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FQA99 (P.L. 106-34) Fastener coverage exemptions

You should read the entire official text of the law. It is only about 10 pages in length. There will be no excuse for not being familiar with FQA99, and there are criminal and civil penalties for failure to comply.

The Definition of a fastener as stated in FQA99 (P.L. 106-34) Section 3. --

"`(6) `fastener' means a metallic screw, nut, bolt, or stud having internal or external threads, with a nominal diameter of 6 millimeters or greater, in the case of such items described in metric terms, or 1/4 inch or greater, in the case of such items described in terms of the English system of measurement, or a load-indicating washer, that is through-hardened** or represented as meeting a consensus standard that calls for through-hardening, and that is grade identification marked*** or represented as meeting a consensus standard that requires grade identification marking, except that such term does not include any screw, nut, bolt, stud, or load-indicating washer that is --"

This definition is followed by a number of EXEMPTIONS summarized below: (the actual official text of the exemptions may be seen at FQA99 (P.L. 106-34).)

Summary: Which fasteners are NOT covered by FQA99 (P.L. 106-34) --

All fasteners are exempt from FQA99 if they have a nominal diameter of less than 6 millimeters, in the case of such items described in metric terms.

All fasteners are exempt from FQA99 if they have a nominal diameter of less than 1/4 inch, in the case of such items described in terms of the English system of measurement.

All fasteners are exempt from FQA99 if they are not through-hardened**.

All fasteners are exempt from FQA99 if they are not represented as meeting a consensus standard that requires grade identification marking.

All fasteners are exempt from FQA99 if they were manufactured by an ISO 9000 certified entity or another listed QAS. (see Section 3(7) of FQA99 for a listing of other certified QAS organizations).

All fasteners are exempt from FQA99 if they are packaged in a container of 75 pieces or less and are labeled for use as a spare, substitute, service, or replacement part.

All fasteners are exempt from FQA99 if they are part of an assembly.

All fasteners are exempt from FQA99 if they are a part that is contained in an assembly kit, regardless of quantity.

All fasteners are exempt from FQA99 if they are produced and marked as ASTM A 307 Grade A.

All fasteners are exempt from FQA99 if they are produced in accordance with ASTM F 432.

All fasteners are exempt from FQA99 if they are manufactured to a proprietary standard.

All fasteners are exempt from FQA99 if they are specifically manufactured for use on an aircraft if the quality and suitability of those fasteners for that use has been approved -- `(i) by the Federal Aviation Administration; or `(ii) by a foreign airworthiness authority as described in part 21.29, 21.500, 21.502, or 21.617 of title 14 of the Code of Federal Regulations.

All fasteners are exempt from FQA99 if they are manufactured by `(B) any fastener manufacturing system -- `(i) that has as a stated goal the prevention of defects through continuous improvement; `(ii) that seeks to attain the goal stated in clause (i) by incorporating --`(I) advanced quality planning.

All fasteners are exempt from FQA99 if they are manufactured by an entity that `(II) undergoes regular or random evaluation and assessment by the end user or end users of the screws, nuts, bolts, studs, or load-indicating washers produced under such fastener manufacturing system to ensure that such system meets the requirements of clauses (i) and (ii).

If the fastener meets ANY of the exemptions listed above then it is NOT a covered fastener.


**Further clarification on several points as to what is considered a through hardened fastener under FQA99.
Externally threaded (bolts, screws) steel fasteners from class 8.8 and up are considered through hardened. Internally threaded (nuts) steel fasteners from class 8 and class 9 are NOT considered through hardened. Internally threaded (nuts) steel fasteners from class 10 and up are considered through hardened. Stainless steels in the 'A' austenitic (A1, A2, A4) and 'C' martensitic (C1, C3, C4) series are NOT considered through hardened. Stainless steels in the 'F' ferritic (F1) series are considered through hardened. Case hardened, solution hardened and mechanically hardened fasteners are NOT considered through hardened.

***Another curious side effect of the FQA99 fastener definition is that while metric sized socket head cap screws are covered because their consensus standards require class (grade) marking, USA sized socket head cap screws are exempt because the USA consensus standards do not require grade marking.


Summary: What fasteners are ARE covered by FQA99 (P.L. 106-34) -- More detailed commentary from MINA will follow later after we have completed further analysis of FQA99. However, remember that to even be considered as a covered fastener, ALL of the following basic criteria must be met:

  • It must be made of metal.
  • It must have internal or external threads, with a nominal diameter of 6 millimeters or 1/4 inch or greater, or must be a load indicating washer.
  • It must be through-hardened.
  • It must be BOTH through-hardened and be made TOTALLY to a 'consensus standard' that requires property class or grade marking. (Note: a 'consensus standard' is different from a 'contractual specification'.)
    The official list of consensus standards organizations can be found here.
Implementation: Remember that basically -- FQA99 shall be applicable only to fasteners fabricated after December 6, 1999, and that the use of accredited laboratories - will not take effect until 2 years after that.
06/10/99, REV. 09/14/99, 11/21/99, 11/25/99
Note: MINA will refer to the 'Fastener Quality Act Amendments Act of 1999' (P.L. 106-34), as 'FQA99™'.
Press notice: You are welcome to freely use any MINA materials. Just credit MINA as the source. Be advised that any communications from MINA should not be taken as legal advice.

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