ICA evidence
ICA package evidence review for quality teams
An ICA package evidence review checks that the Instructions for Continued Airworthiness delivered with a design change describe the configuration that was actually approved, and that every maintenance task, limitation, and part reference has a basis behind it. Quality teams run it ahead of a submittal, a finding response, or a design-change review. It examines task coverage, airworthiness limitations, illustrated parts data, and configuration effectivity, then ties each element to the certification basis. You receive a gap list, an evidence map, and a closure sequence for quality leadership.
When this review is needed
- An STC or design change is nearing submittal and its ICA has to match the configuration under approval.
- A finding questions whether the maintenance tasks cover every part the change introduced.
- The airworthiness limitations section has to be reconciled to the substantiation that sets each limit.
- The design moved late and the ICA drafted against the earlier configuration was never revised.
The problem
ICA is usually written alongside the design, then frozen while the design keeps moving. By submittal the maintenance tasks, the airworthiness limitations, and the illustrated parts data can each describe a slightly earlier configuration, and no single person owns reconciling all three back to what was approved. A quality team inherits a package that reads as complete but where a task references a part number the change superseded, or a limitation has no traceable substantiation.
What gets reviewed
- Maintenance task coverage checked against every part and system the change introduced
- Airworthiness limitations traced to the substantiation that establishes each interval
- Illustrated parts data reconciled to the approved configuration and effectivity
- Servicing, inspection, and removal procedures matched to the as-approved design
- Effectivity of the ICA confirmed against the serial or model range the change applies to
- Open ICA items sequenced by their effect on submittal and on in-service maintainability
What gets validated
- Each maintenance task references a part number and configuration that exist in the approved design
- Every airworthiness limitation traces to substantiation, not to a value carried forward without basis
- Parts data matches the effectivity of the change rather than an earlier revision
- Removal, installation, and servicing procedures reflect the configuration that was approved
- ICA effectivity agrees with the applicability stated in the approval itself
Evidence normally required
- The draft or delivered ICA package, including the airworthiness limitations section
- The approved configuration list and the design-change documentation
- Substantiation supporting each limitation and inspection interval
- The certification basis and the compliance claims the ICA supports
- Illustrated parts data and effectivity records for the change
Common discrepancies
- A maintenance task that calls out a part number the design change superseded
- An airworthiness limitation with an interval that no substantiation on file supports
- Illustrated parts data drawn from a configuration earlier than the one approved
- An ICA effectivity that names a broader model range than the approval actually covers
What is at stake
An ICA that lags the approved configuration puts an operator at risk of maintaining the change to the wrong instructions once it enters service. At certification it draws a finding that stalls the approval, and a limitation without traceable substantiation can force the whole airworthiness limitations section back to engineering while the submittal waits.
Move from findings to resolution
Identify gaps against the means of compliance.
How the work runs
Bound the change
Establish the approved configuration and every part and system the design change introduced.
Check task and limit coverage
Confirm maintenance tasks cover the change and each limitation traces to substantiation.
Reconcile parts and effectivity
Match illustrated parts data and ICA effectivity to the approved configuration.
Sequence the gaps
List the mismatches and order them by submittal impact and in-service risk.
What the buyer receives
- A gap list identifying each ICA element that does not track the approved configuration
- An evidence map linking limitations and tasks to their substantiation and the certification basis
- A closure sequence ordering the gaps by submittal impact and in-service risk
Who uses the output
- Quality leadership judging whether the ICA is ready to accompany the approval
- Certification engineers answering a finding on task coverage or limitation basis
- Engineering teams updating ICA content that lagged a late design change
How the work fits into the transaction or program
The review runs where the design freezes and the ICA has to be reconciled to it before submittal. Its gap list drives the revisions engineering makes to the package, and its evidence map gives the reviewer a path from each limitation and task to the substantiation that supports it.
Start with a single asset
Confirm requirements trace through verification.
Jurisdiction-specific considerations
FAA and EASA both require ICA with a design approval, but they structure the airworthiness limitations section and its approval status differently. A review supporting both notes where a limitation accepted under one authority's format needs restating for the other, and where the limitations section must be separately identifiable for approval.
Regulatory limits
The review reconciles the ICA to the approved configuration and to its substantiation. It does not approve the ICA, set an airworthiness limitation, or determine that the continued-airworthiness instructions are adequate for service.
What this review does not cover
- Authoring the maintenance tasks or the airworthiness limitations section
- Establishing or approving an inspection interval or life limit
- Any airworthiness determination on the continued-airworthiness instructions
Specific to this review
- The airworthiness limitations section is the part of the ICA most often missing traceable substantiation, because intervals get carried forward from a prior design without re-derivation.
- ICA lags the design because it is drafted early and rarely revised for late changes, so the parts data is where the mismatch usually shows first.
- An ICA that names a wider effectivity than the approval covers is a finding waiting to happen, since the instructions then claim applicability the approval never granted.
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
Does this review approve the airworthiness limitations, or just check them?
It checks them. The review confirms each limitation traces to substantiation and that the limitations section matches the approved configuration, so the package is defensible at submittal. Approving a limitation rests with the authority, and the review does not substitute for that.
Relevant glossary terms
Related pages
Where this fits
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