Instructions for continued airworthiness evidence review for equipment suppliers

When this review is needed

• The ICA was drafted early against a preliminary design and the configuration has moved since.
• An airworthiness limitation from the safety assessment may not have made it into the limitations section.
• A finding asks the supplier to show the maintenance tasks cover every part and mode of the approved equipment.
• A design change altered a serviceable part or an inspection interval and the ICA has not caught up.

The problem

The ICA is usually the last package written and the first to fall out of date. It is drafted while the design is still moving, so tasks describe a configuration that later changed, part numbers name items that were superseded, and the airworthiness limitations that must flow from the safety assessment are the ones most easily left incomplete. Because the ICA is delivered late, no one rereads it against the configuration that was finally approved.

What gets reviewed

• Coverage check that maintenance tasks address every part and function of the approved equipment
• Confirmation that the airworthiness limitations reflect those the safety assessment requires
• Read of part numbers and configuration data against the approved configuration
• Consistency check between tasks, intervals, limitations, and referenced procedures
• Review of whether design changes after the draft reached the ICA
• Identification of tasks or parts describing a superseded configuration

What gets validated

• Maintenance tasks cover every serviceable part and failure mode of the approved equipment
• The airworthiness limitations section includes every limitation the safety assessment mandates
• Part numbers and configuration references match the approved configuration
• Inspection intervals and task references are internally consistent across the package
• Design changes after the ICA draft are reflected in the tasks and parts data

Evidence normally required

• The ICA package, including maintenance tasks, limitations, and parts data
• The approved or intended configuration for the equipment
• The airworthiness limitations derived from the safety assessment
• The design change history since the ICA was first drafted
• Any component maintenance manual or service data referenced by the ICA

Common discrepancies

• Maintenance tasks written against a part number the design later superseded
• An airworthiness limitation from the safety assessment missing from the limitations section
• Inspection intervals inconsistent between the task list and the limitations section
• A design change that added a serviceable item the ICA never picked up

What is at stake

An ICA that lags the approved configuration puts an operator in the position of maintaining the equipment against instructions for a version that no longer exists. On the certification side, an incomplete airworthiness limitations section is a direct finding, because those limitations are mandatory and their absence is not a matter of judgment. Fixing it late means reopening the package after the design data is otherwise closed.

How the work runs

What the buyer receives

• A gap list of ICA coverage and currency issues against the approved configuration
• An evidence map from each configuration item to the task and limitation that address it
• A closure sequence ordering revisions by whether they touch mandatory limitations first

Who uses the output

• Engineering leadership scoping the ICA revision before the package is submittable
• Certification leads confirming the mandatory limitations are complete for the authority
• Continued-airworthiness authors reconciling tasks and parts to the approved configuration

How the work fits into the transaction or program

The ICA is where the certified design becomes maintainable in service, so it is checked against the configuration management review that fixes the approved baseline and the safety assessment review that sets the mandatory limitations. This review confirms the delivered instructions describe that baseline and carry those limitations before the package leaves the supplier.

Jurisdiction-specific considerations

The FAA requires ICA under its type and supplemental type certification rules with the airworthiness limitations section segregated and approved, while EASA carries an equivalent expectation under its continued-airworthiness framework. Both treat the limitations as mandatory, so this review distinguishes the approvable limitations content from the advisory maintenance content that each authority handles differently.

Regulatory limits

This review checks ICA coverage and currency against the approved configuration. It makes no airworthiness determination, approves no instructions, and does not set or approve airworthiness limitations. Approval of the limitations and acceptance of the ICA rest with the authority and its delegates.

What this review does not cover

• Writing or revising the maintenance tasks, limitations, or parts data
• Determining or approving airworthiness limitation intervals
• Assessing the maintainability of the equipment in service operation

Specific to this review

• The ICA is written first against a moving design and delivered last, which is why it so often describes a configuration the program has already left behind.
• The airworthiness limitations section is the part with the least tolerance for gaps, because those limitations are mandatory and a missing one is a finding rather than a discussion.
• A design change that adds a serviceable item is the currency failure that hides best, since a new part with no task simply reads as absent rather than wrong.

Sources

Frequently asked questions

Relevant glossary terms

Related pages

Where this fits