As a raconteur of the FARs, some days I feel that I am as effective as a Band-Aid on a sucking chest wound. Why this attempt at self-flagellation? Allow me to explain. This year, from the middle of January through the end of March, I traveled to 31 cities doing IA renewal meetings. This function, which is described in my job description in small print, says that not only do I have to explain Federal Aviation Regulations; but I have to defend them as well. The majority of IAs sitting in my class would rather be someplace else for eight hours instead of listening to a D.C. bureaucrat wagging his tongue. But on the flip side, most IAs would agree that beats the alternative, which is to sit for the IA test over again or take an oral exam from an FAA inspector.
At most of these meetings this year, I covered the less-than-exciting subject of Instructions for Continued Airworthiness (ICA) for about two hours. I explain that an ICA can be a 20-page maintenance manual or a single paragraph of instructions that describes procedures and inspections for maintaining a major alteration performed under an FAA field approval. The format of the ICA, be it a manual or just a paragraph, has to look like the applicable airframe/engine/accessory manufacturer's manual on whose product the major alteration was performed.
It was depressing to find out early on that a good third of the IAs in my classes did not know how to fill out an ICA, or that the ICA checklist was in AC 43-210, titled: Standardized Procedures for Requesting Field Approval of Data, Major alterations and repairs. This bit of reality really sunk my boat since I wrote the ICA policy and checklist in 1999, wrote two articles about it in AMT magazine in 2000 and the AC was published by AFS-340 on Feb. 17, 2004. Since the FAA has no courses on depression management, let me try again to get the message out on ICA.
A Few Important Facts
Before I cover the checklist items, which are the meat and potatoes of the ICA, let's cover a few important ICA facts.
- ICA is required only for a major alteration that is field approved.
- ICA is data accepted by the FAA inspector; it is not approved data.
- ICA can be changed to fit the aircraft's inspection program.
- ICA are attached to the Form 337 for the major alteration to ensure that the ICA can be retrieved from the aircraft's file in OKC.
- ICA can be developed for older major alteration field approvals that were installed prior to 1999.
- The ICA checklist provided in AC 43-214 meets FAA requirements.
- The ICA checklist has 16 items but most installations require written statements for only five to eight items.
- The ICA must be attached to the Form 337 at the time it is submitted to the FAA for the field approval.
- The ICA allows you to identify replacement parts. These parts do not necessarily need to be PMA or TSO parts.
- All ICA checklist items must be addressed. Those items that are not applicable to the alterations are marked with N/A.
On page 19 of AC 43-210 is Figure 1, which contains the checklist for an ICA. As I explained earlier, I designed the checklist and it was first published in 1999. I made it a generic document that would hopefully cover 98 percent of all major alterations performed under a field approval. In my "live" presentations of ICA I go over how the ICA policy was developed, using a PowerPoint presentation that starts with a beautiful lady lawyer who asked me a question, then spend some time discussing the possible end of field approvals as we know it, and finish by installing a nuclear powered port-a-potty on an aircraft. The AMT editor limits the amount of words I am allowed to write per article, so in order to hear the rest of the story on how those three events interacted to create the ICA policy you will have to attend one of my IA renewal presentations on ICA.
In Part 2 of my tome on field approvals, we will cover current field approval policy found in Change 16 to FAA Order 8300.10.
My father was a big man, straight from the old sod. He was a lot smarter than I and a card-carrying survivor of the depression years.
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