Planned changes to EASA instructions for continued airworthiness (ICA) and parts-marking rules take into account industry feedback on a draft proposal but stop short of satisfying maintenance providers that believe their access to key repair data remains too limited.
A revised opinion, or proposed rule change to the European Commission, issued by EASA in December 2019 shows the agency’s most significant proposal—incorporating ICA into the applicable EASA type certificates (TC)—remains in place. One change from the draft rule: ICA for repair design approvals do not have to be made available right away. “The repaired product, part or appliance may be released into service before the related instructions for continued airworthiness have been completed, but this shall be for a limited service period, and in agreement with the agency,” EASA explained.
The regulation defines ICA as any maintenance information that references airworthiness limitations, the accomplishment of scheduled maintenance—such as the periodic removal of a component for an inspection or test—referenced in the product ICA, or when a design approval holder (DAH) specifies information as ICA. This means some component maintenance manuals (CMMs) will continue to be categorized as outside the scope of ICA—a point that many in the maintenance industry have challenged for years.
“CMMs are not ICA yet are required as ‘approved data’ under the EASA regime for maintenance,” Aeronautical Repair Station Association (ARSA) executive director Sarah MacLeod said.
ARSA’s comments on the proposal argued that the regulations will continue to leave a gap between DAH requirements and those that MRO providers must follow, even if EASA adopts its proposed changes. “The [EASA regulations] Part-M and Part-145 requirements are not limited to components referenced in airworthiness limitations or those having a recommended scheduled maintenance interval in the product’s ICA,” ARSA argued. “They apply to all components.”
EASA responded by saying the rule updates are aimed at improving safety, not addressing commercial considerations. The proposed ICA changes were prompted in part by two accidents linked to failure to follow required maintenance actions. In one, involving the commanded shutdown of an engine on a Icelandair Boeing 757 and subsequent emergency landing in June 2009, an engine’s low-pressure fuel pump failed due to extensive wear. Investigators found that required maintenance detailed in the CMM was not incorporated into Icelandair’s maintenance program.
“The specific objective ... is to establish clear requirements and responsibilities for all parties involved in the production of ICA, their approval and their implementation,” EASA explained in its draft proposal, issued in early 2018. “The new [guidance material], for their format and their link with supplier’s documentation, will increase the consistency of ICA between manufacturers. Therefore, the implementation of ICA by the end-users will be improved.”
EASA also simplified proposed parts-marking requirements changes and will no longer require an EASA Form 1 for all parts. But instead of requiring parts to be categorized into one of four categories, as the draft proposed, they will now need a Form 1 unless they are determined by the DAH as having a “negligible safety effect.”
Some commenters pointed out that EASA’s proposed system makes it possible for two DAHs to classify the same part differently.
“It would be needed, in those cases where the same part is classified in both categories for different products, that the MRO stocks the parts separately,” EASA acknowledged.
Another option, EASA said, is to only purchase the parts from suppliers that provides the parts with Form 1s.
“A part with an EASA Form 1 can always be installed even when that part, according to the ICA published by the [DAH], does not require it,” the agency said.
The next steps are adoption by the EC and final publication, including guidance material. EASA expects the new regulations to be in place by late 2021.
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