publishing further ICA policy. Quite the contrary! The FAA has been actively engaged with international partners like EASA in an effort to develop internationally harmonized ICA policies that will help guide a larger swath of the aviation community.
One of the issues on the FAA’s plate is Component Maintenance Manuals (CMMs). Many aircraft components are produced under FAA design and production approvals, and as such are subject to the ICA regulations. For example, when a supplier to a type certificate holder chooses to sell their component directly to the aftermarket, the supplier must either obtain independent production authority (like a TSOA or PMA) or obtain direct ship authorization from the type certificate holder. Where the component is produced under independent production authority, the producer usually has independent ICA obligations under current regulations, and has an independent obligation to make those ICAs available. But some aircraft components are
produced and sold only to the type certificate holder, and as a consequence the producer has no independent ICA obligations under current regulations. If the
Some aircraft components are produced and sold only to the type certificate holder, and as a consequence the producer has no independent ICA obligations under current regulations.
producer creates their own CMM, then there is a question about whether the CMM is required to be provided to the marketplace. Under existing FAA policy, CMMs that are incorporated into ICAs become part of the ICAs and as such are required to be made
available just like ICAs, but CMMs that are not incorporated by reference into the ICAs would not subject to the regulations requiring ICAs to be made available. The FAA is considering policy guidance that will better explain when a CMM is considered to be incorporated into ICAs, and how and when a CMM user can avail themselves of their right to the availability of those CMMs. The FAA is also discussing broader ICA theory with their international partners, and has established working groups to examine issues like better standards for determining whether ICAs are complete, and better ways for the world’s regulatory authorities to share information and approval data concerning ICAs. AM
Aviation Maintenance |
avm-mag.com | June/ July 2012 57
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