Update on USM and China

Many of you were at the ASA/AFRA Annual Conference and got an update on the work we’ve been doing with the Chinese government to open their system to foreign (non-Chinese) USM.

USM, or Used Serviceable Material, is the term that is often applied to parts that have been disassembled from aircraft with the intent that they be overhauled and then subsequently installed in a different aircraft.

The Chinese government has legitimate concerns about unapproved and counterfeits parts being passed off as USM and entering their civil aviation system. They have decided that China should be open to USM, but that they want to control the flow of USM entering China to help protect China from unapproved and counterfeits parts. To this end, China has adopted a policy of requiring USM to have been removed by a qualified facility that is regulated under Chinese law. The USM is then recorded in a database that permits subsequent CCAR145 repair stations and performing service on the parts, as well as installers, to verify the provenance of the part before using it. This will help to better distinguish legitimate USM from counterfeit parts that might be passed-off as USM.

CAAC has been working closely with the Aircraft Fleet Recycling Association (AFRA) to develop a protocol for accepting USM that has been removed outside of China. AFRA is the leading trade association for aircraft end-of-life solutions, and focuses on safe disassembly practices that protect both airworthiness and environmental priorities.

We will provide our next public update on this CAAC-AFRA process at the Civil Aviation Materials and Maintenance Management Forum. Because of travel schedules and competing priorities, I will be joining the conference remotely. I will provide the update and I also plan to answer audience questions.

China Approves ASA-100

The Aviation Suppliers Association is pleased to announce that the Civil Aviation Administration of China (CAAC) has approved the ASA-100 Quality System Standard for use under Chinese law.

Under CAAC guidance, Chinese air carriers who purchase parts from distributors need to ensure that the distributor has been appraised and accredited by one of the recognized industry organizations. AC-120-FS-058 Rev. 3. Recognized organizations are listed in CAAC’s IB-FS-MAT-001 (rev. 1) (see below). The first such organization was the Civil Aviation Maintenance Association of China (CAMAC). The second is now ASA (see approval letter, below.

September 15, 2020 letter from CAAC, appointing ASA as a “recognized organization” under IB-FS-MAT-001 with respect to the ASA-100 Quality System Standard

This is the culmination of a multi-year dialogue between ASA and CAAC (and CAMAC). This should alleviate one of the concerns that ASA members have raised with respect to their efforts to support Chinese Air Carriers.

USM Alert

Members have also raised concerns about recently-published CAAC standards for Chinese air carrier purchase of parts from aircraft-disassemblies and other used serviceable material. ASA has been speaking with CAAC about this issue and is developing a solution to propose to CAAC. The solution will be designed to protect the interests that CAACis trying to protect, while also providing a reasonable path that allows safe aircraft parts to be sold.