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.
For the purposes of this article, we are going to install a pair of cable cutters on a Part 91, Weston 210, 4 place, single rotor, helicopter using approved data under a FAA field approval. For the uninitiated, the cable cutters are two sets of long sharpened steel blades shaped like an open bird beak, mounted and riveted to the top and bottom of the aircraft along the longitudinal center line, just forward of the cockpit. The object of this alteration is to cut a cable in two with the fixed blades instead of ensnarling the helicopter in the cable. Using this installation scenario, I want you to figure out whether or not you would have to create instructions for all of the checklist items or just need to write N/A. So, for each of the following 16 items just write either a "yes" or a "no." "Yes" means you have to write something for the ICA and "No" means this is not applicable to this installation.
Item 1. Introduction. This is where you describe the aircraft, engine, propeller, or component that has been altered.
Item 2. Description. Describe the major alteration and its functions, including an explanation of its interface with other systems, if any. Yes________No___________
Item 3. Control. Is the major alteration controlled in some way, are any special procedures needed to operate the device(s).
Item 4. Servicing instructions. Does the installation require routine servicing such as maintaining fluid levels, servicing points, access panels, as appropriate.
Item 5. Maintenance instructions. This is where you can set up the recommended inspection periods, cover what has to be cleaned, serviced, and maintained. This section can refer to the manufacturer's instructions, if any, by reference. It should also include warnings, special notes, cautions, etc.
Item 6. Troubleshooting information. Describes any probable malfunctions, How to recognize those malfunctions and remedial actions to take.
Item 7. Removal and replacement information. Describes the order and method of removing and replacing products and parts and any necessary precautions. This section can list replacement parts or their equivalent.
Item 8. Diagrams. Where access plates are and information on how to gain access for inspection.
Item 9. Special inspection requirements. Such as X-rays, ultrasonic testing, or magnetic particle inspection if required.
Item 10. Application of protective treatments. Is anything applied to the affective area after inspection or maintenance, if any.
Item 11. Data. This is relative to structural fasteners such as type, torque, and installation requirements, if any.
Item 12. List of special tools. Such as required nuclear-powered torque wrench or wind drive safety wire pliers, if any.
Item 13. For commuter category aircraft. The following information must be provided, as applicable:
- Electrical loads.
- Method of balancing flight controls.
- Identification of primary and secondary structures.
- Special repair methods applicable to the aircraft.
Item 14. Recommended overhaul periods. This is required to be noted on the ICA when the manufacturer establishes an overhaul period for a component or piece of equipment. If no overhaul period exists then the ICA should state "no additional overhaul time limitations."
Item 15. Airworthiness limitation section. Must include any "approved" airworthiness limitation(s) identified by the manufacturer or found in a companion STC or other field-approved installation that interfaces with this alteration.
Item 16. Revision. This includes information on how to revise the ICA. For example, a letter will be submitted to the local FSDO with a copy of the revised FAA Form 337 and the revised ICA. The FAA inspector upon accepting the change, will sign Block 3 of the Form 337 with the following statement: The attached revised/new ICA (date____) for the above aircraft or component major alteration have been accepted by the FAA, superseding the ICA (dated______). After the revision has been accepted, a maintenance entry will be made, identifying the revision, its location, and date on the FAA Form 337.
What I got! For those interested parties, I said, "yes" to items 1, 2, 5, 7, and 16. Others who took this little exercise may have also said yes to items 11, 12, or 13. What you have to remember is there is no 100 percent correct answer because none of us will write identical ICA for this installation.
The checklist only provides a method by which the most important items will be addressed. The mechanic decides what should be in the ICA, and the FAA inspector has a choice to either "accept" the mechanic's logic or reject it. The magic word here is "accept" not "approve." From the FAA inspector's point of view, the difference between writing the words "accepted by the FAA" and writing "approved by the FAA" is the difference between deciding what rope will be used at a hanging or being the one being hung by it.
In closing, I hope this little article on how to make your own ICA is a help to you. I know it made me feel better.