processes

        The Control   Area Survey system is used to determine
whether the production       certificate    holders   and their    sup-
pliers    are complying   with specifrcatlons       and procedures
that have been approved by FAA            The system functions      as a
periodic     recheck of the systems and procedures         of manufac-
turers    in the interim   period between triennial        Board

                                                 5
meetings --at which          time the manufacturers'              quality     control
systems are subject            to reapproval.

        Under the Control      Area Survey system, the facilities
of prime manufacturers         and their    suppliers    are divided     into
manufacturing      control    areas on a functional       basis,   such as
heat treatment,       metal surface treatment,        and laboratory
testing.      FAA inspectors      try to visit     manufacturers'     and
suppliers'     plants    at least annually     and try to make, at
that time, inspections         of as many materials,        parts,   ap-
pliances,     and assemblies      as possible     to assure their     con-
formity    with originally       approved items                                             L

         Conformity    inspections   are made by FAA to ensure that
aircraft      parts passing through      critical   manufacturing      pro-
cesses conform to FAA-approved           processing      standards  or
specifications       for the parts.      To accomplish       this obJec-
tive,     FAA inspectors      apply a series of tests and procedures
deemed appropriate         for the particular     parts.

         In fiscal      year 1968, FAA initiated,                on a one-time        ba-
 sis, the reexamination             of production        certificate        holders'
quality     control       of products       considered       by the FAA to be
critical      to the airworthiness             of aircraft.          FAA designated
this reexamination            a "critical        characteristics         audit"     and
assigned      the responsibility            for the reexamination             to its
regional      offices         The objectives,          as stated in an FAA
order,     were (1) to reexamine,              on a one-time         basis,     all FM-
approved manufacturer             quality      control     systems (practices
and procedures)           that affected        the critical         characteristics
of parts to determine             whether parts with critical                 defects
could go undetected            through manufacturers'               systems and
 (2) to prepare         a report      on the results         of the reexamination,
including       any appropriate          recommendations          for corrective
action        As of November 30, 1970, FAA Washington                       headquar-
ters had received            most of the region reports               and expected
to complete a review of the results                     of the critical           char-
acteristics        audits     by July 1971.

       The principal         officials     of the Department   of Transpor-
tation    responsible        for the administration      of activities
discussed     rn this      report      are listed in appendix    II
                                         CHAPTER 2

                     IMPROVED SURVEILLANCE NEEDED OVER

         PRODUCTION OF CRITICAL                PARTS FOR CIVIL            AIRCRAFT

        FAA needs to rmprove the surveillance                  over the produc-
tron of parts critical            to the airworthiness          of civil     air-
craft,    because certain         of these parts,       referred     to as pro-
prietary    parts,     are   not    subJected    to  production      surveillance.
Although    FAA had been aware, at the time of our review,                        of
the lack of surveillance             over critical      proprietary       parts,
 it had not acted to bring all such parts under surveillance.
In some instances         proprietary       parts had been placed under
productron     surveillance,         but only after       the malfunctroning         1
of that part caused the occurrence                 of an accident        or inci-
dent.     In one instance         the accident      had been fatal        to the
pilot    of an aircraft.

       FAA's existing     productron    surveillance        system is dr-
rected primarily      toward selected       functional      areas rather
than toward the overall        quality    control      systems of manufac-
turers   holding    FAA production     certificates.          FAA's system
coverage 1s limited,       however, by the availability            and loca-
tion of Its lnspectlon        staffs   and by the contlnulng          Increase
in the number of manufacturing          facilities       that must be in-
spected.
          In October 1967, FAA lnltiated                      a comprehensive          program
to reexamine,           on a one-trme basis,                the   overall      quality       con-
trol      systems of production              certlflcate          holders,        The pro-
gram, however,           did not provide             for consrderation            of crltr-
 cal proprietary            aircraft      parts.        In    May   1970,    one    FAA re-
gion proposed that FAA's production                           surveillance        system be
 directed      or limited         on the basis of overall                 evaluations         of
the adequacy of manufacturers'                       quality      control      systems over
 critical      aircraft        products.         We believe         that such a system
 could include          surveillance         over the production               of many
 critical      aircraft        parts that are not currently                    being sub-
 Jetted      to inspection           by FAA or by the production                  certifi-
 cate holders.            In   vrew    of  the     limrted       number     of   FAA   person-
 nel available          for surveillance             activities,         we believe        that
 FAA should place greater                 emphasis on requiring                production
 certificate        holders        to maintain         production        surveillance
 over their        suppliers.
                                                 7
EXPANDED PRODUCTION SURVEILLANCE
NEEDED FOR CRITICAL AIRCRAFT PARTS

         We found that certain           parts critical         to the airworthi-
ness of cavil        arrcraft     generally       were not being subjected
to production        surveillance        by FAA or by the production             cer-
tificate      holders.        FAA defines       a critical      arrcraft  part as
one that does not have a backup system and the failure                          of
which could cause a fatal              alrcraft       accident.

          The critical        parts not being subjected                    to production
surveillance          are off-shelf        items which are purchased by
production        certificate       holders        from suppliers            and which may
be suitable         for use in more than one type of aircraft.
These parts are referred               to as proprietary                parts because
neither      FAA nor the production                certificate          holders     have
design control           over them,      and     the    suppliers         are   generally
reluctant      to permit surveillance                 over the production              of
these parts by FAA or by the production                            certificate       holders.
Under such circumstances,                production          certificate         holders
are limited         to verifying       the functional              aspects of propri-
etaryparts        at the receiving           lnspectlon          points.        Such parts
may also be purchased              by an aircraft            owner directly          from
the supplier          for use on his aircraft,                 in which case the
parts would not be subJected                   to inspection            by the production
certlflcate         holder or by the FAA prior                   to their      use on the
aircraft.

        We visited     the facilities      of a production      certificate
holder     in FAA's Eastern Region to determine              the nature and
extent     of proprietary      parts that were not under production
surveillance       by either     the cognizant     FAA Engineerrng        and
Mknufa+urlng        District     Offlce  or by the production          certlfl-
cate holder.        Representatrves      of   this  productron    certificate
holder provided        us with a listing       of 30 proprietary        parts
which they consxdered,           for the most part,      to be of a crit-
ical nature and whrch were not under productron                  surveillance
by the company or by FAA. Discussions                with the cognizant
FAA inspector       confirmed      that many of these parts were crrtl-
cal to the operation          of an aircraft.

      We obtained additional     listings    of critical                    proprietary
parts from other drstrict    offices      in the Eastern                    Region.
We were advised by Eastern Region officials            that                 the

                                             8
maJority   of these parts were not subJected              to either  FAA's
or the manufacturers'          surveillance.     Following    are examples
of these proprietary          parts and a description       of the effect
that their   failure      or malfunction     might have on the opera-
tion of certain      aircraft.

      Flexible    propeller      coupling      used in the DC-7--Failure
      or malfunction        could result       in the loss of use of a
      propeller    and engine power.

      Engine fuel valve used in DC-9 turbojet--Failure                    or mal-
      function  could result in the loss of engine                   power and
      create a fire hazard.

      Flexible  drive coupling    for engine transmission     assem-
      bly used in the FH-1100 helicopter--Failure         or malfunc-
      tion could result     in complete loss of power to drive
      the main rotor    assembly.

      With respect      to these and other          proprietary      parts not
subJected     to production    surveillance,          District    Office   offi-
cials   stated,    in a memorandum to us,           that

      tNalfunction        and/or failure      of the above noted
      parts,     and the resultant        propeller      and/or engine
      malfunction,        under certain      conditions,        could be
      catastrophic.        *** It should be further             noted that
      proprretary       items can be ordered as replacement
      parts from the manufacturer             of the item without
      going through        the P.C. [production          certificate]
      holders     receiving     inspection      and functional        test
      procedures."

       In February  1970, while our            field    review was in prog-
ress, we discussed    the need for            expanded production       surveil-
lance over critical     proprietary           parts with an official         in
FAA's Washington    headquarters.             The official       stated that
there were probably     a number of           critical     proprietary    parts
which were not under production               surveillance       by FAA but
that he was unaware of the extent                 to which this condition
existed.

      Subsequent to completion              of our fieldwork,       we discussed
our findings   with FAA officials             in Washington       who concurred

                                        9
in the need for expanded productlon                   surveillance    of crltlcal
proprietary      parts.      The officials        stated that there were some
critical     parts classlfled         as proprretary          parts, previously
not subJect to production             surveillance,         that were later
placed under productron            surverllance        by FAA. They stated
that,     In some instances,        these parts had been placed under
productIon      surveillance       subsequent       to the occurrence       of an
aircraft.    accident      or lncrdent      which had been caused by the
malfunction      of that part.

          The officials      stated further     that,    in accordance with
FAA's suggestion,          the Aerospace     Industrres       Assoclatlon     of
America,      Inc.,     had agreed In April       1970 to evaluate        on a
national      basis the control       over crrtical        proprietary     parts
and that the results            of the study would provide            them with
addltronal        insight    into the problem.        According       to an FAA
official,       the association's       study had not been InItrated             as
of October 1970 but would be completed by the spring of
1971,




                                         10
QUALITY CONTROL SYSTEMS APPROACH WOULD
BENEFIT EXPANDED PRODUCTION SURVEILLANCE

         FAA's current          policy     is to subJect the manufacturing
activities        of both the production                certificate          holders     and
their      suppliers      to comparable          levels       of production          survell-
lance.       To implement this policy,                  district        offices      are re-
quired to maintain              surveillance        over the parts and processes
of all suppliers            with the exception             of certain         parts which
are subjected          to detailed         inspection         after     receipt      at pro-
duction      certificate          holders'     plants.          In effect,       FAA con-
 siders suppliers            to be extensions           of the production             certifl-
cate holders'          facilities         and exercises           the same degree of
 surveillance         over suppliers'          facilities.            In addition,         pro-
duction      certificate          holders     are required           by FAA to maintain
adequate quality             control      systems over their              own production
operations         and the production            operations          of their      suppliers,

          Under the production              certification            program, FAA uti-
lizes      the triennial           Production        Certification           Boards and Man-
ufacturing         Control      Area Surveys to maintain                   surveillance
over production            certificate         holders       and their        suppliers.
Although       FAA's existing             system of production               surveillance        is
 intended      to provide          considerable         inspection        coverage,       it is
limited       by the availability              and location           of inspection         staffs
and by the continuing                 increase       in the number of manufactur-
 ing facilities          subject        to inspection.             For example, at the
 district      office      with the largest             staff      in the Eastern Region,
 eight manufacturing               inspectors        are responsible            for surveil-
 lance over facilities                of eight manufacturers                 and 114 sup-
 pliers.       One manufacturer              has five separate             large facilities
 in the district           office's        area of responsibility,                 numerous
major part suppliers                 and process and service                 suppliers,       and
 a vast number of small subcontractors                           throughout        the Nation.
 The five remaining              district      offices        in the Eastern Region
 have smaller         staffs       and also have comparatively                    heavy work
 loads.

       We noted that,   as a result     of a recent reexamination              of
the quality    control  systems of production        certificate         hold-
ers, officials     in FAA's Eastern Region concluded             that one of
the major failures     of the existing     production        surveillance
 system was that it directed     district     office    manpower toward
accomplishing     a number of standard     conformity        inspections,

                                                 11
such as those made under Control    Area                Surveys,      rather    than
toward the adequacy of the production                   certificate       holders'
overall  quality control system.

        The Eastern Region found In its reexamlnatlon                     that FAA
inspectors,      in certain       cases,    had   overlooked     entrre     segments
of a manufacturer's          quality     control     system during past in-
spections.       For example, previous            FAA lnspectlons        did not
disclose    that one productloncertificateholder                   had not es-
tablished     procedures       for qualifying        or auditing      surveillance
over nondestructive          testing,      such as X-ray,       and material
process suppliers.           In another       case the Eastern Region found
that the outside       laboratories         used by a productron           certlfl-
cate holder      for analyzing         and quallfylng       raw material        re-
ceived from suppliers            had never been Inspected.             Adequacy of
performance      in each of the above areas materially                   affects
the quality      of aircraft        products.

         These deflclencles        in the manufacturers'             quality     con-
trol     systems should have been detected              by FAA during trien-
nlal Board reviews of the production                  certlflcate        holders'
facllltles       and quality      control    systems.        An Eastern Region
offlclal      stated,    however,     that In the 3 or 4 days during
which these reviews were conducted                the Boards made confor-
mity lnspectlons         to test the production            certlflcate        holders'
lmplementatlon         of their    quality    control      systems.         Due  to the
pressures       of time, the Boards did not make a comprehensive
evaluation       of the manufacturers'         quality       control      system but
assumed that the quality             control   systems were In general
conformance        with FAA regulations        because the systems were
approved by FAA prior           to lssulng     the production          certlflcates.

         Eastern Region officials,              in a special        report   dated
May 1970 on the existing               surveillance        system, recommended to
Washington       headquarters        that the quality          and coverage of
 surveillance        over critical       parts,     wrthin     available     manpower
limitations,         would be improved by placing               increased     emphasis
on overall       evaluations        of the production          certificate      holders'
quality      control     systems as a basis for directing                  or limiting
its production          surveillance       efforts.        The FAA had not acted
to implement         the Eastern Region's           recommendations         at Decem-
ber 1970.        We are of the view that such evaluations                     could



                                           12
provide    needed surveillance       over crItIca    proprietary      air-
craft   parts    that are not    Inspected    by FAA or by the     produc-
tlon certificate      holders.




                                     13
AGENCY COMMENTS AND OUR
EVALUATIONS AND CONCLUSIONS

         In a draft      of this report         submltted      to the Secretary
of Transportation           for comment, we proposed that the FAA Ad-
minlstrator        take appropriate          action    to ensure that all crlt-
lcal proprietary          arrcraft       parts are subJected          to production
surveillance         by either      FAA or by the responsible             production
certificate        holders.        We proposed also that the Adminlstra-
tor modify the existing               production      surveillance      program to
provide     for greater        reliance      upon the adequacy of productlon
certificate        holders'      quality      control    systems as the basis
for directing         or limiting        FAA's surveillance         over both pro-
duction     certificate        holders'       and suppliers'       production
operations.

       In commenting on our proposals,              by letter       dated Sep-
tember 28, 1970 (see app, I>, the Acting AssIstant                       Secretary
for Admlnistratlon,         Department     of Transportation,           acknowl-
edged the existence         of the problems discussed             in our report.
He stated that FAA recognized            the need to assure that the
production      certificate     holders'    quality    control       systems
would extend to all suppliers             of parts that would be incor-
porated     into a product      and, as a result,        inltlated       the crlt-
ical characterlstlcs         audit program in October 1967.                 Fur-
thermore,      he said that FAA's Eastern Region was selected                    In
1968 to study the overall           program and to submit recommenda-
tions    for improvements        in the production       and surveillance
system.       He further    stated that:

       "Upon completion      of our review of both the CCA
       [critical   characteristics      audit]     and the Eastern
       Region proposal,      specific   procedures     will      be es-
       tablished   to ensure that all critical            proprietary
       aircraft   parts will      be subJect to production           sur-
       veillance   and that greater       reliance    will    be
       placed on the adequacy of PC holders'              quality
       control   systems.      We expect to complete our re-
       view by July 1971."

       The action     planned by the          Department,     if effectively
implemented,should        rmprove the         surveillance      over the pro-
duction   of aircraft       and related        aircraft    parts.


                                         14
       Regarding      the Eastern Region's           study of FAA's produc-
tlon surveillance          system, we noted that Its report,               which
mentioned     proprietary        parts as an area needing attention,
was presented       to Washington        headquarters       informally     in Octo-
ber 1969 and again formally               in May 1970.        It  was  not   until
July 1970 after         receiving     our draft      proposals,      however,      that
the Dlrector,       Flight      Standards     Service,    appointed     a  task
force to accelerate           the development        of a new surveillance
system intended         to include      proprretary      parts.

        During December 1970, FAA Washington headquarters                       was
In the process of reviewing               the results    of the critical
characterlstlcs          audit which had been received            and the East-
ern Region's         report   on the production       surveillance         system.
Generally,       the Eastern Region did not include               crltlcal
proprietary        alrcraft    parts under the critical           characterls-
tics audit.          Also, a FAA Southwestern         Region offlclal,          in
reporting       on the final      results    of the critical       characterls-
tics audits        in September 1970, stated that.

       "The real shortcoming           of the program was the fact
       that It did not take into account all critical
       parts.    I refer      specifically      to the     parts clas-
       sified   as proprietary         items.     In our present
       modern-day    aircraft,        many of the most critIca
       items are proprietary           and from all lndlcatlons       It
       appears they will        continue      to be Ignored,     only to
       remain as the topic          of a now and then conversa-
       tion that every one agrees something               should be
       done about but never quite gets done."

        We believe     that,     since the Department            has been aware
for some time that certain               parts crltlcal        to the alrworthl-
ness of aircraft         are not under production              surveillance        and
that,     In the past, slmllar           parts have contributed            to or
caused accidents,         action      should have been taken to bring
such parts under FAA or production                 certificate         holder     sur-
veillance.       We believe        that such action         should be taken as
soon as possible         and should not be delayed further                   while
the crltlcal       characterlstlcs          audits   are being reviewed            and
revlslons      of exlstlng       surveillance      procedures        are being
completed.



                                           15
RECOMMENDATION TO THE ADMINISTRATOR

         Accordmgly,       we recommend that FAA Issue, as soon as
possible,      rnstructlons      requlrmg    that crltxal           proprietary
aircraft      parts be subJect to production             surveillance        by el-
ther FAA personnel          or by production     certlflcate         holders.




                                         16
                                    CHAPTER 3

                                SCOPE OF REVIEW

        Our review included            an evaluation        of selected     aspects
of FAA's production           certification          program and was directed
toward determining           whether these aspects were meeting FAA
objectives     for air safety.              We conducted      our review at FAA
headquarters      in Washington,            D.C.; at the FAA Regional           Office
in New York, New York; and at selected                      FAA engineering      and
manufacturing       district       offices      within    that region.

         We examined pertinent        laws, regulations,          policies,       pro-
cedures,      correspondence,      inspection      reports,      and other re-
lated documents.         We discussed       matters    pertinent       to our re-
view with FM headquarters             and Eastern Regional          Office      of-
ficials.       We also held discussions          with representatives             of
the aircraft       manufacturers      and the parts suppliers             located
within     the geographic      area of responsibility            of one district
office     concerning    the production       surveillance        over critical
proprietary       parts.




                                          17
APPENDIXES




 19
                                                                                       APPENDIX   I
                                                                                           Page 1

                          OFFICE   OF THE SECRETARY         OF TRANSPORTATION
                                        WASHINGTON,   D C     20590



ASSISTANT SECRETARY
 FOR ADMINISTRATION


                                                        September       28,     1970



 Mr. Bernard Sacks
 AssIstant      Dlrector
 Clvll   Dlvlslon
 General Accounting                 Office
 Washington,       D C.             20548
 Dear Mr              Sacks
 This 1s In reply to your request                    for comments on the draft
 report     concerning      Improved Surveillance                 Needed Over Pro-
 duction     of Critical        Parts for Civil          Aircraft,          Federal        Aviation
 Admlnlstratlon         (FAA).      In this report            you conclude           that FAA
 needs to improve surveillance                 over the production                  of parts
 which are critical           to the alrworthlness                of clvll        aircraft
 In that (1) certain            of these crltlcal              Items are not presently
 subJected      to production         surveillance          and (2) the current
 surveillance       system tends to focus on selected                         functional
 areas, rather        than on the overall              quality        control       system of
 manufacturers       with FAA production               certlflcates            (PC).       Accord-
 ingly,     you recommend that the FM Admlnlstrator                              (1) ensure
 that all critical          proprietary         aircraft         parts are subJected
 to production        surveillance        by either         FAA or the responsible
 PC holder      and (2) place greater              reliance         upon the adequacy of
 the PC holders'          quality     control      system as a basis for directing
 or llmltlng       FAA's surveillance            over PC holders'               and suppliers'
 productlon       operations.
  Our own awareness of the problems noted by your report                     led us
  to take certain       steps to improve our surveillance            system.       The
  FAA has put considerable          effort     rnto revising    agency procedures
  for surveillance        over aircraft      parts,   and In expediting        the
  development      of a more complete systems approach which will
  ensure that all crltlcal          proprietary      parts will   be sublect       to
  appropriate      production   surveillance        and that greater     reliance
  will    be placed on the adequacy of the manufacturer's                quality
  control     system
  APPENDIX        I
      Page        2

In the past,            the FAA’s method              of assuring           the alrworthlness                of
alrcraft        provided          for an evaluation               of the adequacy             of the PC
holder’s         quality        control       system used in the production                         of clvll
aircraft         (lncludlng          any purchases            from the supplIers)                 and was
supplemented            by spot checkrng              the effectiveness               of the system
With the growth               and increased           complexity          of the aircraft               pro-
duction        system,        the FAA recognized                the need to evaluate                  Its
own surveillance                system in an effort                 to increase         its     effec-
tlveness,            One of the main problems                     recognized         was the need
to assure          that     the PC holder’s             quality        control       system would
extend       to all       suppliers         of parts        that would be incorporated
into     the product                As a result,          the agency lnltlated                  the
Crltlcal         Characterlstlcs              Audit      (CCA) program           in October           1967
to reexamine,             on a one-time           basis,        those     systems       and procedures
being      used to control              the quality           of the crltlcal             aircraft
parts,       installations,             and    procedures.             This    program,        which       1s
currently          In Its final           stages,       placed        emphasis       on the evalua-
tion     of the manufactldrer’s                  quality        control       system          The FAA
1s presently            studying        the results           of the CCA program                as a
basis      for     improving         Its existing           surveillance           program

In conJunctlon        with     the CCA program,     the FAA’s Eastern         Region
was selected        In 1968 to study       the overall      program   and submit
recommendations         for improvement       In the production       approval
and surveillance          system.    The region     has submitted      a proposal
and this     report     1s presently     under   conslderatlon      at the
Washlngton      headquarters

Upon completion        of our review            of both      the CCA and the Eastern
Region    proposal,      speclflc        procedures       will      be establlshed          to
ensure    that    all critical         proprietary         alrcraft      parts    will      be
subject     to production         surveillance          and that      greater      reliance
will    be placed     on the adequacy             of PC holders’         quality       control
sys terns      We expect      to complete           our review       by July     1971,

Making     improvements        In avlatlon       safety      1s an ongoing   actlvlty
with    the FAA       As aircraft        become more numerous           and complex
and performance         Increases,       we have to change our techniques
and procedures.           The changes       are themselves        complex   and
require      mature   conslderatlon         before      adoptlon      Often  the
development        and lnstallatlon         cycle     must extend     over several
years        Such 1s the sltuatlon           In this       area in which    a change
has been In process            since    1967 and IS now near completion




                                                    22
                                                                          APPENDIX I
                                                                              Page 3

We appreciate   the opportunity    to comment          on your       draft
report
                                       Sincerely,




                                   Actmg       Assls   tant   Secretary




                                  23
APPENDIX II


                   PRINCIPAL   OFFICIALS     OF

              THE DEPARTMENT OF TRANSPORTATION

     RESPONSIBLE FOR THE AD?IIINISTRATION          OF ACTIVITIES

                  DISCUSSED IN THIS REPORT


                                                  Tenure    of offxe
                                                  From                 To

                DEPARTMENT OF TRANSPORTATION

SECRETARY OF TRANSPORTATION.
    John A. Volpe                          Jan.      1969      Present
    Alan S. Boyd                           Jan.      1967      Dec.    1968


               FEDERAL AVIATION     ADMINISTRATION

ADMINISTRATOR:
    John H. Shaffer                        Mar.      1969      Present
    David D. Thomas (acting)               Aug.      1968      Mar.    1969
    Gen. Wllllam    F. McKee               July      1965      July    1968

ASSOCIATE ADMINISTRATOR FOR
  OPERATIONS:
    George S. Moore                        Apr.      1967      Present
    Arvln 0. Basnlght                      July      1965      Apr.    1967

DIRECTOR, FLIGHT STANDARDS SER-
  VICE:
    James F. Rudolph                       Oct.      1967      Present
    James F. Rudolph (acting)              June      1967      Oct.    1967
     Clifford W. Walker                    Apr.      1966      June    1967
    George S. Moore                        Apr.      1963      Apr.    1966




                                                              U S GAO, Wash , D C
                               24