Anyone bought any "AOG Technics" components lately?

[ArrowFlyer86]

Seems like a company has been manufacturing bunk parts for a popular jet engine and somehow selling them to commercial clients.
Apparently they were forging 'Authorized Release Certificates' in order to make the products conformant for the customers, when in fact how/where they were created and within what standards remains a total mystery. I guess that's one way to deal with supply shortages, or to appear you have magical inventory that no one else does, or to just undercut your competition. Just lie! Until someone discovers your company is a fraud (their company website no longer works: here).

I'm a little disappointed. I would have thought the procurement departments at airline companies and other mx shops would be sharp enough to avoid bogus parts? Guess not. Or maybe it's just a handful that got their parts through unscrupulous providers.

This is the first time I'm hearing about this in aviation, has this happened before with any frequency?

Read more:
EASA (EU Aviation Safety): EASA Release Link
BBG: Bloomberg News Link
Drive Drive news link

 

[AKiss20]

Counterfeit parts in aviation are nothing new. Been happening a long time.

Fake parts a real threat | Times Aerospace

www.timesaerospace.aero

Con Air: exploring the trade in counterfeit and unapproved aircraft parts

Abstract. Counterfeit aircraft parts are among the most well-known counterfeits and pose a significant risk to public safety. It is estimated that as much as 10

academic.oup.com

Fake parts: A Pentagon supply chain problem hiding in plain sight

The Defense Department is developing new tests to find counterfeit parts, putting a renewed emphasis on reporting when problematic components are found.

www.defensenews.com

As long as there are operators and MRO shops who seek lowest cost as the highest priority, there will be a market incentive for it.

 

[Half Fast]

Counterfeit electronic parts have been a problem in defense/aerospace for a couple of decades. We were required to establish and monitor a trusted supply chain from manufacturer to distributor. Meticulous record keeping was essential. There were still occasional escapes, however.

Unscrupulous sellers would re-label ICs or other components. Sometimes it was slipping us a commercial grade part instead of industrial or military grade. Those would usually pass acceptance testing but fail in the field due to stress. Other times they’d ship a completely different part that had been re-labeled. It might sit in stock for months or years before being installed and by then the seller would be out of business.

 

[Bell206]

I would have thought the procurement departments at airline companies and other mx shops would be sharp enough to avoid bogus parts?

They are sharp enough. But its heavily based on the documentation you receive with the parts that makes it a legal part. For example, when you get a new engine from Lycoming, do you accept the attached documentation or do you disassemble the engine to insure it conforms to that documentation? From what I read on the OP case, Technics was a reseller and took legitimate 8130-3s and replaced certain part info then sold the part. And given there has been no ADs at this point hopefully it was caught at the receiving point.

Aviation is considered a closed system from an airworthiness perspective, which makes it is very easy for someone to do this, and as mentioned, it unfortunately happens with regularity on all levels. And especially at the private 91 level where some people tend to brag about how they "beat" that closed system and have even posted on PoA how ingenious they were in the process. Selling parts with bogus documentation or installing parts with no documentation all falls under the same category from an airworthiness point.

 

[Half Fast]

I would have thought the procurement departments at airline companies and other mx shops would be sharp enough to avoid bogus parts?

Imagine you're performing receiving inspection at an aerospace company. Your distributor sends you a batch of ICs (hundreds or thousands). Suppose some of those parts are only qualifed to work over the temp range of 0C to 70C instead of the -55C to +125C range you need. A supplier has falsely re-labeled some of the devices so they look just like all the others.

How would you catch that? The only way would be to perform temperature testing on every stinking part. You've already paid the supplier to perform screening (usually done by sampling at the wafer level), and he's provided you with a (false) certificate of compliance. Can you really justify the time and expense to test all the parts, and pass that cost along to your customer?

Multiply that by the hundreds of thousands of electronic components that are in an aircraft.

And I'm talking just the electronic components you buy directly. There are many more in assemblies you purchase from vendors and subcontractors (radios, nav equipment, etc., etc.).

And I'm only talking about electronics. Similar problems exist throughout: engines, structures, flight controls, etc., etc.

Just how "sharp" will you have to be to avoid bogus parts?

 

[ArrowFlyer86]

Imagine you're performing receiving inspection at an aerospace company. Your distributor sends you a batch of ICs (hundreds or thousands). Suppose some of those parts are only qualifed to work over the temp range of 0C to 70C instead of the -55C to +125C range you need. A supplier has falsely re-labeled some of the devices so they look just like all the others.

How would you catch that? The only way would be to perform temperature testing on every stinking part. You've already paid the supplier to perform screening (usually done by sampling at the wafer level), and he's provided you with a (false) certificate of compliance. Can you really justify the time and expense to test all the parts, and pass that cost along to your customer?

Multiply that by the hundreds of thousands of electronic components that are in an aircraft.

And I'm talking just the electronic components you buy directly. There are many more in assemblies you purchase from vendors and subcontractors (radios, nav equipment, etc., etc.).

And I'm only talking about electronics. Similar problems exist throughout: engines, structures, flight controls, etc., etc.

Just how "sharp" will you have to be to avoid bogus parts?

Thanks! That illustrates the problem clearly. I was thinking of it much more simplistically, like verifying an engine from P&W actually did come from P&W. There's far fewer of them, probably much easier to track.
Admittedly if you have a bunch of ICs or numerous/hard-to-verify components it's going to be next to impossible to verify them all. At some point you have to trust that the construction and testing was done right. Only after you have enough failure datapoints might you start to suspect something is wrong.

I guess what I had in mind was more solid, reputable supply chains with a chain-of-custody to ensure the parts were sourced from the right place (e.g., valid serial numbers that can be traced from place to place). It sounds like this guy sold bogus products, made profiles for bogus non-existent employees, and spent a lot of time forging documents. It surprises me that someone like this was able to get their foot in the door at any major aerospace company as a seller.

Not that I ever would, but is there anything stopping someone from creating a sharp website and claiming they do all the appropriate testing, and then start selling parts to Boeing/Cummins/repair shops/etc? Is the verification process not more rigorous than salesmanship?

And assuming they catch/try this person, wouldn't they be on the hook for massive fraud? You mentioned sometimes components might sit on the part for years before they're finally discovered to be problematic and by then the company is out of business. Aren't they still on the hook (criminally) for selling you fake products?

 

[SoonerAviator]

If vendors/suppliers are falsifying certificates of conformance, there's very little chance it gets caught unless you have a rash of failures or another way to verify that the data they supplied matches another database. We run into that sort of issue with ISO/API certs in oil and gas manufacturing. We provide documentation that says it was made to "this spec/standard", and the customer pretty much has to accept that as fact unless they want to tear down/inspect every component to verify which would often involve destructive testing. Same for aircraft components. The cost/benefit to universal part inspection would never pencil out, especially for complex items which involve multiple assemblies.

 

[Half Fast]

Not that I ever would, but is there anything stopping someone from creating a sharp website and claiming they do all the appropriate testing, and then start selling parts to Boeing/Cummins/repair shops/etc? Is the verification process not more rigorous than salesmanship?

OEMs do source inspections and quality audits at suppliers of major items, but not for small piece-parts like electronic components or screws and washers. Companies selling those sorts of items are qualified and certified by external organizations, typically. Considering the number of items purchased, the process works quite well but it's obviously not perfect.

Aren't they still on the hook (criminally) for selling you fake products?

Sure, if you can reach them. Many, maybe most, of the small parts are made overseas. That can make it tough to get enough data to take legal action, and there are limits on what data we can let leave the US due to International Traffic in Arms Regulations (ITAR). It becomes amazingly complicated, and expensive to investigate.

Here's an example to show the difficulty (not ultimately a counterfeit part issue, but you'll get the point):

Some years ago we were doing qualification testing on a new seeker for the nose of a missile, and we were getting failures in a particular power op amp, a well-known device that had been used in designs for many years. We questioned whether we might have counterfeit devices and began to investigate.​

​

The part was originally a Burr-Brown device made in their US foundry. Sometime around 2000, Texas Instruments bought Burr Brown. They eventually closed the BB foundry and moved the part manufacturing to a TI facility.​

​

After some more time, TI went offshore to a factory in the Phillipines to make the part. Then it moved to another offshore facility, which was about when we bought parts for our particular application.​

​

As we investigated, we discovered that in one of the moves, TI had changed the method of attaching the op amp die to its heatsink/mounting tab and used a more modern epoxy. When they changed offshore foundries, the new facility was unable to source that epoxy and went to an alternate that unfortunately didn't flow well and provide complete coverage across the tab. The foundry tested every part over temperature and they passed, BUT they were failing in our system.​

​

We discovered that during the foundry testing, the part was not attached using the mounting hole in the tab. When we installed it, however, we screwed the tab down to a heatsink with a thermal pad and soldered the leads to a circuit card. This was introducing a mechanical stress which caused the die to debond from the tab and the part would then overheat. This had not been a problem with the original BB part, nor when TI made the part domestically. The new foundry's epoxy, however, didn't work as well and this allowed the die to debond.​

​

This took MONTHS to discover through research, testing, xrays of parts, etc., etc., complicated by the fact that we could not share details of our application for the part with a foundry outside the US due to ITAR.​

Now this was a case where the manufacturer, TI, wasn't trying to be deceptive. In fact, they were doing everything they possibly could to help solve the problem. Nobody was trying to sell fake parts in this case.

Now imagine if there had in fact been a crook trying to hide what he was selling us. Imagine that the crook provides falsified data. Imagine that we can't investigate too closely without compromising ITAR data.

We'd have to wade through all that just to determine that we even have a counterfeit part issue and not some other problem.

This is NOT an easy problem.

 

[ArrowFlyer86]

OEMs do source inspections and quality audits at suppliers of major items, but not for small piece-parts like electronic components or screws and washers. Companies selling those sorts of items are qualified and certified by external organizations, typically. Considering the number of items purchased, the process works quite well but it's obviously not perfect.



Sure, if you can reach them. Many, maybe most, of the small parts are made overseas. That can make it tough to get enough data to take legal action, and there are limits on what data we can let leave the US due to International Traffic in Arms Regulations (ITAR). It becomes amazingly complicated, and expensive to investigate.

Here's an example to show the difficulty (not ultimately a counterfeit part issue, but you'll get the point):

Some years ago we were doing qualification testing on a new seeker for the nose of a missile, and we were getting failures in a particular power op amp, a well-known device that had been used in designs for many years. We questioned whether we might have counterfeit devices and began to investigate.​

​

The part was originally a Burr-Brown device made in their US foundry. Sometime around 2000, Texas Instruments bought Burr Brown. They eventually closed the BB foundry and moved the part manufacturing to a TI facility.​

​

After some more time, TI went offshore to a factory in the Phillipines to make the part. Then it moved to another offshore facility, which was about when we bought parts for our particular application.​

​

As we investigated, we discovered that in one of the moves, TI had changed the method of attaching the op amp die to its heatsink/mounting tab and used a more modern epoxy. When they changed offshore foundries, the new facility was unable to source that epoxy and went to an alternate that unfortunately didn't flow well and provide complete coverage across the tab. The foundry tested every part over temperature and they passed, BUT they were failing in our system.​

​

We discovered that during the foundry testing, the part was not attached using the mounting hole in the tab. When we installed it, however, we screwed the tab down to a heatsink with a thermal pad and soldered the leads to a circuit card. This was introducing a mechanical stress which caused the die to debond from the tab and the part would then overheat. This had not been a problem with the original BB part, nor when TI made the part domestically. The new foundry's epoxy, however, didn't work as well and this allowed the die to debond.​

​

This took MONTHS to discover through research, testing, xrays of parts, etc., etc., complicated by the fact that we could not share details of our application for the part with a foundry outside the US due to ITAR.​

Now this was a case where the manufacturer, TI, wasn't trying to be deceptive. In fact, they were doing everything they possibly could to help solve the problem. Nobody was trying to sell fake parts in this case.

Now imagine if there had in fact been a crook trying to hide what he was selling us. Imagine that the crook provides falsified data. Imagine that we can't investigate too closely without compromising ITAR data.

We'd have to wade through all that just to determine that we even have a counterfeit part issue and not some other problem.

This is NOT an easy problem.

Good lord. Just reading that story makes my head spin. I don't even know where I'd begin looking. I'd probably just feel like ditching the whole existing design and starting from scratch!
Yes, that very clearly illustrates exactly how hard the problem could be to catch

 

[Half Fast]

Good lord. Just reading that story makes my head spin. I don't even know where I'd begin looking. I'd probably just feel like ditching the whole existing design and starting from scratch!
Yes, that very clearly illustrates exactly how hard the problem could be to catch

I used to really enjoy those sorts of investigations and I served on many failure review boards (FRBs) over the years. Failure investigations are challenging and have to be conducted very methodically lest you inadvertently destroy evidence. Fault trees have to be created and each branch investigated, pulling together evidence from testing, from manufacturing data, from simulations, etc., to either convict or exonerate each potential failure contributor.

Missile failures were always difficult because the hardware was usually a charred mass of twisted metal in a smoking crater in the desert. I'd have to rely on pre-launch test data and telemetry data, which is ALWAYS inadequate.

I once got sent to Dallas to investigate a failed missile shot. When I arrived they took me to the hangar where the recovered pieces were. There was a low lab bench, maybe 40' long, with charred aluminum pieces, circuit cards broken in half, torn wiring, smashed instruments, etc., mixed in with sand and pieces of cactus, spread out the length of the bench. I stared at it, the lead test engineer stared at me, then he said, "So what happened?" Four or five months later we got to root cause.

 

[Bell206]

they catch/try this person, wouldn't they be on the hook for massive fraud?

Aren't they still on the hook (criminally) for selling you fake products?

Yes on both accounts. However, this is not just a violation of an FAR, as the action can violate the USC as well. Thankfully, civil aviation has a number of built in checks and balances that usually gives the authorities an upper hand especially at the commercial end. The addition of international bi-lateral agreements, ICAO, and the Chicago Convention make any efforts to pursue bogus aircraft parts a joint, global process. Regardless, in the US the penalties are stern especially if the part gets installed on an aircraft. Here's a sample:

 

[aterry1067]

For most anything used on a military aircraft, the part needs a mil-spec. In order to have a mil-spec designation, the manufacture must be on the QML (Qualified Manufacture List) and provide testing data. The manufacture must also have a CAGE code, which they must apply for and be certified.

Ideally, everything one would use in aerospace would meet some kind of agreed upon standard; this is how we got AN fitting, MS hardware, etc. For a company to stamp any of their products with any of those designations, they must have been inspected and certified by some government entity. For Defense, that’s usually some component of the DLA (Defense Logistics Agency).

The logistics of all of this is a very deep rabbit hole covered up by a quagmire of paperwork. Saying that, it’s not impossible to become a government supplier and get all of those certifications, as long as you do the requisite paperwork and follow the procedures. There are several businesses that make a ton of money by helping small businesses navigate the process.

When a business that has a certification gets sold, transferred, etc, those certifications often get transferred to the new company without much hassle. This leaves a door wide open for a certified company to supply counterfeit parts.

Below are a few links to get you to the entrance of the rabbit hole, if you wanted to get your company certified to produce/supply your product to gov/mil.

CAGE Code | Application & Registration Services | FAMR

Getting your organization's CAGE Code is a critical step toward earning federal funding & contract opportunities. Learn how we can help!

www.famr.us

US Federal Contractor Registration (USFCR) | SAM.gov Registrations

System for Award Management (SAM) registrations, SBA contract set-aside certifications (VOSB, WOSB, HUBZone, 8a), and other federal contracting services.

usfcr.com

SUBPART 9.2 – QUALIFICATIONS REQUIREMENTS | Acquisition.GOV

www.acquisition.gov

 

[Half Fast]

For most anything used on a military aircraft, the part needs a mil-spec.

This used to be true, but not so much anymore, at least for electronics. Industrial grade parts are common. Many modern devices, especially microprocessors and FPGAs, are simply not made in military grade.

 

[ArrowFlyer86]

When a business that has a certification gets sold, transferred, etc, those certifications often get transferred to the new company without much hassle. This leaves a door wide open for a certified company to supply counterfeit parts.

Thank you for those references. I'm interested in reading more about that process.

That's interesting that when a biz is sold the licenses or certs transfer without hassle. So in theory when TKM shutdown (they built NAV/Comms) someone could have swooped in and bought the IP/company and potentially kept the ability to sell their product to certified aircraft? That one in particular I was curious about because the market concentration for radios is so high (and expensive).

I kind of figured a change of control, change of ownership deal would reset the whole thing. Especially for military components.

From the malicious angle -- I'm sure there's foreign governments who wouldn't mind funding some opaque financing vehicle to acquire an aerospace provider, if for no other reason than to procure the IP and have a window into components used in mil equipment. Being extra malicious, such entities seem like they'd be well served to purposely make bad parts. I'm sure this isn't news to the DoD, and I'm sure they have checks to ensure no such ownership structure terminates with a hostile foreign power.

 

[aterry1067]

This used to be true, but not so much anymore, at least for electronics. Industrial grade parts are common. Many modern devices, especially microprocessors and FPGAs, are simply not made in military grade.

I agree that parts can be sourced third party, but It’s still true, the supplier with the contract is still on the hook for the part. For example, If Honeywell uses a circuit card in one of their parts that they purchased elsewhere, and that circuit card doesn’t meet the certification requirements, then Honeywell is responsible for that part. It’s up to Honeywell to fix the problem with the third party supplier.

This is in-part how this story made headlines:

Pentagon suspends F-35 deliveries over Chinese alloy in magnet

The F-35 Joint Program Office says the magnet made with Chinese materials does not transmit information or put the plane at risk.

www.defensenews.com

 

[aterry1067]

Thank you for those references. I'm interested in reading more about that process.

That's interesting that when a biz is sold the licenses or certs transfer without hassle. So in theory when TKM shutdown (they built NAV/Comms) someone could have swooped in and bought the IP/company and potentially kept the ability to sell their product to certified aircraft? That one in particular I was curious about because the market concentration for radios is so high (and expensive).

I kind of figured a change of control, change of ownership deal would reset the whole thing. Especially for military components.

From the malicious angle -- I'm sure there's foreign governments who wouldn't mind funding some opaque financing vehicle to acquire an aerospace provider, if for no other reason than to procure the IP and have a window into components used in mil equipment. Being extra malicious, such entities seem like they'd be well served to purposely make bad parts. I'm sure this isn't news to the DoD, and I'm sure they have checks to ensure no such ownership structure terminates with a hostile foreign power.

I didn’t say with “no” hassle. Lol. But with much less hassle than starting the certification process from scratch.

Bevan Avionics (*Bevan Aviation) bought all TKM inventory and service agreements, and continues to service TKM, last I heard. I suspect the Intellectual Property rights were sold as well.

Aircraft Avionics Repair Service | Expert Avionics Inspection & Repair | Bevan Aviation

Bevan Aviation offers premier aircraft repair services, specializing in avionics inspection and repair. Trust our expert team for comprehensive avionics repair services and aircraft avionics repair to keep your aircraft in peak condition. Contact us today!

bevanaviation.com

 

[ArrowFlyer86]

I didn’t say with “no” hassle. Lol. But with much less hassle than starting the certification process from scratch.

Bevan Avionics bought all TKM inventory and service agreements, and continues to service TKM, last I heard. I suspect the Intellectual Property rights were sold as well.

Aircraft Avionics Repair Service | Expert Avionics Inspection & Repair | Bevan Aviation

Bevan Aviation offers premier aircraft repair services, specializing in avionics inspection and repair. Trust our expert team for comprehensive avionics repair services and aircraft avionics repair to keep your aircraft in peak condition. Contact us today!

bevanaviation.com

Fair fair.. I read "without much hassle" as no hassle. My mistake!

Never heard of Bevan. Wondering how much they paid for those assets.

 

[Half Fast]

I agree that parts can be sourced third party, but It’s still true, the supplier with the contract is still on the hook for the part. For example, If Honeywell uses a circuit card in one of their parts that they purchased elsewhere, and that circuit card doesn’t meet the certification requirements, then Honeywell is responsible for that part. It’s up to Honeywell to fix the problem with the third party supplier.

This is in-part how this story made headlines:

Pentagon suspends F-35 deliveries over Chinese alloy in magnet

The F-35 Joint Program Office says the magnet made with Chinese materials does not transmit information or put the plane at risk.

www.defensenews.com

True, but that doesn’t imply a Mil-Spec. There are many, many non-mil components in any modern military vehicle.

In fact, my company developed a proprietary database of components approved for our use, and most of our contracts allow its use instead of mil part numbers. This was a cost reduction method we developed as part of acquisition reform and we have an LOA in place with the DOD.

Not uncommon at all.

 

[aterry1067]

True, but that doesn’t imply a Mil-Spec. There are many, many non-mil components in any modern military vehicle.

In fact, my company developed a proprietary database of components approved for our use, and most of our contracts allow its use instead of mil part numbers. This was a cost reduction method we developed as part of acquisition reform and we have an LOA in place with the DOD.

Not uncommon at all.

Agreed. You are correct.

I was initially thinking mostly standard hardware and consumables.

Parts and assemblies do not have a mil-spec. But I believe that all do have a CAGE code and the suppliers are approved/certified by DLA?

 

[Bell206]

That's interesting that when a biz is sold the licenses or certs transfer

Speaking strictly from the civilian aviation side, not all FAA certification approvals can be transferred when a business is sold. For example, PMA's and Production certificates cannot be transferred. The data used to obtain those certifications can certainly be sold/transferred but the actual FAA certification cannot be transferred and a new certification approval must be applied for or added to an existing certificate. Part 21 explains the transferability of each type of certification. Here's the PMA rule which cannot be transferred and the AWC rule that can be transferred.:

 

[ArrowFlyer86]

A little bit of thread drift, and maybe a stupid question but I'll risk it because I'm curious...

Is it possible to:
(1) Create an "open source" design for a component (e.g., a NAV/COMM unit);
(2) Have a prototype made that gets reviewed/tested;
(3) Have that radio "certified"

Then rather than keeping the IP closed, give it away and open it up to anyone who wants to make that implementation of the NAV/COMM radio, so long as they self-certify that they built it exactly to spec? Or does the certification comes with restrictions on who can manufacture that specific design?

I recognize the economic incentives aren't there since the testing/certification process can be expensive, and maybe some liability, too. But I'm curious if that works in theory or if there are glaring restrictions that would only permit 1 specific person/company to make that specific item after it was approved. Not just an academic thought-experiment, I'm genuinely curious if there is potential someday for there to be more of a pilot co-op styled avionics provider for GA rather than just the Garmin/Avidyne/... duopoly.

 

[aterry1067]

I believe for the experimental world, that would work just fine. But for any certified aircraft, every person that built it may need a PMA from the FAA. Others here will have much more knowledge on that than I, so I will certainly defer to their expertise.


That said, I am actually a bit surprised that someone hasn’t developed a better and more capable portable NAV/comm other than the hand helds. Foreflight (and others), Apple (and others), and the various ADS-B/GPS receivers have completely changed VFR navigation. I suspect a similar NAV/comm radio device that requires no certification is right around the corner. VFR only….lol.

 

[Bell206]

Or does the certification comes with restrictions on who can manufacture that specific design?

I depends on who is building what for who. One route outside the STC, TSC, PMA method, would be to follow what Jim Weir did at RST Engineering years ago. In general, he created avionics kits, similar to the old Heath Kits for home electronics, and sold them to aircraft owners who in turn would assemble the kits as an owner produced part per 21.9(a)(5). Then have an A&P install them. There is a requirement for owner parts to be produced off approved data but there are a number ways to get that approval well below the PMA or TSOA levels. You could include that data in the kit or make it part of the kit requirement for the owner to get the approval. Owner produced parts are another method of part approval just like a PMA. I haven't seen Jim post on PoA in a while but I believe he still has his website up which provides more info though it was a bit dated. This would be the most economic and simplest way to go if you want to provide aircraft parts for TC aircraft. The key is you can't produce the part, only the owner can for his own aircraft.

 

[ArrowFlyer86]

Thank you very much for all the detailed information guys!

I will admit a fantasy of one day being able to work on avionics or aerospace equipment in general. My personal electronics knowledge kinds of starts/and stops with arduinos and RPi's, and about 100 different kinds of sensors from Digikey. But the idea of somehow being able to build a career constructing aircraft components (legally) that would be lower cost/rugged is something that I do get pretty excited about and a recurring dream over the last few years.