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Aircraft Parts, FAA, FAA Design Approval, International Trade, Manufacturing, PMA, Policy

International Regulators Discuss Instructions for Continued Airworthiness (ICAs)

At the recent EASA-FAA International Aviation Safety Conference, Tom Howard of Chromalloy asked about the status of the EASA ICA working group which was supposed to be examining strategies for updating the requirements and regulations surrounding Instructions for Continued Airworthiness (ICAs).

The EASA rulemaking group is known by the designation MDM.056.  This group was tasked with addressing issues like:

  • What information is considered to be a part of the ICA?
  • What do you do with information that is published as maintenance instructions but that is not considered to be part of the ICA?
  • Who is entitled to receive/obtain ICA?

In an April 2011 meeting, FAA, EASA and TCCA met to discuss their progress and status on ICA issues. They found that the ICA issues were issues that were being addressed in all three jurisdictions.  They also agreed to split the ICA issues into several sub-tasks, because the original assigned scope of the rulemaking group was too broad.  Work on the EASA group was halted in order to permit better international coordination of the investigation into the ICA issues.

EASA expects to resume work on ICA-related projects next year, with partners from the US and Canada.  In the mean time, the three authorities are developing a regulatory impact assessment to define areas of common interest.  This project is expected to last through 2012, which means that the actual work of addressing ICA issues will not resume until 2012 at the earliest.

Irwin Fleuberger of Austrian Airlines explained that there are some definitions concerning ICAs and the sections that must be included in them – and these need to be harmonized across the authorities.

Walter Desroisier of GAMA is a member of MDM.056.  He explained that there is a vast difference in the understanding of what constitutes ICA in the United States versus what constitutes ICA in Europe.  There are also differences among manufacturers in the elements that they put together in their ICAs.

One source of confusion, according to Desroisier, is that there is maintenance  data that is not ICA. Manufacturers can provide additional maintenance information that is not part of the body of material that is regulated as ICA.  Another source of confusion is found in component maintenance manuals.  A component maintenance manual is part of the ICA if the design approval holder for the product (aircraft or engine) incorporates the  component maintenance manual into the product ICA. However, if it is not incorporated by refernece, then it is not part of the ICA for the higher-level assembly or product.

FAA Engineering Division Manager David Hempe explained that ICA requirements have evolved over time.  Failure to follow ICAs has resulted in accidents, so this is an important safety issue.  He pledged that his office would continue pursuing better ICA guidance.

Howard also asked whether observers would be permitted at the future rulemaking group meetings on ICAs.  EASA Juan Anton explained that EASA does not permit observers in the working group.  Tomorrow afternoon there will be a panel addressing ICA. There were 24 persons on the ICA working group. Following an April 2011 meeting with the FAA, EASA decided that it’s ICA group’s scope was top broad.  EASA is working with FAA to identify areas of common interest.  The Working Group has been suspended while the ICA tasks are revised. EASA expects to be able to continue work on ICAs in 2012.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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