Aerospace Scrap Compliance: Why a Certificate of Destruction Is Non-Negotiable
by Barsha Bhattacharya Our Blogs Published on: 27 May 2025 Last Updated on: 04 June 2025
Disposing of aerospace scrap parts isn’t as simple as tossing them in the trash. Each scrapped piece could potentially find its way back onto an aircraft if not handled properly, and this poses serious safety and legal risks.
This is why compliance in aerospace scrap disposal is so important, and why a Certificate of Destruction (CoD) is considered non-negotiable whenever an aircraft part is retired as scrap.
Certificate of Destruction for Aerospace Scrap
In this article, we’ll explain the compliance responsibilities around aerospace scrap, the role of the CoD, what makes a CoD valid, the risks of non-compliance, and common industry practices for safe disposal.
Compliance Responsibilities for Aerospace Scrap
The aerospace industry is highly regulated, and that extends to what happens with broken or obsolete parts.
The Federal Aviation Administration (FAA) has long warned about the dangers of scrap aircraft parts re-entering service improperly.
FAA guidance is aimed at preventing scrapped or salvaged parts from being distributed and sold as serviceable products, to reduce the chance of unapproved parts winding up on airplanes.
In plain terms, once a part is declared scrap (unusable for flight), it should never again be represented as airworthy.
Companies have a responsibility to ensure these unairworthy parts don’t become a hidden danger.
An aircraft component that can’t be made airworthy is a hazard if someone later misrepresents it and uses it on an aircraft.
Considering this risk, many aerospace firms voluntarily take extra steps when disposing of parts that are beyond repair.
They will physically scrap or mutilate the part and often keep documentation of the destruction to protect themselves and others.
This kind of due diligence means that if a part is truly removed from circulation (and you have proof of it), it’s far less likely to ever mistakenly find its way back onto an aircraft.
The compliance obligations are even more formal if the scrap involves military or government-owned aircraft parts.
U.S. government regulations actually require that unsalvageable aircraft parts must be mutilated so they cannot be reused, and that a record of this destruction be kept.
In other words, agencies have to physically damage the parts (for example, cutting or crushing them) and retain a signed certification that the items were destroyed.
In the defense contracting world, companies may also have contractual obligations to provide proof of destruction for certain sensitive parts.
Whether by law or by industry expectation, the overarching goal in aerospace scrap compliance is clear: make sure no scrapped part can ever jeopardize flight safety.
The Role of the Certificate of Destruction (CoD)
This is where the Certificate of Destruction comes in. A CoD is a formal document that records the destruction of a part or material.
In the aviation context, it serves as solid evidence that a given part was disposed of properly and won’t be returning to the supply chain.
It has become standard in the industry to insist on a CoD whenever important components are scrapped.
Think of it as the final log entry for that part, confirming it met its end in a compliant manner.
The CoD plays a number of important roles.
These include:
- Compliance (including environmental compliance)
- Accountability
- Liability protection
All in all, the CoD is a simple yet powerful document: it ties up the loose ends of a part’s life by documenting its official destruction.
What Makes a Certificate of Destruction Valid?
Not all paperwork is created equal. For a Certificate of Destruction to do its job, it needs to contain the right information.
Here are some key details that a valid CoD should include:
- Date and time of destruction
- Description of the part(s) or material
- Method of destruction
- Statement of compliance
- Authorized signatures
When a CoD contains all of the above elements, it can truly stand up to scrutiny. It’s this completeness that gives the CoD its value in compliance.
Risks and Legal Consequences of Non-Compliance
Neglecting proper scrap compliance – or skipping that Certificate of Destruction – isn’t just cutting a corner. It can lead to serious consequences for both safety and business.
Some of the major risks include:
- Safety hazards: The most alarming risk is to flight safety. If a scrapped part isn’t adequately destroyed or documented, there’s a chance it could slip back into the supply chain.
An unairworthy part that reappears as a “serviceable” part is a recipe for disaster. History has shown that non-airworthy components, when misrepresented and installed on aircraft, can lead to accidents or incidents.
- Legal liability: From a legal standpoint, if an accident or incident is traced back to a part that should have been scrapped, the original owner of that part could face liability.
Even outside of an accident scenario, knowingly selling or transferring a part as airworthy when it is not is illegal. U.S. regulations prohibit the misrepresentation of unairworthy aircraft parts as serviceable.
Companies have been fined or sued in the past for letting faulty parts back into circulation.
Lax scrap practices could open the door to lawsuits, hefty fines, or other legal penalties.
- Regulatory penalties: Regulators like the FAA can impose sanctions on companies that violate aviation safety rules.
If an investigation reveals that a company’s negligence in handling scrap contributed to the presence of an unapproved part on an aircraft, the FAA could pursue enforcement action.
This might range from fines to the loss of repair station certificates or other business licenses.
- Contract breaches and lost business: In cases where contracts (such as with aircraft manufacturers, airlines, or the government) require proper disposal of parts, failing to produce a valid CoD could mean you’re in breach of contract.
If you can’t demonstrate compliance, you might lose that business. At the very least, it damages trust with your clients.
- Reputation damage: Word travels fast in the aerospace community. Being known as the company that lets a scrapped part slip back into service can severely hurt your reputation.
Customers and partners expect strict adherence to safety and compliance standards.
Protecting your reputation is yet another reason these scrap procedures, including getting that CoD, are not to be neglected.
Common Industry Practices in Scrap Disposal
The good news is that the aerospace industry as a whole recognizes these risks, and over time, it has developed sound practices to handle scrap correctly.
Most reputable companies follow similar approaches when disposing of aerospace parts:
- Clear internal policies: Organizations set internal guidelines or standard operating procedures for disposing of parts.
For example, removing identification plates or drilling holes and cutting up key components (“mutilation”) is a common practice to permanently mark a part as scrapped, aligning with FAA and government recommendations.
- Working with certified scrap vendors: Rather than just selling scrap metal to the nearest junkyard, aerospace firms often partner with specialized recycling, destruction, or scrap metal removal companies.
These vendors know the compliance requirements and will provide a Certificate of Destruction as part of their service, which their aerospace clients expect.
In fact, obtaining a CoD has become a normal practice for scrapping aircraft parts, and many third-party scrap processors offer it automatically.
- Comprehensive recordkeeping: Another widespread practice is maintaining detailed records of all scrapped parts.
Although it’s not mandated by law, most companies maintain logs or databases that list which parts were destroyed, along with their serial numbers and dates.
This documentation goes hand-in-hand with the CoD. If questions arise later, the company can pull up proof from its records.
- Following industry standards: Companies often align with industry standards or accreditation programs that stress scrap management.
Organizations like the Aviation Suppliers Association (ASA) publish best-practice guidelines to help prevent unsalvageable parts from creeping back into the market.
These guidelines encourage steps like those above – mutilation of parts, use of CoDs, and proper documentation.
Conclusion: Aerospace Scrap Compliance
Compliance in aerospace scrap disposal is about protecting everyone: the public, your customers, and your own organization.
A Certificate of Destruction may seem like a simple piece of paperwork, but it represents a key safety checkpoint. It ensures nothing falls through the cracks when parts are retired.
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