The subject, and definition, of Instructions for Continued Airworthiness (ICA) remains a topic that’s often misunderstood or misrepresented. It’s not uncommon for hear the use of the term ICA when referring to a document that some call “the principal document.” This has led to confusion when an applicant for an STC, in particular for an interior completion, does not clearly establish or communicate the requirements at the start of the project.
Since the loss of Swissair Flight 111 on September 2, 1998, the FAA started to look closer at aircraft modifications and the respective documentation, with a focus on the ICAs. While the FARs have always required ICAs, enforcement had been limited to new Type Certificates. After this tragic loss of life, the FAA began to look closer at ICAs for interior modifications. Then came the investigation report after the loss of TWA Flight 800 July 17, 1996 which found no evidence of a terrorist attack. These two horrific accidents put the whole topic of Instructions for Continued Airworthiness front and center for the FAA.
Over the past twenty years I have seen the FAA go from not “looking” for ICAs on an interior completion project to where we are today: a lot more scrutiny from the FAA, and specifically the AEG group. The FAA has issued guidance in the past in an effort to bring clarity to this very important aspect of the certification process, with a specific focus on maintaining the airworthiness of an aircraft after extensive modifications.
The degree of misunderstanding or misinformation as it pertains to ICAs is highlighted by the most recent release of guidance from the FAA on this topic. After many years of little or no guidance on this topic, in October of 2010 the FAA issued order 8110.54A – Instructions for Continued Airworthiness Responsibilities, Requirements, and Contents. The FAA has put out a draft of 8110.54B, as well as a draft Advisory Circular AC No: 20-ICA. You should look these up and see where the FAA is headed with regards to ICAs. And don’t find yourself in a difficult situation with your next project by having incomplete ICAs and a looming re-delivery schedule.
For an update on the topic of ICA’s and revision control from an Operator’s perspective please visit the OneStrand Audio Blog published January 15th, 2018.