Pre-submittal review
Closing ICA package gaps against the approved configuration
An ICA gap-closure pass checks whether your Instructions for Continued Airworthiness actually describe how to maintain the configuration you are getting approved. It runs before submittal, once the design and its approved configuration are settled, and it is done for the applicant's certification team. The pass walks the approved parts, modifications, and effectivities against the ICA and finds where a part has no maintenance task, a limitation is missing, or an affected configuration is uncovered. You get a closure brief, an evidence request list, and a disposition package that maps every part, task, and limitation into an ICA a reviewer can accept.
When this review is needed
- An STC added parts or a modification the existing ICA was never written to cover.
- The approved configuration carries life limits or inspection intervals the ICA does not yet state.
- Effectivity changed across configurations and the ICA still reflects only one of them.
- A reviewer is expected to check the ICA against the approved data and the team wants coverage confirmed first.
The problem
ICA gets written alongside a moving design and often lags what the approval finally covers. A part is added late, a limitation comes out of a fatigue or system safety result, an effectivity splits into two configurations, and the maintenance instructions do not catch up. The ICA reads complete because it covers the baseline everyone remembers, while the parts and limitations added along the way have no home in it. The gap only shows when someone maps the approved configuration against the tasks.
What gets reviewed
- The approved parts and modifications walked one by one against the maintenance tasks in the ICA
- Life limits, inspection intervals, and other limitations checked for a corresponding instruction
- Effectivity across configurations confirmed so each approved configuration is covered
- Airworthiness limitations from analysis and test results traced into the ICA limitations section
- STC-added parts checked for the removal, installation, and maintenance instructions they require
- Every uncovered part, task, or limitation logged with the ICA content needed to close it
What gets validated
- Each part in the approved configuration maps to a maintenance or inspection task in the ICA
- Every life limit and inspection interval from the certification results appears in the ICA limitations
- The ICA covers all approved configurations where effectivity has split, not only the original
- Airworthiness limitations derived from fatigue or system safety analysis are present and correctly stated
- STC-added and modified parts carry the removal, installation, and continued-maintenance instructions they need
Evidence normally required
- The current Instructions for Continued Airworthiness package
- The approved configuration definition with parts, modifications, and effectivity
- The approved data and any STC defining what was added or changed
- Airworthiness limitations and intervals from the analysis and test results
- The certification basis and applicable advisory material for ICA content
Common discrepancies
- A part added by an STC with no maintenance or inspection task written for it in the ICA
- A life limit produced by fatigue analysis that never reached the ICA limitations section
- An effectivity split where the ICA still covers only the original configuration
- An installation and removal procedure missing for a modification the approval includes
What is at stake
An ICA that does not cover the approved configuration leaves an operator with no approved instruction for maintaining part of what was certified, which is exactly what a reviewer is charged with catching. Found at the authority, an ICA coverage gap holds the approval and sends the team back to author tasks and limitations under deadline. Downstream, a missing inspection interval or life limit becomes a continued-airworthiness problem the operator inherits rather than a mere paperwork finding.
Move from findings to resolution
Identify the missing data behind the finding.
How the work runs
List the approved configuration
Assemble every approved part, modification, effectivity, and limitation the ICA is supposed to cover.
Walk it against the ICA
Map each part, task, and limitation to its ICA content and mark everything the ICA does not cover.
Trace the limitations
Confirm life limits, intervals, and airworthiness limitations from the certification results reached the ICA limitations section.
Close the coverage
Deliver a disposition package and coverage matrix mapping every gap into the ICA content needed to close it.
What the buyer receives
- A closure brief listing every place the ICA fails to cover the approved configuration
- An evidence request list naming the limitations, intervals, and procedures still needed
- A reviewer-ready disposition package mapping each part, task, and limitation into the ICA
- A coverage matrix tying the approved configuration to the ICA content that maintains it
Who uses the output
- Certification engineers who must show the ICA covers everything the approval includes
- Continued-airworthiness authors closing the tasks and limitations the configuration needs
- Program managers confirming ICA coverage before the package reaches the authority
How the work fits into the transaction or program
ICA is where a certified design becomes maintainable, so it has to describe the configuration the rest of the package got approved. This pass confirms that coverage before the authority checks the ICA against the approved data. It draws on the same reconciled configuration the rest of the submittal relies on, and its gaps feed the finding register until each task and limitation is closed.
Start with a single asset
Confirm each requirement maps to substantiating evidence.
Jurisdiction-specific considerations
Both the FAA and EASA require ICA as a condition of approval and check that it covers the approved configuration, with airworthiness limitations called out in their own section. FAA guidance in AC 21-40 frames what the ICA package must contain, and EASA works from the equivalent expectation under 748/2012. The pass reads the ICA against whichever basis and advisory material the program is certifying to.
Regulatory limits
This work checks ICA coverage against the approved configuration and identifies gaps. It does not approve the ICA, accept the airworthiness limitations section, make compliance findings, or determine airworthiness. Approval of the ICA and its limitations remains with the authority.
What this review does not cover
- Authoring the maintenance procedures and analysis that missing ICA tasks require
- Approving the ICA or its airworthiness limitations section
- Making compliance findings or granting approval on the authority's behalf
Specific to this review
- An ICA gap is the one pre-submittal defect that outlives the approval, because a missing inspection interval or life limit becomes the operator's continued-airworthiness problem long after certification closes.
- The airworthiness limitations section is where gaps hurt most, since a limit produced by analysis but absent from the ICA means a required inspection has no approved home.
- Effectivity splits are the quiet failure mode: the ICA covers the configuration everyone pictures while a second approved configuration goes uninstructed.
- STC-added parts are the usual culprit, because they arrive after the baseline ICA was written and rarely get their own removal, installation, and maintenance tasks without a deliberate check.
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
Why check ICA coverage before submittal instead of letting the reviewer flag gaps?
Because the reviewer flagging a gap costs a cycle and holds the approval, and some ICA gaps require new analysis to close rather than a quick edit. Confirming coverage first means the missing tasks and limitations are already authored and mapped when the ICA reaches the authority, so the check confirms coverage instead of uncovering a hole with the schedule already spent.
Relevant glossary terms
Related pages
Where this fits
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