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aviation, FAA, FAA Design Approval, Manufacturing, PMA, Policy, Repair Stations

Former FAA Manager Giles Discusses New ICA Policies and Old ICA Rules

Carol Giles Leads the Conference in a Discussion of Instructions for Continued Airworthiness

On October 4 at the MARPA Conference, Carol Giles, retired FAA Maintenance Division Manager and current President of Carol E. Giles & Associates, discussed some of the regulatory challenges and compliance issues currently facing the maintenance industry that also have an effect on PMA manufacturers.  She particularly focused on Instructions for Continued Airworthiness (ICA).

Giles noted that a number of air carriers have moved away from MRO to focus on their core business.  In response, a number of design approval holders took advantage of this opportunity to restrict ICA access to MRO facilities under the guise of protecting intellectual property.

She explained that although the FAA is loathe to enter into commercial issues, they reached a tipping point as these restrictions on ICA use began to interfere with the public’s ability to comply with the safety regulations.  The FAA issued a policy statement addressing the practices that restrict the availability or use of  ICA.  The FAA policy explained that FAA design approval holders may not inhibit an owner or operator from distributing ICAs to current or future maintenance providers.  Similarly, design approval holders are not allowed to use the ICAs as a naked vehicle to monopolize the parts market.

ICAs represent an issue on which MARPA has continued to provide industry leadership.  MARPA will continue to work closely with the government to ensure that ICAs are able to support aviation safety.

If you missed the 2012 MARPA Annual Conference, then you can still track MARPA’s developments and the industry and regulatory changes that affect the PMA industry by joining MARPA.


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 Air Carrier Purchasing Conference, and the Modification and Replacement Parts Association. He also represents private clients drawn from the spectrum of the aviation industry.


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