ICA evidence gap
Missing instructions for continued airworthiness in the records
A missing ICA package means a modification, repair, or alteration was installed without the instructions for continued airworthiness that tell the operator how to maintain it. It surfaces for lessors, airlines, and MROs when the maintenance program is rebuilt or audited and a change has no recurring tasks behind it. The check reads the modification list, the approval data, and the maintenance program against the ICA each change should carry. You receive a list of changes with no ICA on file and the path to obtain or reconstruct each one.
When this review is needed
- A maintenance program is being rebuilt for a new operator and each installed change has to map to its recurring tasks.
- An audit finds a modification on the configuration list that the maintenance program never absorbed.
- A repair was embodied under an approval whose ICA supplement was never filed with the aircraft records.
The problem
An approval can release a modification to service while the document that tells the operator how to maintain it is left behind at the design organization or the installing shop. The change shows on the configuration list, the work that installed it is signed off, but the inspections, life limits, and special tasks it introduced never enter the maintenance program. The aircraft then runs against a program that does not cover everything fitted to it.
What gets reviewed
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What gets validated
- Every installed change has an ICA or maintenance supplement present in the records
- The recurring tasks in each ICA appear in the operator's maintenance program
- Life limits and inspection intervals from the ICA are tracked, not merely filed
- The ICA references the same approval and configuration as the embodiment record
- Superseded ICA revisions are replaced by the current issue applicable to the change
Evidence normally required
- Configuration and modification status list
- STC, repair, and alteration approval documents
- Maintenance program task list or its digital equivalent
- ICA supplements and continued-airworthiness documents on file
Common discrepancies
- A modification on the configuration list with no ICA anywhere in the records
- An ICA on file whose recurring tasks were never loaded into the maintenance program
- A superseded ICA revision still governing a change the program tracks
- A repair approval present but its continued-airworthiness instructions absent
What is at stake
A change with no ICA can leave recurring tasks unaccomplished because the program never knew to schedule them. Closing the gap may mean recovering the supplement from the approval holder or reconstructing the tasks from the approval basis, and at a transition the missing ICA blocks the receiving operator from accepting the configuration.
Move from findings to resolution
Sequence the fixes and the documentation that closes each finding.
How the work runs
List the embodied changes
Pull every modification, repair, and alteration on the configuration list for the specific aircraft.
Match each to its ICA
Check whether the supplement or continued-airworthiness instructions for each change are present in the records.
Test incorporation
Confirm the recurring tasks, life limits, and intervals from each ICA actually appear in the maintenance program.
Set the recovery path
For each gap, identify whether to source the supplement from the approval holder or reconstruct tasks from the approval basis.
What the buyer receives
Who uses the output
- Continuing-airworthiness staff loading the recovered tasks into the program
- Engineering deciding whether a supplement can be sourced or must be rebuilt
- Records teams closing the configuration gap before a transition
How the work fits into the transaction or program
The review separates an ICA gap from a broader configuration problem, so a change that is approved and installed but missing only its maintenance instructions is handled distinctly. It feeds the maintenance program rebuild and the discrepancy register a transition depends on.
Aircraft-specific considerations
The volume of ICA supplements grows with how heavily a type has been modified, so a cabin-reconfigured or avionics-upgraded airframe carries more supplements to reconcile than a near-baseline one. The check is scoped to the modifications actually embodied on the specific tail rather than a generic list for the type.
Jurisdiction-specific considerations
An ICA accepted under one authority is read against the program the aircraft is moving to. A supplement written for an FAA approval may need mapping before its tasks sit cleanly in an EASA continuing-airworthiness program, so the gap is assessed against the receiving system.
Regulatory limits
The review confirms whether the instructions for continued airworthiness are present and incorporated. It does not write or approve an ICA, set maintenance intervals on the authority's behalf, or make an airworthiness determination.
What this review does not cover
- Authoring or approving an ICA or maintenance supplement
- Setting inspection intervals or life limits on the authority's behalf
- Embodiment or rework of the modification itself
Specific to this review
- An ICA is the bridge between a one-time approval and the recurring program, so a change can be fully approved and still leave the program incomplete when its ICA is absent.
- Recovery often means obtaining the supplement from the approval holder rather than the operator, because the document originates with the design data, not the aircraft file.
- An ICA on file is checked separately from an ICA incorporated, since a filed supplement whose tasks never reached the program leaves the same exposure as a missing one.
Sources
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
Federal Aviation Administration. Completion and use of FAA Form 8130-3, Authorized Release Certificate, for new and used parts.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
Frequently asked questions
Is a missing ICA the same as a missing approval?
No. The approval can be present while its ICA is absent. The approval shows the change was permitted; the ICA tells the operator how to keep maintaining it, and the program is incomplete until those tasks are incorporated.
Can you write the ICA if it cannot be found?
We do not author or approve an ICA. We identify the gap, list the recurring tasks the change should carry, and map the path to obtain the supplement from the approval holder or escalate reconstruction to the appropriate design data holder.
Relevant glossary terms
Related pages
Where this fits
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