Instructions for continued airworthiness evidence review for avionics suppliers

When this review is needed

• An ICA package is heading into a submittal and no one has checked it against the configuration that was finally approved.
• A design change late in the program altered parts or tasks and the maintenance data may not reflect it.
• A finding asks whether the airworthiness limitations section covers every limitation the approval established.
• The equipment is being installed on a new aircraft type and the ICA has to reconcile with that installation.

The problem

ICA are written toward the end of a program, when the design is still moving, so they chase a configuration that keeps changing under them. A part number gets revised, a task gets added to cover a new failure mode, a limitation shifts, and the ICA document, drafted weeks earlier, quietly falls a revision behind. The maintenance data looks complete because every section is filled in, but the sections describe the airplane the design was, not the one it became.

What gets reviewed

• Maintenance tasks checked against the approved configuration and the failure modes the design introduced
• Airworthiness limitations section confirmed to carry every mandatory limitation the approval established
• Parts data and part numbers reconciled against the released, approved configuration
• Task intervals and procedures checked for consistency with the maintenance program assumptions
• Configuration coverage confirmed so the ICA describes the latest revision, not an earlier draft state
• Installation-specific content checked where the equipment goes onto a defined aircraft type

What gets validated

• Every maintenance task traces to a feature or failure mode of the approved configuration
• The airworthiness limitations section contains each mandatory limitation the approval set
• Part numbers in the ICA match the released, approved configuration
• Task intervals are consistent with the assumptions the maintenance program is built on
• The ICA revision reflects the latest approved configuration, not a superseded design state

Evidence normally required

• The ICA package with its maintenance tasks, limitations, and parts data
• The approved configuration definition and the design change history behind it
• The airworthiness limitations established by the approval
• Parts lists and part number records for the released configuration
• The installation definition where the equipment goes onto a specific aircraft type

Common discrepancies

• A maintenance task set written to a configuration one revision behind the approved design
• An airworthiness limitation established by the approval that never reached the limitations section
• Part numbers in the ICA that a late change superseded in the approved configuration
• A new failure mode covered in the safety assessment but with no corresponding maintenance task

What is at stake

ICA that lag the approved configuration send the wrong maintenance instructions into service, where the gap is discovered by the operator rather than the supplier. A missing airworthiness limitation is worse, because the limitations section carries mandatory content, and an omission there can hold the approval or force a revision after the fact. The cost of catching it in service dwarfs the cost of reconciling the ICA before submittal.

How the work runs

What the buyer receives

• A gap list naming each task, limitation, or part number that the approved configuration outran
• An evidence map tying ICA content to the approved configuration and its limitations
• A closure sequence separating mandatory limitations content from routine task and parts updates

Who uses the output

• Certification leadership deciding whether the ICA are current enough to submit
• Maintenance engineering staff who need the specific tasks and part numbers to correct
• The team answering a finding about the completeness of the airworthiness limitations section

How the work fits into the transaction or program

The ICA are the bridge from certification into service, translating the approved design into the maintenance a fleet will actually perform. This review checks that the bridge reflects the design as approved, so the maintenance data enters service matching the configuration rather than trailing it, which is where continued-airworthiness gaps begin.

Jurisdiction-specific considerations

FAA and EASA both require ICA as a condition of approval and both treat the airworthiness limitations section as mandatory, approved content that maintenance cannot relax. The review reads the ICA against whichever approval basis and installation the program is pursuing, since the limitations that must appear and the tasks that must be covered follow from the specific approved configuration.

Regulatory limits

This review reports whether the ICA cover the approved configuration and its limitations. It does not approve the ICA, does not accept the airworthiness limitations, and does not make an airworthiness determination. Approval of the ICA and the limitations section remains with the authority under the applicable rule.

What this review does not cover

• Authoring the missing maintenance tasks, limitations, or parts data
• Approving the ICA or the airworthiness limitations section
• Establishing the maintenance program the operator will run

Specific to this review

• ICA are unusually exposed to late design change because they are drafted last, so they inherit whatever configuration drift the final weeks of a program produced.
• The airworthiness limitations section is the one part of an ICA that is mandatory and approved rather than advisory, which makes an omission there a different class of problem from a missing routine task.
• A new failure mode in the safety assessment should generate a maintenance task, and the missing link between the two is a common gap the ICA alone never reveals.
• Installing the same equipment on a new aircraft type reopens the ICA even when the box is unchanged, because intervals and procedures depend on the installation rather than the article alone.

Sources

Frequently asked questions

Relevant glossary terms

Related pages

Where this fits