PMA article data
Instructions for continued airworthiness support for a PMA article
ICA support checks that the instructions for continued airworthiness delivered with a PMA article actually describe how to maintain the configuration being approved. It runs before formal review, for a supplier who has to hand the operator a set of tasks, limitations, and part data that match the part as approved. The work reads the maintenance tasks, airworthiness limitations, and parts coverage against the configuration and finds where the ICA still describes an earlier design. You receive a gap assessment against the approved configuration, an evidence map from each instruction to its basis, and a closure plan to bring the ICA current before the package moves.
When this review is needed
- The article's design changed during the program and the ICA still reflects the earlier build.
- An airworthiness limitation derived from the safety analysis is not carried into the ICA the operator will use.
- The part numbers and effectivity in the ICA do not match the configuration being approved.
- The package is heading into formal review and the applicant wants the ICA reconciled before a reviewer checks it.
The problem
The ICA is usually the last document written and the first to fall behind. Design changes that ripple cleanly through the analyses often never reach the maintenance tasks, so the ICA describes a maintenance regime for a configuration that no longer exists. Airworthiness limitations that the safety assessment derived get left out or worded loosely, and the part-number and effectivity data drift from the approved build. The operator inherits instructions that do not match the part they installed.
What gets reviewed
- Maintenance tasks reviewed against the approved configuration and its failure modes
- Airworthiness limitations traced from the safety assessment into the ICA content
- Part numbers, effectivity, and applicability reconciled to the configuration being approved
- Inspection and replacement intervals checked for consistency with the substantiation behind them
- Coverage confirmed so every maintenance-significant item on the article has an instruction
- The ICA structure checked against the format the operator's program expects
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Identify what is missing against the means of compliance.
What gets validated
- Each maintenance task describes the configuration being approved rather than a superseded design
- Every airworthiness limitation the safety assessment derived is carried into the ICA and worded to be enforceable
- Part numbers and effectivity in the ICA match the approved configuration
- Inspection and replacement intervals trace to the analysis or test that set them
- No maintenance-significant item on the article is left without an instruction
Evidence normally required
- The draft instructions for continued airworthiness for the article
- The approved configuration and its part-number and effectivity data
- The safety assessment and any airworthiness limitations it derived
- The substantiation behind inspection and replacement intervals
- The maintenance-significant item list for the article
Common discrepancies
- A maintenance task written for a design revision the program later superseded
- An airworthiness limitation derived in the safety case but absent from the ICA
- Part-number or effectivity data in the ICA that does not match the approved build
- An inspection interval stated without the substantiation that set it
What is at stake
An ICA that lags the approved configuration puts the operator in the position of maintaining the part against instructions that do not fit it, which is exactly the kind of gap that surfaces at an audit or a shop visit long after approval. If an airworthiness limitation the safety case relies on is missing from the ICA, the mitigation credited in the analysis is not actually enforced in service, and closing that gap after approval means revising a document already in the field.
How the work runs
Pull the configuration
Establish the approved configuration and its maintenance-significant items as the yardstick.
Check the tasks
Read each maintenance task against that configuration and its failure modes.
Trace the limitations
Confirm every airworthiness limitation from the safety case reaches the ICA and is enforceable.
Reconcile and close
Match part data and intervals to the approved build and list what has to be corrected.
What the buyer receives
Who uses the output
- Certification leads confirming the ICA describes the part as approved
- Engineering owners deciding how a design change flows into the maintenance tasks
- Quality leads verifying the airworthiness limitations are complete and enforceable
How the work fits into the transaction or program
The ICA is the bridge from approval to the operator's continued-airworthiness program, so it has to reflect the same configuration and safety limitations the rest of the package establishes. Reconciling it before formal review keeps the applicant from shipping instructions that a shop later finds do not fit the part, and it closes the loop from the safety assessment, whose derived limitations only take effect once they land in the ICA the operator follows.
Start with a single asset
Reduce finding cycles by checking the package first.
Jurisdiction-specific considerations
The ICA is prepared to the FAA content and format expectations for a PMA article, and its airworthiness limitations have to match those derived in the certification basis. Where the same part is maintained under another authority's continued-airworthiness rules, the review notes where the limitation or interval conventions differ so the operator is not handed two conflicting instruction sets.
Regulatory limits
The review confirms the ICA describes the approved configuration and carries the limitations its basis requires. It does not author the maintenance program, approve the ICA, or make an airworthiness determination about the article or its continued maintenance.
What this review does not cover
- Writing the instructions for continued airworthiness from scratch
- Setting inspection or replacement intervals the applicant has not substantiated
- Any approval of the ICA or the maintenance program built on it
Specific to this review
- The ICA is typically the last document drafted, which is why it lags design changes that reached every other part of the package.
- An airworthiness limitation only becomes real once it is in the ICA, so a limitation left in the safety analysis is a mitigation that is credited but never enforced.
- Correcting an ICA after approval means revising a document already in operators' hands, which is far more disruptive than reconciling it before submittal.
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. FAA type certification process, certification basis establishment, and compliance findings.
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 airworthiness limitations get so much attention here?
A limitation credited in the safety assessment only protects the aircraft once it is written into the ICA the operator follows. If it is left in the analysis and never lands in the ICA, the mitigation exists on paper but is not enforced in service, so the review checks each one lands.
Relevant glossary terms
Related pages
Where this fits
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