Regretfully, the ICA acronym that I am referring to is not an “I Can Attitude”. ICA stands for Instructions for Continued Airworthiness and provides documentation of recommended methods, inspections, processes and procedures to keep products airworthy. The ICA must contain information on each item or part, as appropriate, installed on the product and can represent a whole lot of repeated inspections, life limit, overhaul and functional testing.
The Original Equipment Manufacturer (OEM) creates the inspection program, Chapters 4 and 5, for a new aircraft’s Maintenance Manual. This Maintenance Manual is based on the commonly referred-to ‘Green’ aircraft. This reference’s origin comes from the color of the delivery primer paint and bare minimum equipment that is installed at this point. This Green condition is typical of larger turbine aircraft when delivered from the manufacturing plant to a completion center, where all of the pilot toys are installed into the cockpit, and the luxury interior and accessories are added to the cabin.
Each component or system that is added requires an ICA to assure future reliability and safety. Each ICA goes through a series of reviews and approvals by the appropriate Regulating Authority and is then incorporated into the Maintenance Program for that particular aircraft being delivered and is approved, as long as no changes are made to any systems or components. The challenge is, these additional ICA requirements are not in the OEM Maintenance Manual, but buried in additional inspection requirement paperwork. This is where the ATA Chapter Codes and a maintenance tracking system explode from a few required items with a Green aircraft to a multitude of additional items from all the ICAs.
During the life of the aircraft, minor changes to avionics components and interior systems are made, and each of those should include some kind of an ICA inspection, functional check, or replacement. These are all added to the inspection program and hopefully those ICAs from the removed equipment are deleted from the inspection program. If the ICA for a removed item is not deleted, then you could have an aircraft inspection program that requires more maintenance dollars spent on a mechanic looking for a component, or attempting to perform redundant functional checks on a piece of equipment that is no longer in the aircraft.
Refurbishments of an aircraft should include not only new avionics, interior and exterior colors, and new creature comfort items, but a full review and correction of the ICAs that are contained in the inspection program. The completion of this review and appropriate corrections will have a major impact on future maintenance costs by eliminating obsolete inspections and functional checks, but also by combining the old systems with the new ones and redesigning a combined ICA, rather than just adding another one to the package.
Let me share just one of the many ICA problems that I have run into while performing my duties at JSSI as an Airframe Technical Advisor: Life Raft inspections and overhaul requirements are required at specific intervals. These vary between manufacturer and model of raft. If an old ICA is not revised or removed when a life raft is replaced with a different make or model, you will be performing the required maintenance either too soon, which will be costly, or too late, which will result in an un-airworthy condition.
The ironic part about the rafts not being inspected properly is that the requirements are on a placard attached on the outside of the raft and are easy to locate. But it is not uncommon to have your aircraft in the shop with a job card to remove the raft and perform an inspection before it is due. The maintenance technician complies with the job card instructions, wondering why the placard on the raft shows that it is not due yet but his job is to perform the maintenance as directed.
The maintenance facility will rarely perform the required inspection in-house, so they comply with the maintenance job card and create a Purchase Order for the outside shop to have the inspection/overhaul performed, as stated in the ICA that is still listed in the inspection program.
You can see where this is going… The raft arrives at the vendor that performs Life Raft Inspections/Overhauls even though the placard on the raft clearly states that the raft is not due for any work, but the Purchase Order is for the inspection/overhaul. Sometimes you will get lucky and a responsible technician will inform you that the raft is really not due for any maintenance, but do you really want to rely on luck to drive your aircraft maintenance expenses? After $3,000 for the raft inspection and hundreds of dollars in shipping for maintenance that was not due, the raft is returned, the job card is signed-off and the aircraft is returned to service.
Now the question is: Was the ICA changed in the system to reflect the actual maintenance interval, or does this just occur all over again? All of this happens because someone did not notice or take the time to review the ICA for the component that is installed, and make a minor correction to the paperwork and tracking system.
An even worse scenario than the costly mistake described above would be that an FAA Inspector meets you on the ramp, climbs into the cabin, has your crew pull out the life raft and there on a placard on the outside of the raft is a statement that reveals its inspection/overhaul was due six months ago. The time and money spent on replying to aviation authorities’ questions, hiring lawyers and the possible impact on charter certificates, pilot and mechanics certificates and even the possible revocation of certificates, is all very daunting when it could have been prevented with just a little extra research and a paperwork correction.
When you look at all of the items that have ICAs on your aircraft, you really need to have the “I CAN ATTITUDE” of taking the time and effort to add ICAs to your list of items to update and review during an aircraft refurbishment.