Instructions for continued airworthiness support for a major change

When this review is needed

• The ICA are drafted but the design moved after they were written and no one has reconciled them.
• The safety assessment credited a maintenance task and it has to appear as an airworthiness limitation in the ICA.
• New or changed parts came out of the change and the ICA parts data has not caught up.
• A reviewer will check that the maintenance instructions cover the configuration the change actually approved.

The problem

ICA are usually written while the design is still moving, so they describe the configuration as it was at draft, not as approved. A maintenance task credited in the safety assessment can be absent from the airworthiness limitations, a part introduced by the change can be missing from the parts data, and an inspection interval can lag a late design decision. The instructions are the last thing to catch up to the airframe, and the gap is easy to miss because the ICA read complete on their own.

What gets reviewed

• Maintenance tasks in the ICA reconciled to the approved configuration and its effectivity
• Airworthiness limitations matched to the tasks the safety assessment credited
• Parts data covering the parts the change introduced or altered
• Inspection intervals and thresholds consistent with the approved design
• ICA structure and referencing consistent with the operator's existing maintenance data
• Continued-airworthiness coverage mapped against the certification basis for the change

What gets validated

• Every maintenance task the safety assessment credited appears in the ICA with the correct interval
• Airworthiness limitations in the ICA trace to the analysis that established them
• Parts data covers each part the change introduced, changed, or made obsolete
• Inspection thresholds in the ICA match the approved configuration rather than a superseded state
• Effectivity in the ICA matches the effectivity of the approved change

Evidence normally required

• The draft Instructions for Continued Airworthiness for the change
• The safety assessment showing credited maintenance tasks and limitations
• The approved configuration and effectivity for the change
• Parts data and illustrated parts information for the affected items
• The certification basis and any applicable maintenance data standard

Common discrepancies

• A maintenance task credited in the safety assessment that never made it into the ICA
• An airworthiness limitation with an interval that lags a late design decision
• A part introduced by the change that is missing from the ICA parts data
• ICA effectivity that does not match the effectivity of the approved change

What is at stake

ICA that do not cover the approved configuration leave the operator without the maintenance the safety case assumed, which is exactly the kind of gap a reviewer stops on. If a limitation the safety assessment relied on is missing, the finding cannot close until the ICA are corrected, and reconciling them under review pressure is slower than confirming coverage while the design data is fresh in hand.

How the work runs

What the buyer receives

• A gap assessment listing each ICA element that lags the approved configuration
• An evidence map linking each maintenance task and limitation to the approved design
• A closure plan for the instructions that must be corrected before the finding closes

Who uses the output

• Certification engineers confirming the ICA cover what the change approved
• Maintenance engineering leads reconciling tasks and limitations against the safety case
• Compliance managers tracking which ICA gaps still block the finding

How the work fits into the transaction or program

The review sits at the point where the design settles and the maintenance data has to catch up, confirming the ICA describe the approved configuration before the finding closes. It draws on the safety assessment for the tasks that must appear and feeds the finding register with any instruction still lagging the design.

Jurisdiction-specific considerations

The FAA and EASA both require ICA for a major change, but the format expectations, the way airworthiness limitations are segregated, and the acceptance route can differ between them. The review notes where the same instructions need to be structured or referenced differently to satisfy each authority's finding.

Regulatory limits

The review confirms the ICA cover the approved configuration and the tasks the safety case relied on. It does not author the ICA on the program's behalf, approve the airworthiness limitations, or make any airworthiness determination.

What this review does not cover

• Writing the Instructions for Continued Airworthiness from scratch
• Approving airworthiness limitations on the authority's behalf
• Any airworthiness determination on the modified aircraft

Specific to this review

• ICA are usually the last document to catch up to a change, so they most often describe the configuration as drafted rather than as approved.
• A maintenance task the safety assessment credited but the ICA omit is a hard stop for the finding, because the safety case assumes an instruction the operator would never receive.
• Airworthiness limitations are the one part of the ICA the operator cannot deviate from, so an interval that lags a late design change carries more consequence than a general task that does.

Sources

Frequently asked questions

Relevant glossary terms

Related pages

Where this fits