Update on ICA Instructions for Continuing Airworthiness 4 June 2009 Cologne Rotorcraft PCM
Update on ICA: overview Status of activities related to implementation of current regulations Rulemaking activities for the future 4 June 2009 Slide 2
Status ICA activities Working Group Review of ICA Definition ( what and when ), current regulations Sept. 2008, launch of a WG (C+DOA) triggered by DOA findings and FAA statements of non-compliance Internal review within EASA to collect information on current industry practice and applied ICA definition Basic questions: what includes the complete package of ICA and when must it be available Review of existing requirements Part 21, CS25.1529, Appendix H Drafting of a EASA check list to support current ICA compliance finding (issue 21 frozen in March 2009), comparable to the FAA order 8110.54 ICA check list review from rulemaking to ensure interpretation given are within the remits of the current regulation Identify issues to the planned Rulemaking WG for further attention which may require an update, review of the regulatory framework and guidance material ( long-term activity) Basically completed 4 June 2009 Slide 3
Status ICA activities Discussions with a Sample of EU TC Holders Provide industry with background on EASA WG activities to understand better industry practice, capability and concerns in relation to the current regulations Sample on active EU TC holders Airbus, BAe, ATR, Dassault, Alenia and CASA, (Eurocopter, TBD review for the time being dedicated to CS 25) Major results so far: Wide variations on what is considered ICA by industry Majority of TC holders respect the timely availability of ICA at TC, EIS/CoA, when Concern on CMMs being declared ICA (business impact) Concern on the practical implementation of the ICA as part of the DOA, certification activities if the ICA scope would be enlarged Request of a workshop to allow different industrial players to comment on final checklist Ongoing 4 June 2009 Slide 4
Status ICA activities Discussion with FAA & TCCA on their Approach and Understanding Discussion during the FAA/EASA/Airbus Meeting in November 2008. Agreement on the need to harmonize and to meet for further consultancy FAA is reviewing their engineering order 8110.54 for ICA compliance (basically for implementation of EWIS requirements) and has drafted a Memo dealing with the use of an operational limit in case of incomplete ICA. This also addresses a regulatory difference in 14 CFR 21.50 compared to IR 21A.61. EASA has recently provide comments to this FAA Memo. Major comment placed: legal requirements for an operator to integrate in a timely manner updated or new ICA which are delivered in extension of an operational limit (especially the one not being enforced by mandatory actions) Ongoing Rulemaking WG Terms of Reference (TOR) currently drafted for the long-term activities Ongoing 4 June 2009 Slide 5
ICA rulemaking Rulemaking task MDM.056 Instructions for Continued Airworthiness Draft TOR sent for consultation to AGNA/SSCC Drafting group to be set up FAA and TCCA invited to participate / follow: Positive reaction at CMR meeting Might affect Part-21, all CS, Part-M and Part- 145 and associated AMC/GM Opinion/Decisions scheduled 1Q 2012 4 June 2009 Slide 6
MDM.056 TOR Subjects to be addressed What is the content of ICA E.g. includes all CMM? How far need ICA to be controlled by TC holder What is the level of Agency verification and/or approval of ICA E.g. need for specific approval of certain parts of ICA: what is checked for other parts How does the MRB process fit in the approval/acceptance of ICA 4 June 2009 Slide 7
MDM.056 TOR Subjects to be addressed When do ICA need to be available Regulatory difference with FAA what needs to be there before TC; what can be made available later Privileges under DOA to issue and (possibly) approve ICA Should DOA privileges be extended 4 June 2009 Slide 8
MDM.056 TOR Subjects to be addressed To whom should ICA be made available Only to operators/owners, or Also to maintenance organisations How are ICA used by operators / maintenance organisations How far can operators deviate from ICA Specific point of attention: Obligation for STC holders to produce ICA Possible other issues 4 June 2009 Slide 9
MDM.056 objectives Clarification, not reinvent the wheel Align as much as possible to existing practice Harmonisation with FAA is important FAA and TCCA invited to participate / follow: Positive reaction at CMR meeting Drafting group to review also existing FAA documents 4 June 2009 Slide 10
Thank you for your attention Questions? 4 June 2009 Slide 11