EASA Warns of Stolen Engine Parts

The European Union Aviation Safety Agency (EASA) has published an unapproved parts notice explaining that a large volume of engine parts were stolen. The stolen parts include parts from CFM56, IAE V2500, PW1100 and RB211 turbofan engines. These parts were intended to be scrapped, and were rerouted late January 2026 when they were intended to go to a contract mutilation facility. They were rerouted by a third party that impersonated the contracted mutilation provider.

The EASA alert includes detailed information on affected serial numbers, part numbers, engine types, and parts descriptions.

ASA members received an email notice about this on Friday, but we wanted to follow-up for community members who might not have received this notice.

To help you respond appropriately, ASA recommends reviewing the following possible actions:

1. Communicate the Information Internally and Externally

Ensure relevant team members—such as quality, supply chain, procurement, operations, and IT—are aware of this notice. Consider handling this as a company-wide notification for reinforcement of our shared responsibility for maintaining a safe supply chain. If applicable, consider sharing the information with trusted external partners who may be affected or may participate in related transactions.

2. Implement an Internal “Flag” for Identified Part Numbers

ASA encourages you to update your internal systems so that any transaction involving the listed part numbers triggers an alert. This flag is not intended to prohibit procurement; rather, it is intended to alert the company’s compliance professionals that additional verification steps may be necessary before the transaction proceeds.

3. Confirm Your Company Is Subscribed to Government Safety Notifications

While ASA will continue to share relevant alerts promptly, it is important that your organization is registered directly with the appropriate government agencies for official notices. Doing so helps ensure you receive real-time information on potential safety or compliance risks. You can create an EASA account and register for EASA unapproved parts notices on the EASA website. You can subscribe to FA unapproved parts notices and other FAA notices on the FAA’s website.

EASA Notification and Details

Full details about the stolen engine parts notice, including the list of affected components (with serial numbers), can be found here:
https://www.easa.europa.eu/en/domains/aircraft-products/suspected-unapproved-parts/theft-turbofan-engine-parts-mutilation

While this notice provides details regarding the stolen parts, ASA feels that even if your company is not involved in the engine parts market, you should think about how you would manage a notice that impacts your business line.

New Sick Leave and Parental Leave Guidance

We previously published articles about the new paid sick leave and paid parental leave provisions.  The Department of Labor has issued new guidance concerning these new laws.  The new guidance provides answers to some of the compliance questions facing the industry.

Effective Date

The effective date of the new paid sick leave and paid parental leave provisions has been fixed.  These paid leave provisions are effective on April 1, 2020, and apply to leave taken between April 1, 2020, and December 31, 2020.

Posting Notice

We indicated that a notice would be required, but was not yet published.  The new notice has been published.  In recognition of the fact that many employees may be working from home, employers can meet the notice requirement by emailing the notice or posting it on the employee portion of their website:

“An employer may satisfy this requirement by emailing or direct mailing this notice to employees, or posting this notice on an employee information internal or external website.”

Enforcement

The government will not bring enforcement actions against any public or private employer for violations of new paid sick leave and paid parental leave provisions that take place between March 18 and April 17, 2020, provided that the employer has made reasonable, good faith efforts to comply with the new laws. There is further guidance and instructions for this forbearance, so if you think you may have violated the new laws, then you should contact an attorney immediately.

General Compliance

Looking for guidance on the interaction between the Covid-19 and the Family and Medical Leave Act (FMLA) or general Labor Law?  The Department of Labor has published guidance:

Still not sure what to do?  ASA member should send their questions to ASA so we can try to find you answers!

Do You Use Confidentiality Agreements? Make Sure They Reflect the New Federal Notice Requirement!

It is very normal for aerospace distributors to ask their employees to sign non-disclosure agreements in order to protect the business’ confidences.  This protects a wide range of trade secrets, including customer lists and financial data.

Congress passed a new trade secret law, which provides a federal cause of action for trade secret infringement. The new law, known as the Defend Trade Secrets Act of 2016 (DTSA), is identified as Public Law 114-153 and was signed into law on May 11, 2016 (yesterday).

Provisions of the new law will impose some affirmative burdens on employers, and if you fail to meet those obligations then you could undermine your company’s intellectual property rights.  In short, the new law provides new whistle-blower protection but it also imposes on employers an affirmative obligation to provide notice about the new whistle-blower protection.  Failure to provide notice when it is required could undermine your ability to collect in a trade secret infringement case.

WHISTLE BLOWER PROTECTION

The DTSA provides whistle blower protection to certain employees who disclose trade secrets to the Government (including in a court filing). The whistleblower immunity applies if the employee discloses a trade secret, but does so in one of these contexts:

  • A confidential disclosure to a Federal, State, or local government official, either directly or indirectly, or to an attorney (but only for the purpose of reporting or investigating a suspected violation of law); or
  • A disclosure made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal.

NEW NOTICE REQUIREMENTS

The most important clause for employers to understand is the NEXT clause, which requires employers to provide notice of the whistle blower immunity. This clause says:

(3) NOTICE.—

(A) IN GENERAL.—An employer shall provide notice of the immunity set forth in this subsection in any contract or agreement with an employee that governs the use of a trade secret or other confidential information.

(B) POLICY DOCUMENT.—An employer shall be considered to be in compliance with the notice requirement in subparagraph (A) if the employer provides a cross-reference to a policy document provided to the employee that sets forth the employer’s reporting policy for a suspected violation of law.

(C) NON-COMPLIANCE.—If an employer does not comply with the notice requirement in subparagraph (A), the employer may not be awarded exemplary damages or attorney fees under subparagraph (C) or (D) of section 1836(b)(3) in an action against an employee to whom notice was not provided.

(D) APPLICABILITY.—This paragraph shall apply to contracts and agreements that are entered into or updated after the date of enactment of this subsection.

This imposes an affirmative duty on employers to notify their employee of the immunity clause (the whistle blower protection) in the DTSA.This obligation arises whenever the business has a contract or agreement with an employee governing the use of confidential information (including trade secrets).

The notice about the whistle blower protection needs to be included in the confidentiality agreement that governs the use of the trade secrets/confidences. So if your employees each sign a confidentiality agreement (or employment agreement that includes confidentiality obligations) at the time of hiring, then this standard agreement should be modified to reflect the requirements of the law. This new language should be reflected in every contract addressing confidentiality provisions that is entered into on or after May 12, 2016 (today).

Old and existing contracts (those entered-into before May 12, 2016) do not need to be modified to reflect this new language, unless they are updated in any way. If you make any sort of update to a pre-existing contract that addresses confidentiality, then please make sure the modifications also include the new whistle blower protection notice language.

There is an option to publish a policy document including the appropriate notice, and then to cross reference that document in the agreements with the employees, consultants and contractors. If you do this, then you should be specific about the revision level of the policy document, to make sure that it includes the appropriate language.

Failure to provide notice can limit the company’s ability to collect certain damages and attorneys fees, to which the company might otherwise be entitled. Eliminating the chance of recovering attorneys fees can make a valid lawsuit economically undesirable.

APPLIES TO CONTRACTORS AND CONSULTANTS, TOO

The definition of employee for these purposes includes contractors and consultants!

(4) EMPLOYEE DEFINED.—For purposes of this subsection, the term ‘employee’ includes any individual performing work as a contractor or consultant for an employer.

So your consulting agreements and other agreements with independent contractors need to reflect this new disclosure language as well. This may be especially important when working with contractors who normally sign a non-disclosure agreement.