ICA Efforts
Background:
Instructions for Continued Airworthiness (ICA) are the manuals required to maintain aircraft in airworthy condition.
The Federal Aviation Regulations require the holders of design approvals to prepare ICAs and make them available to persons required to comply with the terms of the instructions, including owners and repair stations that perform maintenance on the products.
Chronology:
August 9, 2012: FAA responds to three-year old ARSA request for legal interpretation.
FAA response
June 11, 2012: ARSA asks Supreme Court to intervene on ICA availability.
Amicus curiae brief
March 29, 2012: FAA releases final ICA policy.
Policy statement
January 4, 2012: ARSA Weighs in on Proposed FAA ICA Policy.
ARSA comments | FAA draft policy
October 6, 2011: FAA releases a draft policy regarding the availability of instructions for continued airworthiness (ICA).
Draft policy
January 26, 2010: ARSA’s submission to EASA for consideration during its rulemaking activity.
Email and documents submitted by ARSA
January 19, 2010: EASA provides a presentation on its ICA Terms of Reference during a public workshop on the subject.
EASA Terms of Reference Presentation | Minutes and presentations
September 28, 2009: EASA adds ICA to its Terms of Reference in anticipation of rulemaking.
EASA ICA Terms of reference
May 18, 2009: ARSA Requests ICA Legal Interpretation.
ARSA interpretation request
November 6, 2008: ARSA sends rebuttal to EASA ICA ruling.
ARSA rebuttal letter
July 3, 2008: ARSA receives second response from EASA clarifying agency’s ICA position.
EASA second response
May 30, 2008: ARSA receives clarification from EASA on ICA requirements.
EASA response | ARSA article
March 5, 2008: ARSA files complaint with EASA regarding failure of Rolls-Royce and Airbus to provide maintenance instructions, with attached copies of the FAA part 13 complaint.
EASA ICA complaint
February 29, 2008: ARSA files a part 13 complaint with the FAA against Parker-Hannifin for failure to provide maintenance instructions on a PMA part.
ARSA PMA complaint
April 18, 2007: ARSA’s comments to Part 145 include a request to remove language that requires repair stations to have ICA to become certificated (see page 8 of ARSA’s comments).
ARSA part 145 comments
February 28, 2006: Rolls-Royce filed a response.
Rolls-Royce response (.pdf)
November 23, 2005: ARSA filed a complaint with the FAA against Rolls-Royce for failure to provide complete engine overhaul instructions to an ARSA member.
Rolls-Royce complaint (.pdf)
July 1, 2005: Unfortunately the FAA did not take ARSA’s deliberations into consideration, and its issuance of Order 8110.54 did not clarify the issue.
FAA Order 8110.54 (.pdf)
August 20, 2004: ARSA formed a joint industry policy committee, composed of a variety of manufacturers, repair stations, and carriers who submitted comments to the FAA on ICA guidance material.
Joint industry policy
December 10, 2003: Airbus responded to ARSA’s complaint although the FAA has not issued a response.
Airbus response (.pdf)
October 3, 2003: ARSA’s first complaint on availability of maintenance manuals (or ICA) was filed with the FAA.
Airbus complaint (.pdf)
April 14, 2003: FAA issues legal interpretation detailing when component maintenance manuals are considered part of ICA’s.
FAA/McCurdy legal interpretation
March 30, 2002: Research reveals how other agencies carry out requirements to “make available” maintenance information.
Other agency actions (.pdf)
January 10, 2001: The Federal Aviation Regulations (FARs) and their predecessor, the Civil Air Regulations have long required that ICA be provided. The attached memo is a complete history of ICA regulations.
History of U.S. ICA regulations, 1941-1980 (.pdf)
December 13, 1999: A legal opinion issued by the FAA (the Whitlow Letter) supports ARSA’s position that complete instructions be made available.
Whitlow letter(.pdf)
