Instructions for Continued Airworthiness
In a position of leadership in any FAA 145 repair station and as an independent A&P mechanic, you should include instructions for continued airworthiness (ICA) as part of your training and assure that you and your technicians have complete knowledge in this area. In the last few months, I have provided remedial training to A&Ps sent to me by the local FISDO as a way of avoiding legal action. I applaud my FISDO and SW-19, and as their DME I have set up a good curriculum on this subject. I was surprised at the beginning, of the level (years) of being certificated versus knowledge in this subject. Time and time again, I have had A&Ps tell me that they did not understand this subject matter and never received any type of training on ICAs from their FAA 145 repair stations when employed and could not tell me what ICA stands for. I like to use the example of having a one-time interior STC installed on an aircraft.
The customer wants his entertainment system troubleshot and repaired, the shower water heater seems inoperative and one of the 32-inch monitors flickers off and on. Unless you have the ICAs for those parts, how can you legally work on the discrepancies and sign them off per FAR 43.9, 43.11 and 91.417? Simple answer — you can’t. Some OEMs give you completion manuals that include all ICAs and on one-time STCs, the operator is normally given a book(s) on ICAs depending on the extent of work noted on the FAA form 337. If it were a simple field approval, the ICAs would be noted on the approved form 337 and should be followed. Remember the three types of 337 field approvals? (That’s another article in itself.)
What are ICAs and how many items are there?
ICAs are always required for a FAA 337, field approval and STCs. For the purpose of this article, I will just cover the 337 and STC. The complete guidance for the ICA can be found in FAA Order 8118.54A and FAA handbook bulletin for airworthiness (HBAW98-18).
There are 16 points that must be answered in the 337, and/or an ICA manual for each installed article.
1) Introduction: This section briefly describes the aircraft, engine, propeller or component that has been altered. You must include any other information on the content, scope, purpose, arrangement, applicability, definitions, abbreviations, precautions and units of measurement, referenced publications and distribution of the ICA as applicable.
2) Description: Describe the major alteration and its functions, including an explanation of its interface with other systems, if any.
3) Control: Include operation information, or special procedures, if any.
4) Servicing information: Such as types of fluids used, servicing points, and location of access panels, as applicable.
5) Maintenance instructions: Such as recommended inspection/maintenance periods in which each of the major alteration components are inspected, cleaned, lubricated, adjusted and tested, including applicable wear tolerances and work recommended at each scheduled maintenance period. This section refers to the manufacturer’s instructions for the equipment installed where appropriate (functional checks, repairs and inspections). It should also include any special notes, cautions or warnings, as applicable.
6) Troubleshooting information: Information describing possible malfunctions, and how to recognize those malfunctions, and the remedial actions to be taken.
7) Removal and replacement information: This section describes the order and method of removing and replacing products, parts and any necessary precautions. This section should also describe or refer to manufacturer’s instructions to make required tests, trim checks, alignment, calibrations, center of gravity changes, lifting or shoring, if any.
8) Diagrams: Of access panels and information, if needed, to gain access for inspections.
9) Special inspection requirements: Such as X-ray, ultrasonic testing, or magnetic particle inspection, if required.
10) Application of protective treatments: To the affective area after inspection and/or maintenance, if any.
11) Data: Relative to structural fasteners such as type, torque, and installation requirements, if any.
12) List of special tools: Special tools that are required, if any.
13) For commuter category aircraft:
a) Electrical loads
b) Methods of balancing flight controls
c) Identification of primary and secondary structures.
d) Special repair methods applicable to the airframe.
14) Overhaul period: Recommended overhaul periods are required to be noted on the ICA when an overhaul period has been set by the manufacturer of a component, or equipment. If there is no overhaul period, the ICA should state for item 14, “no additional overhaul time limitations.”
15) Airworthiness limitation schedule: Include any approved airworthiness limitations identified by the manufacturer or FAA type certificate holding office. (An STC incorporated in a larger field approved major alteration may have an airworthiness limitation.) An FAA inspector should not establish, alter or cancel airworthiness limitations without coordinating with the appropriate FAA certificate holding office. If there are no changes to the airworthiness limitations, the ICA should state for item 15: “no additional airworthiness limitations” or “not applicable.”
16) Revision: This section should include information on how to revise the ICA.
A note on implementation and record keeping: For most alterations, performed IAW the FAA field approval policy, the owner/operator operating under part 91 is responsible for ensuring that the ICA is made part of the applicable section 91.409 inspection program for their aircraft. This is accomplished when a maintenance entry is made in the aircraft’s maintenance record in accordance with section 43.9. This entry records the major alteration and identifies the original ICA location, (Block 8 of FAA form 337) along with a statement that the ICA is now part of the aircraft’s inspection/maintenance requirements.
For major alterations performed in accordance with a field approval on air carrier aircraft, the air carrier operator is responsible for ensuring that the ICA is made part of the applicable inspection/maintenance program for their aircraft.
If a procedure is not currently included in the operator’s manual to incorporate ICA, this process will need to be appropriately addressed. (The operator submits a revision to its maintenance program to the applicable FAA certificate holding district office (CHUDO).) For aircraft inspected under approved aircraft inspection program (AAIP), the operator will submit a change to the CHUDO in accordance with FAA 135. 419b.
For air carrier aircraft inspected using an annual/100-hour inspection program, a reference to the new ICA will be made in the aircraft’s maintenance record IAW section 43.9 This entry records the major alteration and identifies the original ICA location.
If any do not apply, then just put “not applicable,” but they must all be listed.
Getting back to the water heater and after reading the ICA for that particular installation, required special tooling for opening up the control panel face, special instructions and cautions on draining water from unit and circuit breaker sequence when removing power, schematics on the system, an IPC list of parts, time limitations on components, and inspection requirements on a six- and twelve-month inspection schedule. The monitor and the emergency lighting also required the ICAs to correctly remove and repair the discrepancies without causing damage to the units themselves, to the aircraft and the safety of the technician(s). And let’s not forget the legal sign of certifying all work was accomplished using approved data.
When scheduling an aircraft into your facility, ask the operator to assure any ICAs that completion manuals are with aircraft upon arrival. Ask the company DOM if they have an AAIP/GMM if an aircraft is on a 135 certificate, and just because the aircraft is 10 seats or less does not necessarily mean it is on that type of program. We had operated helicopters and Gulfstreams under our certificate, but chose to maintain our certificate 10 or more to keep our fleet uniform.
Train your technicians on ICAs and how they correlate with the FAA 337, FARs 43, 91, and logbook entries.
Phillip Esparza owns and operates Semper Fi Aviation out of Fort Worth, Texas. Esparza served with the USMC as a crew chief on helicopters. He has been active in aviation for 35 years and holds an FAA A&P, IA and private pilot’s license and serves as the Fort Worth-area designated maintenance examiner (DME). He has held positions with Aerospatiale helicopter Corp. (now American Eurocopter) as a field service representative, and with Bombardier Business Aircraft as an international field service representative covering Mexico and Central America. He worked with Dallas Airmotive as an international engine maintenance sales representative for Latin America. He held the position of flight line technician as well as field service working on F-16s in the UAE with Lockheed Martin. Phillip has held positions as general manager for a large 145 repair station in Fort Worth, and director of maintenance for Polaris Aviation Solutions based in Teterboro, N.J. He has worked globally and has extensive knowledge of International logistics, maintenance practices and interior and completion projects. He currently is a consultant for FAA Part 145, 125, and 135 operations, aircraft completions, maintenance, interior and international maintenance operations. Visit his Web site at www.semperfiaviation.com