ARSA RSS Feed ARSA LinkedIn
Ask ARSA Pay ARSA

ARSA Weighs in on Proposed FAA ICA Policy

On Jan. 4, ARSA submitted its comments to the FAA’s draft policy regarding the availability of instructions for continued airworthiness (ICA).

The Association believes that the current policy must be rewritten to ensure that the regulations are not used to justify contractual restriction and to discourage such practices.

While ARSA is pleased to see the FAA taking an interest in this important area, it is critical that any FAA policy on the matter be enforceable under the safety regulations. To tackle the contractual obligations and economics of availability, the FAA must address all four fundamental issues:

1) Set the standard for the nature and extent of information that is essential to the continued airworthiness of an aviation product.

2) Set the standard for the content of ICA documents.

3) Determine exactly who is “required to comply” with the ICA.

4) Determine exactly how ICA should be “made available.”

Without addressing basic requirements, it is unclear how the proposed policy will reduce the burden on maintenance providers in determining and maintaining appropriate maintenance instructions or reduce the possibility of error caused by applying an incorrect ICA.

As currently drafted, the FAA’s proposed policy would have the agency reviewing private contracts, an inappropriate action. Since the FAA has not declared restrictions on the distribution and use of an ICA void as a matter of public policy, its jurisdiction is problematic. Rather the FAA’s policy should state that it will not support the implementation of non-technical provisions, such as restrictions on use of alternative parts, procedures or suppliers.

Requiring repairs or alterations only by the DAH or a DAH-authorized source and statements limiting the dissemination of the data between the “operator” and its chosen maintenance provider are unenforceable under the provisions of 14 CFR. Indeed, regulatory compliance discourages such activity.

In its comments, ARSA suggests a number of changes that, if accepted, would align the proposed policy with existing regulations in addressing ICA restrictions.

~~~ posted 1/9/12 ~~~



More from ARSA

Coming Soon On Demand – An Overview of Part 91

On May 31, ARSA Executive Vice President Christian Klein presented an online training session overviewing 14 CFR part 91. Description: This session overviews the general operating rules of 14 CFR…Read More

AMT Day 2023 – Celebrating Charlie

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 155 years later – we celebrate him with every safe arrival…Read More

GAO Workforce Report Makes Limited Use of Misleading Data

On May 17, the U.S. Government Accountability Office (GAO) released a report on the “Current and Future Availability of Airline Pilots and Aircraft Mechanics.” The GAO’s analysis reads like a…Read More

Live Training Sessions

Stay smart. Stay current. Stay out of trouble with ARSA training.…Read More

Training – Part 43 for Repair Stations

On June 14 at 11:00 a.m. EDT, ARSA Vice President of Operations Brett Levanto will lead an online training session covering 14 CFR part 43 that highlights the interplay between…Read More
Master Air Parts
ARSA