ARSA's ICA Action

Background:

Instructions for Continued Airworthiness (ICA) are the manuals required to maintain aircraft in airworthy condition.

The Federal Aviation Regulations require the holders of design approvals to prepare ICAs and make them available to persons required to comply with the terms of the instructions, including owners and repair stations that perform maintenance on the products.

   Text of Title 14 CFR section 21.50

Here's how you can help ARSA with this issue, along with some pertinent information regarding our efforts to date.

Member Involvement:

While ARSA continues to work on this issue, your support remains critical to our ultimate success. Here’s what you can do to help:

ICA Draft Order

The Federal Aviation Administration has amended Order 8110.54A, Instructions for Continued Airworthiness Responsibilities, Requirements, and Contents. The amendments clarify responsibilities for affected parties and PMA Instructions for Continued Airworthiness (ICA) applicability. They include the review and acceptance of ICAs delegated to qualified delegated organizations. It updates the ICA process to include Electrical Wiring Interconnection Systems and addresses the responsibilities, requirements, and content for ICA for foreign validation certification projects.

The draft order may be found here.

Chronology:

May 18, 2009: ARSA Requests ICA Legal Interpretation.
   ARSA Interpretation Request

November 6, 2008: ARSA sends rebuttal to EASA ICA ruling.
   ARSA rebuttal letter

July 3, 2008: ARSA receives second response from EASA clarifying agency's ICA position.
   EASA second response

May 30, 2008: ARSA receives clarification from EASA on ICA requirements.
   EASA response | ARSA article

March 5, 2008: ARSA files complaint with EASA regarding failure of Rolls-Royce and Airbus to provide maintenance instructions, with attached copies of the FAA part 13 complaint.
   EASA ICA Complaint

February 29, 2008: ARSA files a part 13 complaint with the FAA against Parker-Hannifin for failure to provide maintenance instructions on a PMA part.
   ARSA PMA Complaint

April 18, 2007: ARSA’s comments to Part 145 include a request to remove language that requires repair stations to have ICA to become certificated (see page 8 of ARSA’s comments):
   ARSA Part 145 comments

February 28, 2006: Rolls-Royce filed a response.
   Rolls-Royce Response (.pdf)

November 23, 2005: ARSA filed a complaint with the FAA against Rolls-Royce for failure to provide complete engine overhaul instructions to an ARSA member.
   Rolls-Royce Complaint (.pdf)

July 1, 2005: Unfortunately the FAA did not take ARSA's deliberations into consideration, and its issuance of Order 8110.54 did not clarify the issue.
   FAA Order 8110.54 (.pdf)

August 20, 2004: ARSA formed a joint industry policy committee, composed of a variety of manufacturers, repair stations, and carriers who submitted comments to the FAA on ICA guidance material. A copy of those comments are here:
   Joint Industry Policy

December 10, 2003: Airbus responded to ARSA’s complaint although the FAA has not issued a response.
   Airbus Response (.pdf)

October 3, 2003: ARSA’s first complaint on availability of maintenance manuals (or ICA) was filed with the FAA.
   Airbus Complaint (.pdf)

April 14, 2003: FAA issues legal interpretation detailing when component maintenance manuals are considered part of ICA's
   FAA/McCurdy Legal Interpretation

March 30, 2002: Research reveals how other agencies carry out requirements to “make available” maintenance information.
   Other Agency Actions (.pdf)

January 10, 2001: The Federal Aviation Regulations (FARs) and their predecessor, the Civil Air Regulations have long required that ICA be provided. The attached memo is a complete history of ICA regulations.
   History of U.S. ICA regulations, 1941-1980 (.pdf)

December 13, 1999: A legal opinion issued by the FAA (the Whitlow Letter) supports ARSA’s position that complete instructions be made available.
   Whitlow Letter(.pdf)