Considering NPA 2018-01 in Relation to EASA Instructions for Continued Airworthiness

SofemaOnline looks at the challenges related to the potential uncertainty of the status of instructions for continued airworthiness (ICA) and needs, therefore, to avoid there being too much room for interpretation in the rules and standards, leading to differences and possible safety risks.

The specific objective is to establish clear requirements and responsibilities for all parties involved in the production of ICA, their approval and their implementation.

The Notice of Proposed Amendment (NPA) proposes to amend Annex I (Part 21) of Regulation (EU) No 748/2012 to clarify that ICA are part of the type certificate (TC) and to develop the related acceptable means of compliance (AMC) and guidance material (GM).

It also merges the requirements related to record-keeping, manuals and ICA in the various subparts into a single requirement for each of these aspects in Subpart A (new points 21.A.5, 6 and 7).

The proposed changes are expected to improve the harmonisation of ICA among the design approval holders (DAHs) in relation to the identification, approval, formatting, and availability of ICA to the end-users.

Instructions for continued airworthiness (ICA) have to be produced by design approval holders (DAHs) as part of the product/part certification which, if properly implemented, should ensure that the product/part remains airworthy during its intended life.

Experience has shown that there is too much room for interpretation in the current rules and standards, leading to differences and possible safety risks.

It appears that different type certificate (TC) holders have different interpretations of what is a complete set of ICA and to what level they are required to control the data that constitutes the ICA.

The consequence is that maintenance organisations may not have all the necessary data to perform the maintenance in the correct way, which can lead to them using unapproved methods.

The aim of this proposal is to clarify the status of ICA in order to improve the continuing airworthiness of all aircraft within the scope of the Basic Regulation, and therefore to improve safety.

Related safety issues The following safety recommendations (SRs) addressed to EASA from aircraft accident investigation report(s) published by the designated safety investigation authority.

Boeing 757-200 TF-FIJ, Icelandair, 85 NM south-south-east of London Gatwick Airport on June 4, 2009. (Smoke in the flight deck and the cabin was followed by an engine shut down and an emergency landing because a maintenance action from a component maintenance manual (CMM) had not been performed.)

Piper PA-28R-201T G-JMTT, near 9 NM south of Oban Airport, Argyll (Scotland) on April 9, 2007. (The aircraft crashed after a loss of control in instrument meteorological conditions with a defective vacuum pump because its required maintenance actions had not been performed.)

The proposed NPA addresses potential issues by proposing revised GM, which states that DAHs should systematically review the initial maintenance recommendations provided by suppliers and consider them whether they are applicable and effective.

This review also includes European Technical Standard Order (ETSO) articles where the DAH or design approval applicant (DAA) may have to incorporate certain maintenance instructions into the product’s ICA in order to ensure that the ETSO article continues to satisfy the terms of its ETSO authorisation after installation.

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