Instructions for Continued Airworthiness
ICA package evidence review for certification teams
This review checks that an ICA package describes how to maintain the configuration that was actually approved, not an earlier or partial one. It runs before the ICA is submitted, during a finding response, or when a design change ripples into maintenance instructions, and it is done by or with the team accountable for the certification data. The work examines the maintenance tasks, airworthiness limitations, illustrated parts data, and configuration coverage in the package, and it flags every place the instructions lag the approved design or leave a serviced item without a procedure. You receive a gap list, an evidence map tying instructions to the configuration they cover, and a closure sequence compliance management can work in order.
When this review is needed
- An ICA package is nearly complete and the team needs it reconciled to the approved configuration before submittal.
- A finding questions whether the airworthiness limitations section reflects the substantiated life and inspection intervals.
- A design change added or modified equipment and the maintenance instructions have not yet caught up.
- The installation adds parts to an existing type and the ICA has to integrate cleanly with the aircraft-level instructions.
The problem
ICA is written toward the end of a program, when the design is supposed to be settled, but late changes keep arriving. A modification adds a component, a limitation gets revised as analysis matures, a part number changes at release, and the ICA has to absorb each of these without gaps. Because the package spans maintenance tasks, limitations, and parts data authored by different groups, an item can be added to the configuration and never picked up by a maintenance procedure, or a limitation can lag the value the substantiation now supports.
What gets reviewed
- Maintenance tasks checked for coverage of every serviced item in the approved configuration
- Airworthiness limitations reconciled to the lives and intervals the substantiation actually supports
- Illustrated parts data confirmed against the released part numbers and effectivity
- Configuration coverage checked so added or modified equipment has corresponding instructions
- Interfaces with the aircraft-level ICA checked for tasks that fall between the installation and the platform
- ICA references confirmed against the certification basis and the approved type design
What gets validated
- Every serviced item in the approved configuration has at least one maintenance task addressing it
- Each airworthiness limitation matches the life or interval the supporting analysis substantiates
- Part numbers and effectivity in the illustrated parts data agree with the released configuration
- Tasks that span the installation and the platform are assigned rather than left in the seam
- Limitations and tasks reference the approved data they derive from, not superseded values
Evidence normally required
- The draft ICA package, including maintenance tasks, limitations, and illustrated parts data
- The approved configuration and released part numbers with effectivity
- The substantiation behind each airworthiness limitation
- The aircraft-level ICA the package has to integrate with
- The certification basis and any prior findings on continued-airworthiness instructions
Common discrepancies
- A component added by a late modification with no maintenance task covering it
- An airworthiness limitation carrying an interval superseded by later substantiation
- Illustrated parts data citing a part number changed at release
- A task that neither the installation nor the aircraft-level ICA clearly owns
What is at stake
An ICA that trails the approved configuration ships instructions an operator cannot fully execute, which surfaces as a finding at submittal or as a field problem after entry into service. An airworthiness limitation that understates a life or interval is a safety exposure; one that overstates it is a warranty and compliance exposure. Either way the package has to be reopened and reconciled, often after the design has already been frozen.
Move from findings to resolution
Identify gaps against the means of compliance.
How the work runs
Map the configuration
List every serviced item in the approved configuration the ICA has to cover.
Check task and limitation coverage
Confirm each item has a maintenance task and that limitations match the current substantiation.
Reconcile parts and interfaces
Verify part numbers and effectivity, and assign tasks that span the installation and platform.
List and order the gaps
Record each lag and sequence closure so limitations and configuration fixes precede referencing tasks.
What the buyer receives
- A gap list naming each serviced item, limitation, or part where the ICA lags the approved design
- An evidence map linking each instruction to the configuration and substantiation it covers
- A closure sequence ordered so limitation and configuration corrections precede the tasks that reference them
Who uses the output
- Compliance management confirming the ICA reflects the approved configuration before it is submitted
- Maintenance-engineering authors closing the coverage and limitation gaps that are flagged
- Certification leadership judging whether the package is ready or needs a reconciliation pass
How the work fits into the transaction or program
The review runs late in the program, after the design settles but before the ICA is submitted, catching the maintenance instructions up to the approved configuration. Its gap list drives the task and limitation corrections that have to close before the package supports a finding and before an operator receives instructions it can execute.
Start with a single asset
Confirm requirements trace through verification.
Jurisdiction-specific considerations
FAA and EASA both require ICA and both control the airworthiness limitations section, but they format and place the limitations differently and expect the ICA to fit their own approval routes for installations on an existing type. The review notes where a package built for one authority needs its limitations restructured or re-referenced to be acceptable to the other.
Regulatory limits
The review checks the ICA for completeness and configuration match. It does not approve the instructions, accept the airworthiness limitations, or make a compliance finding. Approval of the ICA and its limitations rests with the applicant's authorized representatives and the authority.
What this review does not cover
- Authoring the maintenance tasks, limitations, or illustrated parts data
- Approving the ICA or its airworthiness limitations section
- Performing the underlying life or inspection-interval substantiation
Specific to this review
- The airworthiness limitations section is the highest-consequence part of the ICA, because an understated interval is a direct safety exposure and it is controlled separately from the rest of the package.
- Late modifications are the usual source of coverage gaps: the design change lands, but the maintenance task that should follow it does not get authored in time.
- Tasks that fall between an installation's ICA and the aircraft-level ICA are the ones operators discover in service, because neither package clearly owns them.
Sources
U.S. Government (eCFR). Type certificates, STCs (Subpart E), TSO authorizations (Subpart O), PMA (Subpart K), and export airworthiness approvals (Subpart L).
Federal Aviation Administration. STC application process, certification basis, and continued airworthiness obligations of an STC holder.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
Our design is frozen. Why would the ICA not already match it?
A frozen design and a reconciled ICA are different milestones. The instructions are authored by separate groups from the design data, and the last changes before freeze are exactly the ones the ICA most often has not yet absorbed. The review targets that lag.
Relevant glossary terms
Related pages
Where this fits
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