TSO finding closure
Closing ICA that does not cover the approved configuration in a TSO program
This helps equipment suppliers whose Instructions for Continued Airworthiness do not fully cover the configuration being approved. A specialist compares the ICA package against the approved configuration and its maintenance-significant items, and finds parts with no task, limitations that never made it in, and affected configurations the instructions do not address. The work is done during the program, before a reviewer or the operator finds a part or limitation the ICA leaves uncovered. You receive a closure brief listing every ICA gap, an evidence request list for the source data needed to write the missing content, and a disposition package that maps parts, tasks, limitations, and affected configurations into the ICA.
When this review is needed
- A reviewer finds a maintenance-significant part in the configuration with no task in the ICA.
- A life limit or maintenance limitation established in the analysis never made it into the ICA package.
- The article was approved for several configurations but the ICA addresses only one.
- The ICA was drafted early and never reconciled with the configuration that was finally approved.
The problem
The ICA is the part of the package that keeps the article airworthy after it ships, and it is usually written early against a configuration that is still moving. Parts get added, limitations get established, and effectivity gets split across configurations while the ICA sits on an earlier version, so it ends up describing maintenance for an article slightly different from the one being approved. A part with no task, a life limit that never crossed into the instructions, a configuration the ICA does not mention: each is a gap that looks minor on paper and becomes an operator's problem in service.
What gets reviewed
- The approved configuration and its maintenance-significant items enumerated as the basis for the ICA
- Each part in the configuration checked for a corresponding task in the ICA
- Life limits and maintenance limitations from the analysis checked for their presence in the ICA
- Affected configurations and effectivity checked so the ICA covers every approved variant
- Airworthiness limitations verified as present in the correct, controlled section of the package
- A reconciled ICA mapping parts, tasks, limitations, and configurations to the approved article
What gets validated
- Every maintenance-significant part in the approved configuration has a corresponding ICA task
- Each life limit and limitation established in the analysis appears in the ICA
- Every configuration the approval covers is addressed by the ICA through effectivity
- Airworthiness limitations reside in the controlled airworthiness-limitations section, not scattered in general text
- Tasks in the ICA reference parts and configurations that exist in the approved article
Evidence normally required
- The draft ICA package and its airworthiness-limitations section
- The approved configuration, part list, and effectivity or drawing tree
- The analyses that establish life limits and maintenance limitations
- The maintenance-significant-item selection and any supporting reliability data
- Any reviewer or operator comments on ICA coverage
Common discrepancies
- A maintenance-significant part in the configuration with no task in the ICA
- A life limit set in the analysis that never crossed into the airworthiness-limitations section
- An approved configuration variant the ICA does not address through effectivity
- An airworthiness limitation buried in general text rather than the controlled section
What is at stake
An ICA that does not cover the approved configuration is a certification gap and an operational one at once. A reviewer will not accept an approval whose continued-airworthiness instructions leave parts or limitations uncovered, so the finding blocks the submittal. If it slips through, the gap lands on the operator, who cannot maintain a part the ICA never addressed or observe a limitation it never stated, and a missing life limit in particular can let a part run past a boundary the analysis set.
Move from findings to resolution
Identify the missing data behind the finding.
How the work runs
Enumerate what needs coverage
List the approved configuration's parts, limitations, and variants that the ICA must address.
Check the ICA against them
Find parts with no task, limitations that never entered the ICA, and variants it does not cover.
Scope the missing content
Identify the source data needed to write each missing task or limitation and name the owner.
Reconcile the package
Deliver an ICA mapped to the approved configuration, with limitations in the controlled section and a disposition package.
What the buyer receives
Who uses the output
- Certification leadership confirming the ICA covers the configuration being approved
- Engineering leads writing the missing tasks and limitations from the source analyses
- Program management clearing the ICA finding before it blocks the submittal
How the work fits into the transaction or program
This reconciles the ICA with the configuration finally approved, sitting between the design approval and the operator handover. It catches the parts, limitations, and variants that moved after the ICA was drafted, so the instructions that leave the program actually maintain the article that was approved.
Start with a single asset
Confirm each requirement maps to substantiating evidence.
Jurisdiction-specific considerations
FAA and EASA both require Instructions for Continued Airworthiness that cover the approved configuration, and both place airworthiness limitations in a controlled section the operator cannot revise without approval. The coverage check is authority-neutral, though the format and the boundary of the airworthiness-limitations section can differ between the two.
Regulatory limits
The work identifies where the ICA fails to cover the approved configuration and maps what is missing. It does not approve the ICA, does not determine airworthiness, and does not set the maintenance program; the acceptance of the ICA stays with the authority and the operator's program remains the operator's responsibility.
What this review does not cover
Specific to this review
- The ICA is drafted early against a moving configuration, so it is structurally prone to lagging the article that is finally approved.
- A missing life limit is the most consequential ICA gap, because it can let a part run past a boundary the analysis set.
- Airworthiness limitations have to live in a controlled section; a real limitation buried in general text is effectively uncontrolled.
- Effectivity is the quiet trap: an ICA that covers one approved variant can silently omit another the same approval carries.
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 do life limits have to be in the ICA rather than just in the analysis?
The analysis establishes a life limit, but the operator maintains the article from the ICA, not from the certification analysis. If a life limit never crosses into the airworthiness-limitations section of the ICA, the operator has no controlled instruction to observe it, and the part can run past the boundary the analysis set. The ICA is where a limit becomes something the operator is required to act on.
Relevant glossary terms
Related pages
Where this fits
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