European Aviation Safety Agency
Notice of Proposed Amendment 2018-01
Instructions for continued airworthiness
RMT.0252 (MDM.056)
EXECUTIVE SUMMARY
The objective of this Notice of Proposed Amendment (NPA) is to mitigate the risks linked to the uncertainty of the status
of instructions for continued airworthiness (ICA) and therefore to avoid there being too much room for interpretation in
the rules and standards, leading to differences and possible safety risks .
This NPA proposes to amend Annex I (Part 21) of Regulation (EU) No 748/2012 to clarify that ICA are part of the type
certificate (TC), and to develop the related acceptable means of compliance (AMC) and guidance material (GM). It also
merges the requirements related to record keeping, manuals and ICA in the various subparts into a single requirement
for each of these aspects in Subpart A (new points 21.A.5, 6 and 7).
The proposed changes are expected to improve the harmonisation of ICA among the design approval holders (DAHs) in
relation to the identification, approval, formatting and availability of ICA to the end users.
Action area: Manufacturers
Affected rules: Part 21 and related AMC/GM
Affected stakeholders: DAHs and manufacturers
Driver: Level playing field Rulemaking group: Yes
Impact assessment: Light Rulemaking Procedure: Standard
15.5.2013 29.1.2018 2018/Q3 2019/Q3 2019/Q3
(first issue of ToR)
20.6.2016
(ToR Issue 5)
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Table of contents
Table of contents
1. About this NPA ..................................................................................................................................... 3
1.1. How this NPA was developed ...................................................................................................................3
1.2. How to comment on this NPA...................................................................................................................3
1.3. The next steps ...........................................................................................................................................3
2. In summary — why and what ............................................................................................................... 4
2.1. Why we need to change the rules — issue/rationale...............................................................................4
2.2. What we want to achieve — objectives ...................................................................................................4
2.3. How we want to achieve it — overview of the proposals ........................................................................5
2.4. What are the expected benefits and drawbacks of the proposals? .........................................................5
3. Proposed amendments and rationale in detail ...................................................................................... 6
3.1. Draft regulation (Draft EASA opinion).......................................................................................................6
3.2. Draft acceptable means of compliance and guidance material (Draft EASA decision) ..........................12
4. Impact assessment (IA) ....................................................................................................................... 30
4.1. What is the issue .....................................................................................................................................30
4.2. What we want to achieve .......................................................................................................................31
4.3. How it could be achieved — options ......................................................................................................32
4.4. What are the impacts..............................................................................................................................32
4.5. Conclusion ...............................................................................................................................................33
4.6. Monitoring and evaluation .....................................................................................................................34
5. Proposed actions to support implementation...................................................................................... 35
6. References ......................................................................................................................................... 36
6.1. Affected regulations................................................................................................................................36
6.2. Affected decisions ...................................................................................................................................36
6.3. Other reference documents ...................................................................................................................36
7. Appendix ........................................................................................................................................... 37
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1.About this NPA
1. About this NPA
1.1. How this NPA was developed
The European Aviation Safety Agency (EASA) developed this NPA in line with Regulation (EC)
No 216/20081 (hereinafter referred to as the ‘Basic Regulation’) and the Rulemaking Procedure2. This
rulemaking activity is included in the EASA 5-year Rulemaking Programme3 under rulemaking task
(RMT).0252 (MDM.056). The text of this NPA has been developed by EASA based on the input of the
Rulemaking Group (RMG) RMT.052 (MDM.056). It is hereby submitted to all interested parties4 for
consultation.
1.2. How to comment on this NPA
Please submit your comments using the automated Comment-Response Tool (CRT) available at
http://hub.easa.europa.eu/crt/5.
The deadline for submission of comments is 30 April 2018.
1.3. The next steps
Following the closing of the public commenting period, EASA will review all comments and perform a
focused consultation which will consist of one or more meetings of the RMG.
Based on the comments received, EASA will develop an opinion containing the proposed amendments
to Regulation (EU) No 748/20126. The opinion will be submitted to the European Commission, which
will use it as a technical basis in order to prepare an EU regulation.
Following the adoption of the regulation, EASA will issue a decision containing the related AMC/GM.
The comments received and the EASA responses will be reflected in a comment-response document
(CRD). The CRD will be annexed to the opinion.
1
Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of
civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC,
Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1) (http://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1467719701894&uri=CELEX:32008R0216).
2
EASA is bound to follow a structured rulemaking process as required by Article 52(1) of Regulation (EC) No 216/2008. Such a
process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision
No 18-2015 of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied by EASA for the issuing of
opinions, certification specifications and guidance material (http://www.easa.europa.eu/the-agency/management-
board/decisions/easa-mb-decision-18-2015-rulemaking-procedure).
3
http://easa.europa.eu/rulemaking/annual-programme-and-planning.php
4
In accordance with Article 52 of Regulation (EC) No 216/2008 and Articles 6(3) and 7) of the Rulemaking Procedure.
5
In case of technical problems, please contact the CRT webmaster (
[email protected]).
6
Commission Regulation (EU) No 748/2012 of 3 August 2012 laying down implementing rules for the airworthiness and
environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and
production organisations (OJ L 224, 21.8.2012, p.1-85) http://eur-lex.europa.eu/legal-content/EN/TXT/
?qid=1473415871666&uri=CELEX:32012R0748
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2. In summary — why and what
2. In summary — why and what
2.1. Why we need to change the rules — issue/rationale
Instructions for continued airworthiness (ICA) have to be produced by design approval holders (DAHs)
as part of the product/part certification which, if properly implemented, should ensure that the
product/part remains airworthy during its intended life.
Experience has shown that there is too much room for interpretation in the current rules and
standards, leading to differences and possible safety risks. It appears that different type certificate (TC)
holders have different interpretations of what is a complete set of ICA and to what level they are
required to control the data that constitutes the ICA. The consequence is that maintenance
organisations may not have all the necessary data to perform the maintenance in the correct way,
which can lead to them using unapproved methods.
The aim of this proposal is to clarify the status of ICA in order to improve the continuing airworthiness
of all aircraft within the scope of the Basic Regulation, and therefore to improve safety.
Related safety issues
The following safety recommendations (SRs) addressed to EASA from aircraft accident investigation
report(s) published by the designated safety investigation authority7, were considered during this RMT:
— SR ICLD-2013-001: Boeing 757-200 TF-FIJ, Icelandair, 85 NM south-south-east of London Gatwick
Airport on June 4, 2009. (Smoke in the flight deck and the cabin was followed by an engine shut
down and an emergency landing because a maintenance action from a component maintenance
manual (CMM) had not been performed)
— SR UNKG-2007-004: Piper PA-28R-201T G-JMTT, near 9 NM south of Oban Airport, Argyll
(Scotland) on April 9, 2007. (The aircraft crashed after a loss of control in instrument
meteorological conditions with a defective vacuum pump because its required maintenance
actions had not been performed).
This NPA addresses both of these SRs by proposing revised GM, which states that DAHs should
systematically review the initial maintenance recommendations provided by suppliers and consider
them whether they are applicable and effective. This review also includes European Technical
Standard Order (ETSO) articles where the DAH or design approval applicant (DAA) may have to
incorporate certain maintenance instructions into the product’s ICA in order to ensure that the ETSO
article continues to satisfy the terms of its ETSO authorisation after installation.
2.2. What we want to achieve — objectives
The overall objectives of the EASA system are defined in Article 2 of the Basic Regulation. This proposal
will contribute to the achievement of the overall objectives by addressing the issues outlined in
Section 2.1.
The specific objective of this RMT is to establish clear requirements and responsibilities for all parties
involved in the production of ICA, their approval and their implementation.
7
Regulation (EU) No 996/2010 of the European Parliament and of the Council of 20 October 2010 on the investigation and prevention
of accidents and incidents in civil aviation and repealing Directive 94/56/EC (OJ L295, 12.11.2010, p.35) http://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:32010R0996
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2. In summary — why and what
The aspects to review are, among others:
— the definition and identification of ICA (to be provided during the certification process), including
the determination of the relationship between ICA and the maintenance information for ETSO
articles;
— the completeness of ICA (during the certification process) provided by the DAH upon delivery of
the product or issuance of the first airworthiness certificate;
— the certification of ICA by the competent authority (during the certification process);
— the availability of ICA for any person required to comply with them;
— the acceptance/approval of ICA by organisations other than the certification authority; and
— updates of ICA throughout the life of the products.
2.3. How we want to achieve it — overview of the proposals
The main change to Part 21 introduced by this proposal is to clearly place ICA as part of the TC (point
21.A.41).
The related GM for the scope, availability, publication format, supplier’s data, integration between
products, of ICA will improve the implementation by the end users.
Furthermore, the current Part 21 duplicates the requirements for manuals, instructions for continued
airworthiness and record-keeping for each category of certificates or approvals: it is therefore
proposed to create a single requirement for each of these aspects (new points 21.A.5, 6 and 7).
Question for stakeholders
Do you consider that grouping all requirements related to record keeping, manuals and ICAs for
holders of design approvals and ETSO authorisations in Subpart A will improve the consistency of
Part -21 and the way it is being applied?
Is it sufficiently clear that these provisions do not apply to record keeping for production
organisations, permit to fly holders, competent authorities (except for design approvals transferred
to EASA)?
2.4. What are the expected benefits and drawbacks of the proposals?
The expected benefits and drawbacks of the proposal are the following. By clarifying the status of ICA
as part of the TC, their identification and their control by the design organisation and/or EASA will be
improved. The new GM, for their format and their link with supplier’s documentation, will increase the
consistency of ICA between manufacturers. Therefore, the implementation of ICA by the end-users will
be improved .
The main drawbacks of this proposal are the need for manufacturers to update the development
processes of some ICA; in addition, this proposal will potentially create dis-harmonisation with the US.
For the full impact assessment of the alternative options, please refer to Chapter 4.
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3. Proposed amendments and rationale in detail
3. Proposed amendments and rationale in detail
The text of the amendment is arranged to show deleted text, new or amended text as shown below:
— deleted text is struck through;
— new or amended text is highlighted in grey;
— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.
3.1. Draft regulation (Draft EASA opinion)
Changes to Annex I (Part 21) to Commission Regulation (EU) No 748/2012
1. The following points 21.A.5 to 21.A.7 are inserted
21.A.5 Record keeping for holders of design approvals and ETSO authorisations
All relevant design information and supporting documentation, drawings and test reports, including
inspection records for the specimen and prototype or article tested, shall be held by the holder of a
type certificate, restricted type certificate, supplemental type certificate, design change or repair
design approval or an ETSO authorisation at the disposal of the Agency and shall be retained in order
to provide the information necessary to ensure the continued airworthiness, continued validity of the
operational suitability data and continued compliance with the applicable environmental protection
requirements of the product or the article.
21.A.6 Manuals
The holder of a type certificate, restricted type certificate, supplemental type certificate, design change
or repair design approval or an ETSO authorisation shall produce, maintain and update master copies
of all manuals or variations in the manuals required by the applicable type certification basis, the
applicable operational suitability data certification basis and the environmental protection
requirements for the product or article, and provide copies, on request, to the Agency.
21.A.7 Instructions for continued airworthiness
(a) Instructions for continued airworthiness are the instructions and information that are necessary for
the continued airworthiness of the aircraft, engine, propeller, parts and appliances, which must be
developed or referenced by the design approval holder in accordance with the applicable
certification basis.
(b) The holder of a type certificate, restricted type certificate, supplemental type certificate, design
change or repair design approval shall furnish at least one set of complete instructions for
continued airworthiness to each known owner of one or more products upon its delivery or upon
the issuance of the first certificate of airworthiness for the affected aircraft, whichever occurs later,
and thereafter make those instructions available on request to any other person required to
comply with any of the terms of those instructions.
(c) The type certificate or restricted type certificate holder may delay the availability of a portion of the
instructions for continued airworthiness, dealing with overhaul or other forms of heavy
maintenance, until after the product or modified product has entered into service, but shall make
those instructions available before the product or modified product requires such overhaul or
heavy maintenance.
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(d) Changes to the instructions for continued airworthiness as established in accordance with (b) shall
be made available to all known operators of the product affected by the change and shall be made
available on request to any person required to comply with any of the terms of those changes to
the instructions. The holder of a type certificate, restricted type certificate, supplemental type
certificate, design change or repair design approval shall submit to the Agency a document
describing the process for how changes to the instructions for continued airworthiness are made
available in order to comply with the first sentence.
2. Point 21.A.41 is amended as follows
21.A.41 Type-certificate
The type-certificate and restricted type-certificate shall include the type design, the operating
limitations, the instructions for continued airworthiness, the type-certificate data sheet for
airworthiness and emissions, the applicable type-certification basis, and environmental protection
requirements with which the Agency records compliance, and any other conditions or limitations
prescribed for the product in the applicable certification specifications and environmental protection
requirements. The aircraft type certificate and restricted type-certificate, in addition, shall both include
the applicable operational suitability data certification basis, the operational suitability data and the
type-certificate data sheet for noise. The engine type-certificate data sheet shall include the record of
emission compliance.
3. Point 21.A.44 is amended as follows
21.A.44 Obligations of the holder
Each holder of a type-certificate or restricted type-certificate shall:
(a) undertake the obligations laid down in points 21.A.3A, 21.A.3B, 21.A.4, 21.A.55, 21.A.657, 21.A.761
and 21.A.62; and, for this purpose, shall continue to meet the qualification requirements for
eligibility under point 21.A.14; and
[…]
4. Points 21.A.55, 21.A.57 and 21.A.61 are deleted
21.A.55 Record-keeping
All relevant design information, drawings and test reports, including inspection records for the
producttested, shall be held by the type-certificate or restricted type-certificate holder at the disposal
of the Agency and shall be retained in order to provide the information necessary to ensure the
continued airworthiness, continued validity of the operational suitability data and compliance with
applicableenvironmental protection requirements of the product.
21.A.57 Manuals
The holder of a type-certificate or restricted type-certificate shall produce, maintain and update
master copies of all manuals required by the applicable type-certification basis, the
applicableoperational suitability data certification basis and environmental protection requirements
for the product, and provide copies, on request, to the Agency.
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21.A.61 Instructions for continued airworthiness
(a) The holder of the type-certificate or restricted type-certificate shall furnish at least one set of
complete instructions for continued airworthiness, comprising descriptive data and
accomplishment instructions prepared in accordance with the applicable type-certification basis, to
each known owner of one or more aircraft, engine or propeller upon its delivery or upon issue of
the first certificate of airworthiness for the affected aircraft, whichever occurs later and thereafter
make those instructions available on request to any other person required to comply with any of
the terms of those instructions. The availability of some manual or portion of the instructions for
continued airworthiness, dealing with overhaul or other forms of heavy maintenance, may be
delayed until after the product has entered into service, but shall be available before any of the
products reaches the relevant age or flight-hours/cycles. (b) In addition, changes to the instructions
for continued airworthiness shall be made available to all known operators of the product and shall
be made available on request to any person required to comply with any of those instructions. A
programme showing how changes to the instructions for continued airworthiness are distributed
shall be submitted to the Agency.
5. The following point 21.A.90C is inserted
21.A.90C Stand-alone changes to ICA
(a) Stand-alone changes to instructions for continued airworthiness are changes that are not directly
prepared together with a change to the type design.
(b) Stand-alone changes to instructions for continued airworthiness can only be made by the holder of
the design approval for which those instructions have been established.
(c) For stand-alone changes to instructions for continued airworthiness that:
— do not affect the airworthiness limitations section of the instructions for continued
airworthiness, or
— do not require additional work to demonstrate compliance with the certification basis,
points 21.A.91 to 21.A.109 are not applicable. The stand-alone changes to instructions for
continued airworthiness will be approved by the holder of the design approval under a procedure
agreed with the Agency.
6. Points 21.A.105 and 21.A.107 are deleted
21.A.105 Record-keeping
For each change, all relevant design information, drawings and test reports, including inspection
records for the changed product tested, shall be held by the applicant at the disposal of the Agency
and shall be retained in order to provide the information necessary to ensure the continued
airworthiness, continued validity of the operational suitability data and compliance with applicable
environmental protection requirements of the changed product. [Regulation (EU) No 69/2014,
27.01.2014]
21.A.107 Instructions for continued airworthiness
(a) The holder of a minor change approval to type-certificate shall furnish at least one set of the
associated variations, if any, to the instructions for continued airworthiness of the product on which
the minor change is to be installed, prepared in accordance with the applicable typecertification basis,
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to each known owner of one or more aircraft, engine, or propeller incorporating the minor change,
upon its delivery, or upon issuance of the first certificate of airworthiness for the affected aircraft,
whichever occurs later, and thereafter make those variations in instructions available, on request, to
any other person required to comply with any of the terms of those instructions.
(b) In addition, changes to those variations of the instructions for continued airworthiness shall be
made available to all known operators of a product incorporating the minor change and shall be made
available, on request, to any person required to comply with any of those instructions.
7. Point 21.A.109 is amended as follows
21.A.109 Obligations and EPA marking
The holder of a minor change approval to a type certificate shall:
(a) undertake the obligations laid down in points 21.A.4, 21.A.105, 21.A.107 and 21.A.108; and
[…]
8. Point 21.A.118A is amended as follows
21.A.118A Obligations and EPA marking
Each holder of a supplemental type-certificate shall:
(a) undertake the obligations:
1. laid down in points 21.A.3A, 21.A.3B, 21.A.4, 21.A.105, 21.A.7, 21.A.119, 21.A.120A and
21.A.120B;
[…]
9. Points 21.A.119 and 21.A.120A are deleted
21.A.119 Manuals
The holder of a supplemental type-certificate shall produce, maintain, and update master copies of
variations in the manuals required by the applicable type-certification basis, the applicable operational
suitability data certification basis and environmental protection requirements for the product,
necessary to cover the changes introduced under the supplemental type-certificate, and furnish copies
of these manuals to the Agency on request. [Regulation (EU) No 69/2014, 27.01.2014]
21.A.120A Instructions for continued airworthiness
(a) The holder of the supplemental type-certificate for an aircraft, engine, or propeller, shall furnish at
least one set of the associated variations to the instructions for continued airworthiness, prepared
in accordance with the applicable type-certification basis, to each known owner of one or more
aircraft, engine, or propeller incorporating the features of the supplemental typecertificate, upon
its delivery, or upon issuance of the first certificate of airworthiness for the affected aircraft,
whichever occurs later, and thereafter make those variations in instructions available, on request,
to any other person required to comply with any of the terms of those instructions. Availability of
some manual or portion of the variations to the instructions for continued airworthiness, dealing
with overhaul or other forms of heavy maintenance, may be delayed until after the product has
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3. Proposed amendments and rationale in detail
entered into service, but shall be available before any of the products reaches the relevant age or
flight-hours/cycles.
(b) In addition, changes to those variations of the instructions for continued airworthiness shall be
made available to all known operators of a product incorporating the supplemental typecertificate
and shall be made available, on request, to any person required to comply with any of those
instructions. A programme showing how changes to the variations to the instructions for continued
airworthiness are distributed shall be submitted to the Agency.
10. Point 21.A.265 is amended as follows
21.A.265 Obligations of the holder 8
The holder of a design organisation approval shall:
[…]
(h) designate data and information issued under the authority of the approved design organisation
within the scope of its terms of approval as established by EASA with the following statement: ‘The
technical content of this document is approved. It is issued under the authority of the DOA ref.
EASA. 21J.[XXXX]. If the issued data and information is part of the instructions for continued
airworthiness for a product, the holder of the design organisation approval shall add the following
statement: ‘This document is part of the ICA for product [yyyy]’.
11. Points 21.A.447 and 21.A.449 are deleted
21.A.447 Record-keeping
For each repair, all relevant design information, drawings, test reports, instructions and limitations
possibly issued in accordance with point 21.A.443, justification for classification and evidence of the
design approval, shall:
(a) be held by the repair design approval holder at the disposal of the Agency; and
(b) be retained by the repair design approval holder in order to provide the information necessary to
ensure the continued airworthiness of the repaired products, parts or appliances.
21.A.449 Instructions for continued airworthiness
(a) The holder of the repair design approval shall furnish at least one complete set of those changes to
the instructions for continued airworthiness which result from the design of the repair, comprising
descriptive data and accomplishment instructions prepared in accordance with the applicable
requirements, to each operator of aircraft incorporating the repair. The repaired product, part or
appliance may be released into service before the changes to those instructions have been
completed, but this shall be for a limited service period, and in agreement with the Agency. Those
changes to the instructions shall be made available on request to any other person required to
comply with any of the terms of those changes to the instructions. The availability of some manual
or portion of the changes to the instructions for continued airworthiness, dealing with overhaul or
8
This amendment is based on the proposed text of this GM as in EASA’s NPA 2017-20 ‘Embodiment of level of involvement acceptable
means of compliance and guidance material to Part-21’ (https://www.easa.europa.eu/document-library/notices-of-proposed-
amendment/npa-2017-20)
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3. Proposed amendments and rationale in detail
other forms of heavy maintenance, may be delayed until after the product has entered into service,
but shall be available before any of the products reaches the relevant age or flight - hours/cycles.
(b) If updates to those changes to the instructions for continued airworthiness are issued by the holder
of the repair design approval after the repair has been first approved, these updates shall be
furnished to each operator and shall be made available on request to any other person required to
comply with any of the terms of those changes to the instructions. A programme showing how
updates to the changes to the instructions for continued airworthiness are distributed shall be
submitted to the Agency.
12. Point 21.A.451 is amended as follows
21.A.451 Obligations and EPA marking
(a) Each holder of a major repair design approval shall:
1. undertake the obligations:
(i) laid down in points 21.A.3A, 21.A.3B, 21.A.4, 21.A.5, 21.A.7, 21.A.439, 21.A.441, and
21.A.443, 21.A.447 and 21.A.449;
(ii) implicit in the collaboration with the type-certificate, supplemental type-certificate and
with the APU ETSO authorisation holder under point 21.A.433 (b), as appropriate.
2. specify the marking, including EPA letters, in accordance with point 21.A.804(a).
(b) Except for type-certificate holders or APU authorisation holders for which point 21.A.44 applies,
the holder of a minor repair design approval shall:
1. undertake the obligations laid down in points 21.A.4, 21.A.5447 and 21.A.7449; and
2. specify the marking, including EPA letters, in accordance with point 21.A.804(a).
13. Point 21.A.609 is amended as follows
21.A.609 Obligations of holders of ETSO authorisations
The holder of an ETSO authorisation under this Subpart shall:
(a) manufacture each article in accordance with Subpart G or Subpart F that ensures that each
completed article conforms to its design data and is safe for installation;
(b) prepare and maintain, for each model of each article for which an ETSO authorisation has been
issued, a current file of complete technical data and records in accordance with point 21.A.5613;
[…]
14. Point 21.A.613 is deleted
21.A.613 Record-keeping
Further to the record-keeping requirements appropriate to or associated with the quality system, all
relevant design information, drawings and test reports, including inspection records for the article
tested, shall be held at the disposal of the Agency and shall be retained in order to provide the
information necessary to ensure the continued airworthiness of the article and of the type-certificated
product in which it is fitted.
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3. Proposed amendments and rationale in detail
3.2. Draft acceptable means of compliance and guidance material (Draft EASA decision)
Changes to AMC/GM to Annex I (Part 21) to Commission Regulation (EU) No 748/2012
1. New GM 21.A.5 is added
GM 21.A.5 Record keeping in cases of repair designs
For repair designs, the record keeping requirement of point 21.A.5 applies to the data described in
AMC 21.A.433(a).
2. New AMC No 1 to 21.A.7(a) is added:
AMC No. 1 to 21.A.7(a) Contents of ICA
(1) The instructions for continued airworthiness should identify:
1.1 any limitations necessary for the continued airworthiness of the product or article;
1.2 the means to determine when the product or article has deteriorated to the extent that it is
no longer airworthy;
1.3 any actions required to restore the product or article to an airworthy state before points 1.1
or 1.2 have been exceeded, as an alternative to the withdrawal of the product or article from
service.
(2) The instructions for continued airworthiness should therefore include:
2.1 any limitations determined through the certification of the product, and instructions on how
to determine that these limits have been exceeded.
2.2 any inspection, servicing or maintenance actions determined to be necessary by the
certification process.
2.3 any inspection or troubleshooting actions determined to be necessary to establish the
nature of faults and the necessary remedial actions.
2.4) sufficient general information on the operation of the product to enable an understanding
of the instructions in 1.1 to 1.3 of paragraph (1) above.
3. New AMC No 2 to 21.A.7(a) is added
AMC No. 2 to 21.A.7(a) Identification of ICA
The instructions for continued airworthiness may be provided in the documents containing other,
additional or optional, maintenance information, as described in point 21.A.6, or in another acceptable
format as per GM 21.A.7, with the following provisions:
1) the information necessary for continued airworthiness is clearly identified (refer to
AMC 21.A.7 (b)).
2) instructions for continued airworthiness may reference additional Instructions for
continued airworthiness in separate publications where necessary (for example, those
produced by suppliers).
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If the product ICA references the use of a supplier’s data (e.g. CMM or section) as the
appropriate location for the ICA, those applicable instructions are incorporated by
reference and become part of the complete set of the ICA for the product.
3) Additional or optional maintenance information not considered as ICA but published
together with the ICA should be evaluated appropriately by the DAH, in order to ensure
that its use will not compromise the continued airworthiness of the product or article.
4) If the maintenance data made available by a DAH includes data from an operator (i.e. in
order to customise the data for the operator, and created under the authority of the
operator), the operator’s data should be identified as such, and the DAH is not required to
additionally evaluate it.
4. New GM No 1, 2, 3 and 4 to 21.A.7(a) are added
GM No 1 to 21.A.7(a) Scope of ICA, their publication format and typical ICA data
1) ICA can be published in documents or in a manner that is outside the traditional understanding of a
document, for example, as a series of web pages, or in a publishing format linked to tasks or data
modules rather than pages.
2) The data containing the instructions itself is the ICA, not any particular type of publication. The DAH
can decide – within the framework provided by point 21.A.7 and its acceptable means of
compliance and guidance material – to publish the ICA in the most suitable location within all the
information published to support the airworthiness of the aircraft. Publications typically created by
DAHs (e.g. for the demonstration of compliance with a certification basis established on the basis of
CS-25), and which may therefore include ICA, consist of:
— Aircraft Maintenance Manuals (AMMs);
— Scheduled Maintenance Requirements (e.g. MRBRs);
— Off-Wing Component Maintenance or Overhaul Manuals;
— Parts Catalogues;
— Tooling Manuals;
— Wiring Diagram Manuals;
— Weight and Balance Manuals;
— Service Bulletins;
— Electrical Loads Analyses;
— Extended Range Operations (ETOPS) Configuration Maintenance Programs/Plans;
— Supplemental Structural Inspection Documentation;
— Certification Maintenance Requirements;
— Airworthiness Limitations Items;
— Aging Aircraft Maintenance Requirements;
— Fuel tank safety related limitations (e.g. CDCCL);
— Electrical Wiring Interconnection System instructions;
— Corrosion Prevention and Control Programmes.
Note: This is only an example of the publications that may contain ICA according to CS-25; this list is
not supposed to be exhaustive, nor is it a minimum list of ICA.
3) The requirement for Instructions for Continued Airworthiness is not intended to ensure that all
products or articles may be restored to an airworthy condition. A certain level of deterioration may
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require a product or an article to be removed from service, and restoration may not be reasonably
achievable.
Certain deteriorations or levels of deterioration may require specific instructions (e.g. inspection or
restoration) that will only be developed and provided on a case-by-case basis, as needed, for a
given product, and as such, will initially not be included in the ICA.
In some exceptional cases, ICA for the product may ultimately instruct the user to contact the DAH
in order to define the specific instructions on a case-by-case basis. This typically happens when the
definition of generic instructions covering all possible cases is not practical. For example, following
an aircraft hard landing, a detailed analysis may have to be carried out by the DAH to determine the
specific instructions to be followed, which depends on the touchdown loads, recalculated
postflight, based on recorded flight data.
GM No 2 to 21.A.7(a) Determination of which supplier’s data are part of ICA
Note 1: In this GM, the term ‘supplier’s data’ also applies to similar types of data when issued directly
by the DAH (e.g. component maintenance manuals issued by the DAH).
Note 2: In this GM the term ‘supplier’s data’ has to be understood as supplier‘s data (e.g. a full CMM)
or part of a supplier’s data (e.g. part of a CMM).
Note 3: The link between the aircraft ICA and the engine /propeller CMM as detailed below is similar to
the link between engine/propeller ICA and the CMM of equipment fitted to the
engine/propeller.
1) When determining whether a supplier’s data is part of the ICA, the following should be considered:
— supplier’s data related to the Airworthiness Limitations Section (ALS) of the ICA are part of the
ICA. A typical CS-25 example is Critical Design Configuration Control Limitation (CDCCL) items
that are included in CMMs.
— supplier’s data related to instructions on how to accomplish the scheduled maintenance part of
the aircraft ICA (such as MRBR) are part of the aircraft ICA. A typical case is the periodical
removal of a component to perform a functional check in a workshop. Example: fire extinguisher
removal for hydrostatic test: this test is performed in a workshop in accordance with the
supplier’s data instructions.
— supplier’s data related to scheduled maintenance on the component should be endorsed by the
DAH before becoming part of the aircraft ICA.
— if the ICA is defined at aircraft level, the following principles apply to the other supplier’s data
that is not related to ALS and not related to scheduled maintenance:
a. if the supplier’s data includes a maintenance instruction for an action identified in
the aircraft-level ICA, including an engine or propeller, this supplier’s data should be
referenced in the aircraft level ICA and should be made available like any other ICA.
As an alternative to linking such supplier’s data to the aircraft level ICA (e.g. with
cross references), it is possible to include the relevant data directly into the aircraft
ICA. In such a case, the supplier’s data is not part of the aircraft ICA since the
aircraft ICA contains all the required information. Another alternative is to develop
the relevant data so it is included directly into the aircraft ICA.
b. if an aircraft level maintenance action is a replacement action for the engine,
propeller, part or appliance (‘remove and replace’ or ‘discard’) and does not refer to
the supplier’s data for necessary airworthiness actions, the aircraft’s airworthiness
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can be maintained by replacement action, and the supplier’s data are not part of
the ICA for the aircraft. In such cases, the supplier’s data does not need to be
referenced in the aircraft ICA. Example: if supplier’s data is required to perform off-
aircraft maintenance on an engine, propeller, or other article (i.e. workshop
maintenance), then this data is not considered as part of the complete set of ICA for
the aircraft. However the removal/installation part of the procedure is part of the
aircraft ICA.
2) However, for the above cases, the aircraft level ICA can provide, as additional or optional
maintenance information, the references of the supplier’s data even if it is not considered as part of
the ICA. In such cases, it should be made clear that the supplier’s data is provided as additional or
optional maintenance information and is not part of the aircraft ICA.
3) For the supplier’s data identified as part of the ICA, the DAH should:
a. identify the supplier’s data that is part of the ICA; this can be achieved either by creating a
listing or by any other acceptable means that allows which data is part of the ICA and
which is not to be identified (refer to AMC 21.A.7(b));
b. ensure the publication of the supplier’s data just as for any other ICA;
c. ensure the accuracy and the adequacy of the technical content of the supplier’s data.
(Refer to GM No.1 to 21.A.239 (a) 3.1.5).
AMC No. 3 to 21.A.7(a) DAH responsibility to check the Supplier’s data.
The DAH may carry out a complete check of the data, or may choose to rely, in whole or in part, on the
supplier’s process. In this second case, the DAH will propose a means to validate the supplier’s process.
Supplier’s data may also be issued by the supplier under contract or arrangement to the DAH that
addresses the following:
— the accuracy and the adequacy of the technical documentation, which should be checked
through verification processes (e.g. component workshop verification);
— evidence showing that workshop verification was performed should be kept by supplier and a
clear statement should be given in the introduction to the supplier’s data as a confirmation that
component verification is complete;
— evidence that the supplier has taken into account all justified feedback and changes to data
requested by any person required to use the ICA; typical examples would be the correction of
reported errors, or mistakes.
In addition, some validation activities may be decided by the DAH, depending on the articles and the
capability level of the supplier.
When a DAH takes credit for an ETSO authorisation for the certification of its product, then the
validation of the suppliers’ process is not needed.
GM No 3 to 21.A.7(a) Non-ICA supplier’s data (e.g. Component Maintenance Manuals) referenced
or published as additional information in the same repository as the ICA
Supplier’s data, or parts of the supplier’s data, which are not considered to be part of the ICA but are
referenced as additional or optional maintenance information in the product level ICA, may be issued
by the supplier under contract or arrangement to the DAH using the methodology proposed in GM
No.1 to 21.A.239 (a) 3.1.5.
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5. New AMC 21.A.7(b) is added
AMC 21.A.7(b) Identification of the complete set of instructions for continued airworthiness
The approval holder needs to identify the complete set of ICA according to point 21.A.7(b) in such a
way that the complete set can be:
— directly listed in the product TCDS; or
— indirectly referenced in the TCDS through other means, which allow the complete list of ICA to
be obtained (e.g. a complete listing of ICA contained in a ‘principal manual’ or a reference to a
DAH’s website); or
— directly listed in the product STC; or
— indirectly referenced in the STC through other means which allow to get the complete list of
ICA;or
— directly referenced in the DDP for the articles approved under ETSO.
If direct reference is made to the ICA in the TCDS or the STC, no reference to the revision level of the
ICA should be made. In this case, the revision level should be available elsewhere (e.g. on the DAH’s
website).
For changes to type certificates and repairs, the identification of ‘one complete set of those changes to
the instructions for continued airworthiness’ should be performed by a statement to provide this
information, or by confirmation that there are no changes to the instructions for continued
airworthiness. This statement can also be made in the accomplishment document.
For products and articles where the design approval holder holds a design organisation approval
(DOA), the ICA are considered to be issued under the authority of the DOA, and therefore each
document containing ICA should be marked as approved in accordance with point 21.A.265 (h).
6. New GM No 1, 2, 3 and 4 to 21.A.7(b) are added
GM No 1 to 21.A.7(b) Other persons required to comply
‘Any other person required to comply’ means:
— any independent certifying staff who perform maintenance on an aircraft or component, which
is covered by Regulation (EU) No 1321/2014, in the frame of a contract (or work order) with the
owner or a Continuing Airworthiness Management Organisation (CAMO).
— any maintenance organisation approved to maintain an aircraft or component, which is covered
by Regulation (EU) No 1321/2014 , in the frame of a contract (or work order) with the owner or
CAMO.
— any CAMO approved to manage the continuing airworthiness or the maintenance programme of
an aircraft which is covered by Regulation (EU) No 1321/2014, when instructed by the
owner/operator (through e.g. the contract with the owner/operator).
GM No 2 to 21.A.7(b) Format of ICA
ICA can be furnished or made available by various means (including paper copies, electronic
documents, or web-based access). Regardless of the format, the design approval holder (DAH) is
expected to furnish or make available the ICA in a means that is readily accessible for and useable by
the owner and any person required to comply with the ICA. Service documents, such as service
bulletins, may be used for transmitting ICA information and updates.
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1) Formatting standards
Applicants may use the latest ATA, AECMA/ASD or GAMA formatting standards such as
— AeroSpace and Defence Industries Association of Europe (ASD), ASD-S1000D, International
Specification for Technical Publications Utilizing a Common Source Data Base, version 4 or
higher;
— the Air Transport Association’s (ATA) iSpec 2200, Information Standards for Aviation
Maintenance, latest edition (ATA is now Airlines for America (A4A) but the standard is still listed
as ATA); or
— General Aviation Manufacturers Association (GAMA) Specification No. 2, Specification for
Manufacturers Maintenance Data, latest edition.
In regard to scheduled maintenance, the applicant may also refer to the glossary of the ATA MSG-3
standard, latest revision, for standardised task definitions and designations.
2) General considerations
The ICA should be easy to read and to follow. All ICA should have a method of identifying their
applicability (model, type, etc.), of recording updates to their content and a list of effective pages.
Refer to sample formats in the Air Transport Association’s iSpec 2200, Information Standards for
Aviation Maintenance, latest edition, or AECMA/ASD standards. There is no requirement for any
specific format or arrangement of the ICA in document or documents. However, the specific format
selected by the applicant should be used and applied in a uniform manner. Empty pages in a document
should contain a statement like ‘Intentionally left blank’ or similar.
At the beginning of each procedure, the ICA should contain cautions and warnings regarding possible
mistakes that can be made when applying the procedure.
Abbreviations, acronyms and symbolisation should be either avoided or explained as part of the ICA
documentation.
The ICA contain units of measurements. These measurements could be, for instance, instrument
readings, temperatures, pressures, tolerances, limits, or torque values. If the ICA contain US standard
measurements, the ICA should include a conversion to the metric measurement for each
measurement, tolerance, or torque value. A general conversion table alone should not be provided, as
it may introduce an additional source of error.
The applicant should use a means to indicate changes directly in relation to each item of
information / data of the ICA, e.g. using a vertical change bar in the margin next to the line.
3) Publication of ICA in multiple documents
DAHs may prepare ICA as a document, or several documents, depending on how much data is
necessary to provide complete ICA.
If there are multiple documents, there should be a principal document that describes the general
scope of all other documents, in order to provide an overview of the multiple document structure. The
principal document is the one used for day-to-day maintenance of the product.
In general, it is recommended that the principal document is the document used for maintenance, e.g.
Aircraft Maintenance Manual (AMM), Rotorcraft Maintenance Manual (RMM), Engine Maintenance
Manual (EMM), etc. The type of product will determine the assignment of the principal document.
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According to different standards, the Airworthiness Limitations Section (ALS) needs to be included in
the principal document as a dedicated section. However, the Agency may also accept a separate
Airworthiness Limitations document, when it is at least referenced as such in the principal document.
A DAH who decides to segregate information dedicated to a specific subject from a principal document
into a separate document, e.g. ‘Fuel Pipe Repair Manual’, ‘Cable Fabrication Manual’, ‘Duct Repair
Manual’ or ‘Instrument Display Manual’, should declare these documents to beICA.
DAHs may decide to integrate certain information in a principal document (as e.g. troubleshooting
information as part of the aircraft maintenance manual (AMM) instead of a separate troubleshooting
manual (TSM)).
4) Language
The ICA should be presented in one of the official language(s) of the European Union acceptable to the
competent authority.
Note: ICA in English (simplified technical english, as e.g. in accordance with ASD Specification STE100)
will generally be acceptable to the authorities competent for continuing airworthiness, in and outside
of the EU. In certain countries, such as the USA, English is required for ICA.
5) Electronic Media
ICA may be provided in an electronic format, e.g. CDs, via the internet, etc., instead of paper copies or
microfilms (refer to the AMC 21.A.7(b))
When an electronic format is used, the DAH needs to consider aspects such as the traceability of
updates, keeping previous versions (record keeping), data security and the possibility for the
operator / owner to comply with the relevant operational requirements in updating their maintenance
data or aircraft maintenance program, as ICA form the basis for the maintenance data and aircraft
maintenance program. Furthermore, there will usually be a need for the operator /owner to update
the maintenance data or aircraft maintenance program to introduce changes such as STCs, repairs, etc.
GM No. 3 to 21.A.7(b) Approval status of the manual for an article
In cases where ICA are contained within a document for a specific article, it is possible that the article
and its document may be used in products for more than one DOA holder. In such cases, instead of
placing approval statements from each DOA holder in the same manual, it may be more practical to
identify the approved status of the relevant document through its inclusion in lists managed by the
DOA holders in accordance with the AMC to 21.A.7 (a).
GM No 4 to 21.A.7(b) Integration of ICA between products (aircraft, engine, propeller)
The aircraft/engine/propeller TCH should ensure the availability of the ICA to allow maintenance of the
aircraft, including the engine/propeller when installed on the aircraft.
When referring to engine/propeller ICA directly in the aircraft ICA, the aircraft TCH should not perform
additional verification and validation. However the integration and interface aspects between the
aircraft and the engine/propeller are still under the responsibility of the aircraft TCH.
If the ICA published by the Aircraft TCH include some engine/propeller ICA developed by the
engine/propeller TCH, the engine/propeller TCH should make an arrangement with the aircraft TCH to
properly discharge its responsibilities under point 21.A.7 for its ICA. This arrangement should:
— define the part of the engine/propeller ICA which are published in the aircraft ICA; and
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— address the development, publication and update processes of these ICA, including
completeness and timely availability aspects.
The incorporated engine/propeller data content remains under the responsibility of the
engine/propeller TCH, and the publication is under the responsibility of the aircraft TCH. Therefore the
aircraft TCH must coordinate with the engine/propeller TCH regarding any modification or alteration of
the incorporated data.
7. New AMC 21.A.7(c) is added
AMC 21.A.7(c) Completeness and timely availability of ICA
1) Completeness and timely availability of ICA for type certificate (TC) and restricted type certificate
(RTC) applicants/holders
An applicant may wish to choose between the three options described below. Once the
certification programme starts, it may be necessary to modify the initially selected option to
accommodate program changes. All such changes shall be coordinated with the Agency.
Option 1 – Complete ICA available at time of the design approval (TC/RTC)
a) ICA will be made available at the time of the design approval. This option minimises the risk of
incomplete ICA, especially for changes.
b) With all ICA available at the time of the design approval, they should also be furnished/made
available to the operator/owner and made available to any other person required to comply with
any of those instructions in accordance with points 21.A.21(c)4, 21.A.44 and with 21.A.7, without
using the provision to delay certain parts of the ICA beyond the entry into service.
c) Frequently, there is only a short time between the design approval and the entry into service.
Nevertheless, applicants/holders may still wish to apply option 2 or 3 for a part of their ICA as
stated below.
Option 2 – Complete ICA available at entry into service (TC/RTC)
If the applicant plans for a part of the ICA to be available to the Agency at entry into service, the
following approach is acceptable:
a) For the ALS, as part of the type design, notwithstanding the selection of option 2: the applicant
submits the ALS for approval prior to the design approval. Any ALS contentthat is incomplete, not
yet demonstrated, or delayed beyond the design approval, requires to be compensated through an
interim limitation to establish compliance within this limitation. The interim limitation is to be
published and included in the ALS as a temporary operational limit.
In this context, ALS content is understood as the task method (e.g. a detailed inspection), including
its reference, title and applicability, and the associated threshold/interval/life limit. The
accomplishment procedure, i.e. how to carry out the task, is usually described in other parts of the
ICA (e.g. in the AMM or NDT manual).
1. This typically may apply when the aircraft structural full-scale fatigue testing required for
compliance with the fatigue and damage tolerance requirements, considering the expected
operational life, will not be completed prior to the type certificate being issued. In this case, a
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temporary operational limit is assigned and stated in the ALS, dependent on the aircraft
full-scale fatigue testing progress. The ALS is effectively incomplete beyond this temporary
operational limit, as the required justification and the resulting ICA are not yet available to
support operation beyond this limitation.
2. A TCDS notation is not necessary, since the product is provided with complete ALS content up to
the established temporary operational limit.
b) A compliance plan identifying those parts of the ICA that are only to be provided at entry into
service is produced, submitted and agreed between the applicant and EASA prior to the design
approval (refer also to para. d) for ICA considered to be necessary at the time of the design
approval.
c) A commitment is provided to produce, verify and submit (when requested) to EASA, the relevant ICA
prior to the entry into service. This commitment should be provided in a certification document,
(e.g. the compliance plan) and should also be addressed in a more general manner in a DOA
procedure for EU holders/applicants in accordance with points 21.A.239 and 21.A.263. If the
respective DOA holder has not previously exercised the practice of delaying the ICA beyond the
design approval, in order for the DOA to demonstrate this capability in their design assurance
system (DAS), the required procedural changes need to be addressed via a significant change to the
DAS in accordance with point 21.A.247.
d) ICA considered to be necessary at the time of design approval are provided or made available in a
format that adequately defines the data. Furthermore, the way the data is presented at the time of
the design approval offers the same understanding of the data as in the final published format.
The applicant should agree with the Agency, in a compliance plan, on all ICA necessary at the time
of design approval. The Agency investigation may vary from no involvement or evaluating a limited
sample of the ICA to performing a thorough review of specific parts of the ICA.
e) In cases where the Agency has doubts that the applicant/holder can meet the applicable obligations
of point 21.A.44 to control and support delaying the ICA beyond design approval, or TC/RTC, and
until entry into service, the Agency can decide to assign a condition for entry into service for
non-ALS ICA.
As a condition for entry into service, a note should be included in the type certificate data sheet
(TCDS) as a result of these pending issues under the ICA paragraph as follows:
‘Note: ICA are not complete: as per Regulation (EC) No 748/2012, point 21.A.7, they must be
completed before the entry into service of the aircraft. Contact the Agency for information on the
status.’
The decision to assign a condition may be based on the applicant’s performance, e.g. if the
applicant has already demonstrated in previous projects that they provided the complete set of ICA
before the entry into service, if the applicant has already experienced difficulties in providing the
ICA considered necessary at time of design approval, or has previously failed on a different project
to meet his commitment to complete ICA prior to entry into service, or if the applicant/holder has
no previous experience with the practice of delaying the ICA beyond the design approval.
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f) A post-TC action is established with the Agency to review the ICA status at entry into service (when
the Agency requests such a review).
g) If all the ICA are available to the Agency at the time of entry into service, they should also be
furnished at this time to the operator/owner and made available to any other person required to
comply with any of those instructions in accordance with points 21.A.21(c)4, 21.A.44 and 21.A.7,
without using the provision to delay certain parts of the ICA beyond the entry into service. For an
EU holder/applicant, this should be supported as part of the DOA/ADOA procedure.
Flowchart A, ‘Completeness of ICA’, Option 1 and 2
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Option 3 - Complete ICA available after entry into service (TC/RTC)
Point 21.A.7(c) contains a provision that certain ICA dealing with the ‘overhaul or other forms of heavy
maintenance’ may be delayed until after the entry into service. Although there is no definition of what
is meant by the ‘overhaul or other forms of heavy maintenance’, the intention of the rule is to provide
flexibility to the applicants/holders for long lead ICA of a scheduled nature.
If the applicant plans for a part of the ICA to only be made available after the entry into service, the
following is acceptable for the complete set of ICA:
a) for the ALS, as it cannot be delayed until after the entry into service, paragraph (a) of option 2
applies;
b) for ICA considered to be necessary at the time of design approval, paragraph (d) of option 2 applies.
c) a detailed compliance plan identifying those parts of the ICA that are to be provided prior to and
after entry into service. For ICA made available after the entry into service, the plan should account
for when the ICA are needed so that they can be complied with. This approach may only be used
for scheduled maintenance accomplishment procedures, where threshold/interval/life limit
requirements of the related scheduled tasks are established. In that respect, the following aspects
should be considered:
1. The majority of the ICA are of an unscheduled nature, therefore these items should be
available at entry into service at the latest.
2. Consideration should be given to the fact that a number of tasks are used both for
scheduled maintenance and for unscheduled maintenance (e.g. an operational check of
a system is planned as a scheduled task at a certain point in time, but is also required as
part of the installation procedure to determine the operational status of the system).
3. For ICA to be made available after entry into service, the detailed plan should contain
threshold(s) controlled by the applicant/holder, stating the maximum value in flight
hours (FH) / flight cycles (FC) or calendar time (CT), or a combination as applicable, by
which point the delayed ICA should be made available.
4. This detailed plan should be available prior to the time of design approval and should be
either directly integrated or cross-referenced in a compliance plan.
5. Information on the format in which the ICA delayed until after entry into service will be
made available on time (e.g. regular Revisions or Temporary Revisions (TRs) or service
information (SBs, SIL, etc.).
d) A written procedure/programme that ensures a detailed plan is produced and is implemented in the
applicant’s organisation in order to ensure the timely availability (to the operator/owner and any
other person required to comply with any of those instructions and to the Agency, if involved and
when requested). For an EU holder/applicant, this should be part of the design organisation
approval (DOA) procedure in accordance with points 21.A.239 and 21.A.263.
e) A commitment is provided to produce, verify and provide the relevant ICA in accordance with the
detailed plan. This commitment should be provided in a certification document, (e.g. a compliance
plan) and should also be addressed in a more general manner in a DOA procedure for EU
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holders/applicants in accordance with points 21.A.239 and 21.A.263. If the respective DOA Holder
has not previously exercised the practice of delaying the ICA beyond the design approval, in order
for the DOA to demonstrate this capability in their Design Assurance System (DAS), the required
procedural changes need to be addressed via a significant change to the DAS in accordance with
point 21.A.247.
f) In order to ensure that the applicant/holder can meet their obligations as set out in point 21.A.44 to
control and support delaying the ICA, EASA may decide:
1. For ICA delayed until entry into service, to assign a condition / notation for the entry into
service to be included in the TCDS as a result of these pending issues under the ICA
paragraph, as per paragraph (e) 1. of Option 2;
2. For ICA delayed until after entry into service, to assign an interim limitation to be
published and included in the ALS as a temporary operational limit, also for non-ALS ICA,
to compensate for the delayed ICA. This approach may only be used for scheduled
maintenance accomplishment procedures, where task and interval requirements are
available.
The decision to assign a condition/limitation may be based on the applicant’s performance, e.g. if the
applicant has already demonstrated in previous projects that they provided the complete set of ICA
before the entry into service, if the applicant had already had difficulties in providing the ICA
considered necessary at time of design approval, or has failed before on a different project to control
and support delaying the ICA, or if the applicant/holder has not previously exercised the practice of
delaying the ICA beyond the design approval.
g) A post-TC action should be established with the Agency to regularly review the ICA status, if the
Agency requests such a review, taking into account the DOA oversight activities.
h) An applicant/holder should provide visibility, regarding the ICA that are delayed beyond entry into
service, to the operator/owner and any other person required to comply with any of those
instructions. This can be achieved by providing this information e.g. on a website or in a document,
such as an MPD or AMM, preferably in the principal ICA manual. This visibility information is then
itself considered to be ICA information.
i) It is assumed that for those ICA that are available to the Agency at the time of entry into service,
they are also at the same time furnished to the operator/owner and made available to any other
person required to comply with any of those instructions in accordance with points 21.A.21(c)4,
21.A.44 and 21.A.7.
This is in order to satisfy the Agency that such a delayed publication will not have an adverse effect
on the continuing airworthiness of any individual aircraft.
To allow the timely review and incorporation of a delayed part of the ICA by the owner/operator
(and any other person required to comply with any of the terms of those instructions), the Agency
considers that the delayed ICA should typically be made available two years before the actual ICA has
to be used, when using normal revisions as a format. However, shorter time margins may be
acceptable, provided that the format used ensures the prompt notification of the availability of the
delayed ICA or the ICA itself, but they should not be less than 1 year before the ICA has to be used.
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3. Proposed amendments and rationale in detail
Flowchart B, ‘Completeness of ICA’, Option 3
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3. Proposed amendments and rationale in detail
2) Completeness and timely availability of changes to ICA (TC/RTC)
Point 21.A.7(d) regulates the distribution of changes to the ICA required from the TC/RTC holder.
Those changes to ICA could result from the design change process (minor and major changes),
service experience, corrections and others.
For an EU TC/RTC holder/applicant, a programme showing how changes to ICA are distributed is
part of the respective procedures (e.g. design organisation procedures, or alternative procedures
used to demonstrate capabilities). For changes to ICA triggered by design changes, typically these
procedures follow the same principles as those available for TC/RTC, options 1 to 3, while taking
into account the relevant privileges, e.g. that a DOA may approve minor changes in accordance
with point 21.A.263(c)2.
8. AMC 21.A.14(b) is amended as follows
AMC 21.A.14(b) Alternative procedures
[…]
4.4 Statement
The information and instructions should contain a statement showing Agency approval:
— ‘The technical content of this document is produced in accordance with alternative procedures
to those in the DOA, as agreed by EASA (No. EASA.APxyz) and it refers to EASA approved
[TC][STC][ETSOA] ref. No. xxx.’
9. New GM 21.A.90C is added:
GM 21.A.90C Stand-alone change
A change to ICA is considered to be a stand-alone change when it is not directly prepared together with
a change to the type design. Stand-alone changes to ICA are usually prepared and issued, for example,
for the purposes of making corrections, improvements, to include feedback from users, or to provide
alternatives.
Also, when the ICA are completed after the product (or change to the product) was approved, this is
considered to be a stand-alone change to the ICA.
When a non-ALS ICA variation is triggered by a change to the type design, this does not affect the
overall classification of the type certificate change as per point 21.A.91.
Stand-alone changes are usually straightforward changes, and are not considered to require additional
work in order to show compliance. However, they must be managed in accordance with a process
accepted by the Agency under point 21.A.239 or point 21.A.14(b), for discharging the obligation to
keep the ICA up to date.
Examples of changes that may require additional activities in order to show compliance are changes to
the CDCCL, and EWIS ICA.
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10. Appendix A to GM 21A.91 is amended as follows
Appendix A to GM 21A.91 Examples of Major Changes per discipline
[…]
10.Airworthiness Limitations Section
Changes that adversely affect the already published limitation(s) or introduce a new limitation not
associated with a physical change to the product, as follows:
(i) a reduction in the life limit of more than x%,
(ii) a reduction in the inspection threshold or interval of more than x %,
(iii) the introduction of a new life limit or a new CDCCL,
(iv) the introduction of a CMR item (e.g. the introduction of CCMR into the ALS following MRB
task re-assessment).
11.Stand-alone changes to non-ALS ICA that require additional work to demonstrate compliance with
the applicable certification basis as follows:
(i) changes related to accomplishment instructions (e.g. to the aircraft maintenance manual)
related to the CDCCL, or the EWIS ICA, when changing the technical content (e.g. gaps, steps) of
the procedures,
(ii) the introduction of novel technology for inspection purposes related to an ALS task,
(iii) changes that adversely affect the certification assumptions: e.g. some specific inspection
procedures, such as inspection procedures for use after a hard landing, may include a decision-
making chart based on the level of exceedance of the load in comparison with the certified limit
loads. Such criteria, and adverse changes, need to be agreed with the Agency.
11. GM No. 1 to 21.A.239(a) is amended as follows
GM No. 1 to 21.A.239(a) Design assurance system
[…]
3.1.5 Maintenance Instructions for continued airworthiness and Operating Instructions
a. Ensuring the preparation and updating of all maintenance instructions for continued airworthiness
and operating/installation instructions (including Services Bulletins) needed to maintain
airworthiness (continuing airworthiness)in accordance with the relevant CS. For that purpose, the
applicant should:
— establish the list of all documents it is producing to comply with the Appendix
referred to in CS 23.1529, CS 25.1529, CS 27.1529, CS 29.1529, CS-E 20, CS-E 25, CS-
P 30, or CS-P 40 (NPA P-3);
— define their procedures and organisation to produce and issue these documents, in
accordance with using where applicable and so elected 21.A.2653(hc)(3)
obligationprivilege. These should cover:
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3. Proposed amendments and rationale in detail
preparation, including the format and language (available industrial standards
can be referred to and used);
proofreading (checking for clarity, readability, typos, etc.);
verification of technical consistency with the corresponding approved
change(s), repair(s) or approved data, including their effectivity, description,
effects on airworthiness and environmental protection, especially when
limitations are changed;
verification of feasibility in practical applications; and responsibilities and
authorised signatories.
b. In accordance with 21.A.6, 21.A.757, 21.A.61, 21.A.107, 21.A.119, 21.A.120A and 21.A.449609
(where applicable)] ensuring that these documents are provided to all affected operators and all
involved authorities.
3.1.6 Operational Suitability Data
a. Ensuring the preparation and updating of all operational suitability data in accordance with relevant
CS. For that purpose, the applicant should:
— establish the list of all documents it is producing to comply with CS-MMEL or CS-GEN-
MMEL, CS-FCD, CS-CCD, CS-SIMD and CS-MCSD as applicable;
— define procedures and organisation to produce and issue these documents, using where
applicable and so elected 21.A.263(c)(3) privilege.
b. In accordance with 21.A.6, 21.A.62, 21.A.108, 21.A.119 and 21.A.120B21.A.7, ensuring that these
documents are provided to all affected operators and training organisations and all involved
authorities.
[…]
12. AMC No. 1 to 21.A.243(a) is amended as follows
AMC No. 1 to 21.A.243(a) Data requirements
The handbook should provide the following information for each product covered by the design
organisation approval.
[…]
9. A description of the record keeping system to comply with 21.A.555 and 21.A.105.
[…]
14. A description of the procedures for the establishment and the control of the maintenance and
operating instructions (see 21.A.6, 21.A.7 and 21.A.609 (where applicable)57, 21.A.61, 21.A.107,
21.A.119, 21.A.120A and 21.A.449).
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3. Proposed amendments and rationale in detail
13. GM 21.A.265(h) is amended as follows
GM 21.A.265(h) Designation of data and information issued under the authority of a design
organisation approval (DOA) holder9
[…]
4. PROCEDURE
For the information and instructions issued under point 21.A.265(h), the DOA holder should establish a
procedure that addresses the following aspects of those items:
a. their preparation,
b. verification of their technical consistency with the corresponding approved change(s),
repair(s) or approved data, including their effectivity, description, effects on airworthiness
and environmental protection, especially when limitations are changed,
c. verification of their feasibility in practical applications,
d. the authorised signatories.
The procedure should include the information or instructions prepared by sub-contractors or vendors,
and declared applicable to its products by the DOA holder.
5. STATEMENT
[…]
14. AMC 21.A.433(a) and 21.A.447 is amended as follows
AMC 21.A.433 (a) and 21.A.5447 Repair design and record keeping
[…]
15. New AMC 21.A.609(c)(d) is added
AMC 21.A.609 (c) and (d) Obligations of holders of ETSO authorisations
In CS-ETSO, there is no specification related to ICA, neither in Subpart A, nor specifically in each ETSO.
Although an ETSO article itself typically does not require ICA, the applicable airworthiness standards
may require the installing design approval holder (DAH) or design approval applicant (DAA) to develop
ICA that describe an ETSO article’s installation requirements, within the context of the product, to the
extent necessary to ensure the product’s continuing airworthiness.
In addition, if an installing DAH or DAA explicitly uses ETSO provisions to demonstrate compliance with
an installation requirement, they should review all the maintenance and inspection instructions for the
ETSO article when defining the ICA of the product.
It may be necessary for the DAH or DAA to incorporate these instructions into the ICA of the product to
ensure that the ETSO article continues to satisfy the terms of its ETSO after installation.
Any DAH who wishes to install an ETSO article should comply with point 21.A.303.
9
This amendment is based on the proposed text of this GM as in EASA’s NPA 2017-20 ‘Embodiment of level of involvement acceptable
means of compliance and guidance material to Part-21’ (https://www.easa.europa.eu/document-library/notices-of-proposed-
amendment/npa-2017-20)
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For this, the applicant for an ETSO authorisation may provide by the time of application and before the
authorisation is issued (in accordance with point 21.A.605) the following:
— instructions that cover periodic maintenance, calibration, and repair, for the continued
airworthiness of the article, including specific guidance on the limits of wear and damage that
would warrant replacement;
— the recommended inspection intervals and service life, which may be affected by storage and
operating conditions (i.e. temperature, humidity, etc.).
16. GM 21.B.55 is amended as follows
GM 21.B.55 Record keeping for design approvals transferred to the Agency
Record keeping related to design approvals, for which the responsibility is transferred to the Agency,
will remain initially with the competent authority of the Member State that has granted the approvals,
at the disposal of the Agency. This GM specifies the administrative documents to be kept for the
various kinds of design approvals. It does not repeat the requirements put on holders of design
approvals to keep records (ref. points 21.A.55, 21.A.105, 21.A.118A(a)(1), 21.A.447, 21.A.605).
[…]
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4. Impact assessment (IA)
4. Impact assessment (IA)
4.1. What is the issue
ICA have to be produced by DAHs as part of the product/article certification which, if properly
implemented, should ensure that the product/article remains airworthy during its intended life.
There are several important questions:
— what are the contents of the ICA?
— what is the level of EASA verification and or approval of the ICA?
— when do the ICA need to be available?
— to whom should the ICA be made available?
— how are the ICA used by operators / maintenance organisations?
— are there any possible other issues that have not yet been identified?
The answers to these questions are already contained in the relevant certification specifications, and
in Part 21, in Part-M and in Part-145. However, experience has shown that there is much room for
interpretation in the current rules and standards, leading to differences and possible safety risks. It
appears that different TC holders have different interpretations of what a complete set of ICA is and to
what level they are required to control the data that constitutes the ICA. The consequence is that
maintenance organisations may not have all the necessary data to perform the maintenance in the
correct way, which can lead to them using unapproved methods.
In addition, there was a specific request from the RMG to emphasise and clarify the obligation for
supplemental type certificate (STC) holders/applicants to produce and make available ICA for the
changed product.
Furthermore, industry representatives pointed out that the requirements related to instructions for
continued airworthiness, as well as to manuals and record-keeping, are duplicated in various sections
under different Subparts of Part 21.
4.1.1. Safety risk assessment
As the status of ICA (their scope, approval/verification, format, availability) is unclear with the current
Part 21 and related GM, potential safety risks exist due to possible misinterpretation of the
implementing rules and airworthiness codes.
These risks have been identified in the investigations of two accidents, which lead to the following
safety recommendations being addressed to EASA:
— SR ICLD-2013-001: Boeing 757-200 TF-FIJ, Icelandair, 85 NM south-south-east of London Gatwick
Airport on June 4, 2009.
Smoke on the flight deck and in the cabin was followed by an engine shut down and an
emergency landing because a maintenance action from a component maintenance manual
(CMM) had not been performed.
A safety recommendation asked for guiding rules to be set for airframe and engine
manufacturers such that maintenance planning documents (MPDs) and engine maintenance
manuals (EMMs) clearly include recommended maintenance information from the CMM of
subcomponents.
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4. Impact assessment (IA)
— SR UNKG-2007-004: Piper PA-28R-201T G-JMTT, near 9 NM south of Oban Airport, Argyll
(Scotland) on April 9, 2007
The aircraft crashed after a loss of control in instrument meteorological conditions due to a
defective vacuum pump because its maintenance had not been performed.
A safety recommendation asked EASA to comply with vacuum pump maintenance and
replacement requirements to ensure that aircraft fitted with vacuum-driven attitude indicators
can be safely operated in instrument meteorological conditions when aircraft are certified to do
so.
This NPA addresses both of these safety recommendations by proposing revised GM, according
to which the DAH should systematically review the initial maintenance recommendations
provided by suppliers and consider whether they are applicable and effective. This review also
includes ETSO articles where DAHs or DAAs may have to incorporate certain maintenance
instructions into the ICA of a product, to ensure that the ETSO article continues to satisfy the
terms of its ETSO authorisation after installation.
4.1.2. Who is affected
The following stakeholders are affected:
producers of ICA — TC holders and applicants,
— STC holders and applicants,
— Minor change approval holders and applicants,
— Repair design approval holders and applicants,
— ETSO authorisation holders and applicants,
— suppliers of components to the above approval holders
users of ICA — owners/operators,
— maintenance organisations
authorities — national aviation authorities,
— EASA
4.1.3. How could the issue/problem evolve
If the regulatory framework is not changed, maintenance organisations may not have all the necessary
data to perform maintenance in the correct way, which can lead to them using unapproved methods,
as identified by the two SRs.
Another risk is that a continued airworthiness management organisation does not have all the
applicable maintenance requirements to develop the aircraft maintenance programme
4.2. What we want to achieve
The operational objectives of this proposal are to clarify the status of ICA versus type certificates and
the consequences on their identification, approval and/or level of verification.
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4. Impact assessment (IA)
4.3. How it could be achieved — options
To clarify the status of ICA, the following options were discussed:
Option 1: similar to operational suitability data (OSD) - ICA would be approved under (as a part of) a
TC. All changes to ICA are considered as changes to a TC and need to be processed in accordance with
Part 21, Subpart D.
Option 2: ICA would be included in the TC but with a ‘special treatment’ as ICA are an obligation for a
design approval holder (DAH).
Option 2a: existing technical verification processes would be strengthened. Non-airworthiness
limitation section (ALS) changes to ICA would not need to be classified and approved in accordance
with Part 21, Subpart D.
Option 2b: Part 21 Subpart D would be partially applicable for Non-ALS ICA.
Option 3: only the airworthiness limitation section (ALS) would be part of the TC, Non-ALS ICA would
not be included in a TC – the technical verification process would be strengthened for Non-ALS ICA.
Option 4: no clarification on the ICA status as part of the TC or not, but only the technical verification
process would be strengthened.
4.4. What are the impacts
4.4.1. Safety impact
Options 1 and 2 (a and b) would clarify the status of ICA as part of a TC: it is expected that they will
improve the quality and consistency of ICA.
Clarification of the questions listed in Section 4.1 would contribute to ensuring that the ICA are
complete, checked properly by authorities, available to those who have to use them, and also that they
are used properly. This is expected to lead to better control of the continuing airworthiness of all
aircraft within the scope of EASA and therefore it is expected to be beneficial in increasing safety .
Option 3 and 4 would keep the current situation where ICA between various manufacturers are not
identified as such, leading to some maintenance actions not being performed.
4.4.2. Environmental impact
No environmental impact is anticipated. Compliance with ICA should also ensure continued compliance
with the environmental requirements.
4.4.3. Social impact
All options would increase the need for qualified staff in ICA producers’ organisations as a result of this
task: however, options 1 and 2 would require more involvement from design organisation approval
holders.
4.4.4. Economic impact
The strengthening of the technical verification of ICA would require additional resources from ICA
producers, mainly for options 1 and 2. Also, the outcome for all options would be that ICA should be
made available to more parties than they are today, and also that the ICA would include all component
maintenance manuals, thus increasing their cost of distribution.
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4. Impact assessment (IA)
4.4.5. General Aviation and proportionality issues
Options 1 and 2 would provide benefits to General Aviation stakeholders because of the clarification of
the ICA status and their availability.
4.5. Conclusion
4.5.1. Comparison of options
Option 1 is the most consistent with Part 21 principles and justifies how the Maintenance Review
Board (MRB) process could be explained as it is currently performed by EASA. However, it would
require additional functions for ICA in the approval process (CVE and OoA) and additional process steps
would be needed (e.g. certification programme). Furthermore, it would raise dis-harmonisation with
the Federal Aviation Administration (FAA).
Option 2a raises no dis-harmonisation with the FAA and would cause a relatively small change in
current industry practices. However, there is no consistency with the current Part 21, especially with
the recently implemented OSD rule changes, and the MRB process cannot be explained.
Option 2b is partially consistent with the current Part 21 principles and the MRB process could be
explained. However, it would require additional functions for ICA in the approval process (CVE and
OoA) but with a limited impact compared to option 1 and additional process steps would be needed
(e.g. certification programme); furthermore, the new regulatory differences would have to be
addressed in the FAA/EASA Technical Implementation Procedures (TIP) of the US/EU Bilateral Aviation
Safety Agreement (BASA).
Option 3 raises no dis-harmonisation with the FAA and requires relatively small changes to current
industry practices. However, there is no consistency in Part 21, especially with the recently
implemented OSD rule changes. Non-ALS ICA are not considered to be included in TC. The MRB process
cannot be explained.
Option 4 would not clarify the status of ICA versus a TC, but it would require additional verification
functions from design holders.
During the review of the options by the RMG, option 2b was identified as the favourite option of most
of the members of the working group, as it:
— clarifies the status of ICA as part of a TC, which options 3 and 4 do not,
— justifies the MRB process as currently supported and monitored by EASA,
— relies on companies with design organisation approvals to manage the development of most CA;
and
— allows the management of changes to ICA following a process that is simpler than that of
option 1.
The main dissenting views were due to the dis-harmonisation with FAA and the fact that this option is
not fully consistent with Part 21 principles.
4.5.2. Option chosen
EASA reviewed the proposal from the RMG and its dissenting views, and decided to propose option 2b.
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4. Impact assessment (IA)
4.6. Monitoring and evaluation
This RMT on the update of Part 21 and the related GM on ICA is a result of EASA’s monitoring and
evaluation activities.
EASA continuously monitors the implementation of Part 21, the AMC and GM through feedback from
stakeholders and via the EASA advisory bodies.
Various tools will be used to further monitor the present proposal, e.g. surveys to collect data on the
level of consistency and coherence of ICA requirements.
In addition, Part 21 will be subject to an evaluation, which is already planned in EASA’s European Plan
for Aviation Safety (EPAS). The evaluation should assess the production of ICA by DAHs if the above
mentioned monitoring results show a need to do so.
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5. Proposed actions to support implementation
5. Proposed actions to support implementation
The implementation of this proposal will be supported by the following actions:
— focused communication for advisory body meeting(s) (TeB, STeB); and
— detailed explanation with clarification and indicated hints on the EASA web pages.
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6.References
6. References
6.1. Affected regulations
Commission Regulation (EU) No 748/2012 of 3 August 2012 laying down implementing rules for the
airworthiness and environmental certification of aircraft and related products, parts and appliances, as
well as for the certification of design and production organisations
6.2. Affected decisions
Decision N°2012/020/R of the Executive Director of the Agency of 30th October 2012 on acceptable
means of compliance and guidance material for the airworthiness and the environmental certification
of aircraft and related products, parts and appliances, as well as for the certification of design and
production organisations (‘AMC and GM to Part 21’)
6.3. Other reference documents
— Safety Recommendation ICLD-2013-001: Boeing 757-200 TF-FIJ, Icelandair, 85 NM south-south-
east of London Gatwick Airport on June 4, 2009.
— Safety Recommendation UNKG-2007-004: Piper PA-28R-201T G-JMTT, near 9 NM south of Oban
Airport, Argyll (Scotland) on April 9, 2007
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European Aviation Safety Agency NPA 2018-01
7.Appendix
7. Appendix
N/a
TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 37 of 37
An agency of the European Union