Maintenance and Manufacturing Staff Instructions, MSI 53
|Review of Supplemental Instructions for Continued Airworthiness||Revision No:||2|
|Number of Pages:||49|
|File No: AARP-5009-3-53||Issue Date:||January 6, 2006|
This MSI outlines procedures to be used when determining the acceptability of supplemental Instructions for Continued Airworthiness (ICA) submitted in support of a change to a type design, and provides sample Statement of Compliance Check Sheets for use by persons seeking approval for such a change.
The responsible office indicated below may be contacted for information regarding the functional direction being provided through this Maintenance Staff Instruction:
Superintendent, Aircraft Evaluation (AARPG)
Aircraft Maintenance &Manufacturing
Phone: (613) 990-1069
Facsimile: (613) 952-3298
Aircraft Evaluation email address: (AircraftEvaluationAARPG@tc.gc.ca)
Director, Maintenance and Manufacturing
Director, Aircraft Certification
Table of Contents
- Responsibility for Review of Proposed Supplemental ICA
- Statement of Compliance
- Review Procedure
- Format and Contents of Supplemental ICA:
- Knowledge requirements
APPENDIX A-1 NORMAL, UTILITY, AEROBATIC AND COMMUTER CATEGORY AEROPLANES – CAR 523
APPENDIX A-2 TRANSPORT CATEGORY AIRCRAFT – CAR 525.
APPENDIX A-3 NORMAL CATEGORY ROTORCRAFT – CAR 527
APPENDIX A-4 TRANSPORT CATEGORY ROTORCRAFT – CAR 529………....29
APPENDIX A-5 MANNED FREE BALLOONS – CAR 531
APPENDIX A-6 AIRCRAFT ENGINES – CAR 533
APPENDIX A-7 PROPELLERS – CAR 535
APPENDIX B - SAMPLE MANUAL CONTENT DESCRIPTIONS
B1. Aeroplane / rotorcraft manual.
B2. Balloon manual.
B3. Engine maintenance manual.
B4. Engine overhaul manual.
B5. Propeller maintenance manual.
B6. Propeller overhaul manual.
B7. System wiring diagram.
B8. Component overhaul / maintenance manuals.
B9. Non-Destructive Testing and Inspection manual or section
B10. Maintenance Review Board (MRB) Report (Transport Category Aircraft).
For the purpose of this MSI:
2.1 “Installation Instructions” means those instructions necessary for the installer to incorporate a design change into an aeronautical product, including instructions necessary to determine conformity of the change, as installed, with its design.
Note: Initial installation instructions are not part of the ICA. Similarly, Aircraft Flight Manuals and other documents that relate solely to the operation of the aircraft are not included in the ICA.
2.2 “Instructions for Continued Airworthiness” (ICA) means all instructions published by the holder of the design approval for an aeronautical product that relate to the inspection, testing, repair, removal and replacement of that product.
Note: ICA include maintenance manuals and equivalent documents that were published before the term “instructions for continuing airworthiness” first came into use in 1981.
2.3 “Reviewer” means any person who evaluates Supplemental ICA to determine their acceptability to the Minister.
2.4 “Supplemental ICA” means additions or amendments to ICA to address changes to the type design of an aeronautical product. Supplemental ICA complement and in some cases supersede the equivalent sections of the original ICA for the product concerned.
3.1 The basic requirements for ICA and for supplemental ICA are contained within the regulatory standard applicable to the product concerned. The applicable standards of airworthiness for a particular design change are determined in accordance with CAR 513.07. These may be the standards that are in force on the date of application, or an earlier amendment of those standards where the Minister finds this appropriate. The general format and presentation of Supplemental ICA should be compatible with the original ICA that they are intended to supplement.
3.2 The standard of compliance for ICA is that the instructions must be “acceptable to the Minister.” This implies a subjective judgment on the part of the Minister’s authorized representatives, so to enable standardization; the Minister has identified objective criteria to be used when reviewing supplemental ICA for acceptability. These criteria are contained in appendices to the various design standards. Some, but not all, of the currently applicable standards and appendices are listed below.
- Normal, Utility, Aerobatic &Commuter Category Aeroplanes: STDs 523.1529 &523 Appendix G
- Transport Category Aeroplanes: STDs 525.1529 &525 Appendix H
- Normal Category Rotorcraft: STDs 527.1529 &527 Appendix A
- Transport Category Rotorcraft: STDs 529.1529 &529 Appendix A
- Manned Free Balloons: STDs 531.82 &531 Appendix A
- Aircraft Engines: STDs 533.4 &533 Appendix A
- Aircraft Propellers: STDs 535.4 &535 Appendix A
The following references are intended to assist in determining adequacy of supplemental ICA:
- Canadian Aviation Regulations (CAR) 513 Approval of Modifications and Repair Designs. http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-subpart13-1772.htm
- Transport Canada Technical Publication: TP13850 Scheduled Maintenance Instruction Development Processes.
- Air Transport Association iSpec 2200, Information Standards for Aviation Maintenance ATA Distribution Center; PO Box 511; Annapolis Junction, MD 20701; Email: email@example.com; Tel: 800-497-3326; Fax: 301-206-9789
- General Aviation Manufacturers Association’s Specification No. 2, Maintenance Manual; 1400 K Street NW, Suite 801; Washington, D.C. 20005; Ph: (202) 393-1500; Fax: (202) 842-4063
- Aircraft Certification Staff Instruction (ACSI) Number 22: Approval of Domestic Design Changes: Issue Number 2; (2000-08-09); and Number 23: Acceptance and Approval of Foreign Design Changes: Issue Number 1; (2000-10-02)
- Aircraft Certification Advisory Circular (AC) 500-016 Issue 1 (2004-12-01; or later version): Establishing the Certification Basis of Changed Aeronautical Products
- Delegations Handbook: TP12995E: Issue 2: June 10, 2003
- Federal Aviation Administration – FAA Advisory Circular – AC 43.13-1A: Acceptable Methods, Techniques, and Practices – Change 3; Aircraft Inspection and Repair; AC 43.13-2A: Aircraft Alterations
- Federal Aviation Administration - FAA Advisory Circular - AC 25-19, Certification Maintenance Requirements
- Aging Transport Systems Rulemaking Advisory Committee, ATSRAC Web-Site: http://www.mitrecaasd.org/atsrac/ for wiring issues and resolutions
5.1 Proposed supplemental ICA are reviewed for acceptability as part of the compliance program for design change approval. Depending on the circumstances, design change approvals may be granted by appropriately delegated persons within Transport Canada, or in the aviation industry. Supplemental ICA are subject to the same requirements as the initial ICA, namely, they must either be complete and acceptable in accordance with this staff instruction at the time of issuance of the approval, or a satisfactory program must be in place to ensure their completion prior to operation. While the ICA must be reviewed and found acceptable in accordance with these procedures, it is not necessary for the reviewer to indicate acceptance on the ICA documents themselves.
5.2 Final responsibility for determining the acceptability of Supplemental ICA rests with the person issuing the approval for the design change on behalf of the Minister. He must ensure that only appropriately experienced persons who are familiar with the process carry out the review of the ICA for acceptability.
5.3 In the case of design changes being approved by Transport Canada HQ Certification Branch, the Aircraft Maintenance &Manufacturing Branch, Aircraft Evaluation Section (AARPG), will review the Supplemental ICA. The proposed Supplemental ICA, together with a copy of the design change documentation, the statement of compliance form completed by the applicant and the installation instructions for the design change must be provided to the reviewer early enough in the program to enable the review to be completed without undue delay to the eventual approval.
5.4 In the case of design changes being approved by a Transport Canada Regional Office, staff of either Aircraft Certification or Aircraft Maintenance &Manufacturing may conduct the ICA review, as mutually agreed by the respective Managers. This agreement may be general, or case-by-case. Regardless of who performs the review, it must be coordinated with the other aspect of the work to avoid undue delay in the final approval.
5.5 In the case of design changes being approved by external delegates whose terms of delegation include making findings against ICA requirements, the delegates may conduct the review themselves. Where the delegate’s terms of delegation do not include making findings against ICA requirements, they must submit the proposed supplemental ICA, together with a copy of the design change documentation, the applicant’s completed statement of compliance check sheet and the installation instructions, to the applicable project manager or senior engineer for evaluation in accordance with 5.4 above.
5.6 Where the original ICA include a Maintenance Review Board Report (MRBR) as a means of showing compliance with the scheduled maintenance requirements, the reviewer must forward a copy of the final supplemental ICA to the HQ Aircraft Evaluation Section (AARPG), to enable them to monitor consistency with the underlying logic of the original program.
6.1 The applicant must provide a written statement of compliance, similar to that shown in Appendix A to this MSI, prior to the evaluation of proposed supplemental ICA. Appendix A provides sample Compliance Check Sheets. These examples apply to design change approvals having Airworthiness Manual Chapters 523 through 535 (at the most recent amendment) as their certification basis. For design changes having another certification basis, appropriate check sheets will have to be developed by the applicant to reflect the equivalent requirements of the appropriate standard.
6.2 The design approval documentation must distinguish between Airworthiness Limitations, which are mandatory as a condition of type approval, and manufacturer’s recommendations, which are mandatory as a condition of operation. Proposed supplemental ICA shall be listed under the appropriate topic headings identified on the applicable sample compliance check sheets in Appendix A.
7.1 When assessing their design change for supplemental ICA, the applicant should first verify whether or not the existing ICA adequately support the change. If the existing ICA are found to be adequate, the applicant should make a statement to that effect on the compliance check sheet. This statement will be evaluated and confirmed by the reviewer. If the reviewer agrees that the existing ICA adequately support the change, an entry should be made in the design change approval documentation stating that the existing ICA support the design change and no additional ICA are required (see paragraph 7.4 following). If supplemental ICA are required, they must be identified on the ICA compliance check sheet, and listed within the approved section of the design change approval documentation.
7.2 The purpose of listing the supplemental ICA in the design change approval documentation is to ensure that persons incorporating the design change are aware of all Supplemental ICA, so that they can make the necessary amendments to the aircraft technical records. If no proposed supplemental ICA are required, it is equally important to provide positive confirmation of this.
7.3 It is not intended that supplemental ICA be developed unnecessarily. Many design changes may involve no supplemental ICA at all. This is particularly true of the scheduled maintenance section of the ICA. For example, the existing zonal program or general area inspection instructions may adequately cover many design changes. In such cases, a simple indication that the scheduled maintenance section of the original ICA are unaffected by the design change will suffice. However, the rest of the supplemental ICA covering the unscheduled maintenance aspects of the design change will still need to be considered separately.
7.4 If a design change does not affect any of the existing ICA, the applicant must submit an explanation of this decision. The assessment must show that the certification project will not affect any information, procedures, process requirements or limitations in the original ICA. The assessment should be appended to the Supplemental ICA Statement of Compliance Check Sheet, with Blocks 2 and 3 being identified as not applicable (N/A).
7.5 Appendix A to this MSI contains samples of ICA Statement of Compliance Check Sheets, corresponding to the standards listed in paragraph 3.2. A completed copy of the appropriate check sheet must be provided to the reviewer upon submission of the design change application. The checklists provided are at the current revision status at the time of publication of this MSI. If that is not the appropriate standard applicable to the design change, the applicant must either amend the check sheets as necessary, or develop new ones that reflect the applicable standard. The compliance check sheets are made up of five blocks. Blocks 2 &3 contain three columns.
- Block 1 identifies the applicant, and provides space for a description of the design change, identification of the certification basis (including revision amendment) for the change and an explanation of the applicant’s program for distribution and amendment of any supplemental ICA. Block 1 also has provision for the applicant to identify the Installation Instructions. A copy of the installation instructions must be provided to the reviewer at the time of submission of the design change.
- Blocks 2 and 3, column 1 identify the topic headings from the design standard, which must be used by the applicant to define the specific Supplemental ICA requirements applicable to the change. The difference between blocks 2 and 3 is that block 3 addresses airworthiness limitations.
- Blocks 2 and 3, column 2 provide space for the applicant to identify the specific ICA published by the design approval holder (DAH), which are applicable to the particular regulatory standard line item and topic identified in column 1. In many cases more than one manual in a set of ICA for an aeronautical product are required to support a particular line item.
- Blocks 2 and 3, column 3 are used by the applicant to identify the applicable supplemental ICA developed by the applicant, that are required to show compliance with the regulatory standard requirement in column 1, and which of necessity must be clearly identified and shown how they amend or alter the ICA of the DAH identified in column 2.
- Block 4 is used by the applicant to state that the supplemental ICA identified in accordance with paragraph (d) above constitutes their means of compliance with requirement to furnish ICA for the design change.
- Block 5 provides space for a statement and signature by the reviewer attesting that the existing ICA, the Supplemental ICA, or combination of both, as identified in paragraph (d) above are adequate to support the design change.
7.6 The applicant for a design change approval must provide information supporting the statement of compliance presented in paragraph 7.6 as follows: (refer to Appendix A for the appropriate check sheet)
- In Block 1, enter the applicant’s name, a detailed description of the design change, the certification basis, the certification basis revision, and a description of their program in accordance with how they will distribute and amend their supplemental ICA, and the identification of the installation instructions necessary to incorporate the design change in the aeronautical product by title and document number.
Note 1: The program for distribution and amendment of the supplemental ICA must be identified by document number or title and date and address. It must contain a commitment by the applicant to support distribution and amendment of the supplemental ICA for the entire time that the design change will be in operational service.
Note 2: This block must also clearly identify the installation instructions by title and document number as provided by the applicant for installing the design change.
- In Block 2, and 3, column 1, No entry required.
- In Block 2, and 3, column 2, identify the ICA documentation published by the holder of the original type design, which are applicable to the respective topic and line item heading in column 1.
Note: When referring to the original ICA documentation published by the design approval holder (DAH) the applicant must identify the relevant documentation by title and document number. This entails inserting new line items for each manual identified. For example if the original ICA comprised a maintenance manual, a wiring diagram manual, an illustrated parts catalogue, and a troubleshooting manual, each manual by title would need to be identified as separate sub-line entries within the context of the first line of block 2 under column 2.
- In Blocks 2 and 3, column 3, and where applicable on a line item by line item basis, the applicant will identify the supplemental ICA developed to show compliance with the respective topic of column 1 for each manual identified in column 2 for which it is necessary to have supplemental ICA provided. If no supplemental ICA are required for the respective line item topic in column 1 as applicable to each manual identified in column 2, enter “N/A.” If no supplemental ICA are required for a particular line item the applicant must provide an assessment of why those items do not require supplemental ICA.
- In Block 4, the applicant will sign and date the following statement of compliance:
“The Supplemental ICA referenced above comprise the complete listing of supplemental ICA necessary to show compliance with the applicable design standard.” The applicant will also provide their name, contact phone number and email address in this block.
7.7 The reviewer will:
- Verify all columns for completeness.
- Assess the applicant’s disposition of columns 2 and 3.
- Assess the referenced section(s) of the proposed supplemental ICA contained in the accompanying documentation for compliance with the requirements of the certification basis. The format of the proposed supplemental ICA should be compatible with that of the original ICA. The following section provides more detailed guidance on assessing Supplemental ICA for format and content.
Note: With reference to the design change, it is suggested that the reviewer read the initial installation instructions provided with the design change, in order to understand the extent of the modification and to establish a notion of the adequacy of the proposed Supplemental ICA.
- Assess the proposed distribution and amendment system for the supplemental ICA.
Note: The means of compliance with this requirement will vary with the nature of the approval. With STCs, the information on the certificate itself may suffice to identify the supplemental ICA, which could be contained in an attached data sheet. The program should address how the applicant will develop and maintain a distribution list of those who require the supplemental ICA. In addition the program must address how amendments to the supplemental ICA will be developed, accepted by TCCA and then distributed to those that require the supplemental ICA .
- Assess the applicant’s disposition of the compliance statement requirement in Block 4
7.8 If the review shows that the proposed ICA are acceptable to the Minister, the reviewer will ensure that the appropriate National Aeronautical Product Approval (NAPA) number is entered on the supplemental ICA statement of compliance check sheet in Block 5, sign, date and enter personal contact information in the form in Block 5, and include the completed form within the documentation for the design change.
Note: The signature confirms that the reviewer has found the reviewed supplemental ICA acceptable to the Minister.
7.9 In the event the proposed ICA are not acceptable, the reviewer will advise the applicant in general terms of the nature of the deficiencies and that no further processing of the supplemental ICA will be undertaken until the deficiencies are corrected. In addition the reviewer will place a copy of the advisement in the file pertaining to the particular design change and forward a copy to the attention of the Superintendent, Aircraft Evaluation, AARPG.
Supplemental ICA for each aircraft must include the following, as applicable to the design change:
- Supplemental ICA for each engine, propeller, and appliance required by the applicable airworthiness regulations that are affected by a design change,
- Supplemental ICA for all appliances or products installed on an aircraft not required by airworthiness regulations (otherwise known as owner options) that are affected by a design change
- Information required for the interface of appliances and products with the aircraft if the interface or those appliances or products is affected by the design change.
- If a component that is part of the design change is exceptionally complex (needing specialized maintenance techniques, test equipment, or expertise), the applicant may refer to the manufacturer of the component as the source of this information.
Note: The applicant must clearly cross-reference the component manufacturer’s instructions by part number, revision level and/or date of publication in their Supplemental ICA. When referenced, those instructions are incorporated by reference in the supplemental ICA and as such become part of the complete ICA for the aircraft within which the design change is embodied. These supplemental ICA must be provided to the owner by the applicant as required under CAR 513.31.
- Applicants must prepare supplemental ICA in a manual format that to the extent possible, and subject to the requirements of 513.07, is compatible with the format of the original ICA. If multiple manuals are required, there must be a principal manual, which identifies each of the supplemental manuals, with a list of effective pages and table of contents for each manual. The applicant signing the statement of compliance check sheet in Block 4 should also sign the supplemental ICA manual cover sheet. The principal manual is the manual that will be used for the day-to-day maintenance of the product.
Note: Supplemental ICA for a design change not only cover the items installed by the design change, but also those systems, parts, structure and areas of the aircraft affected by the change and the existing ICA pertaining to the affected areas. Unaffected areas need not be addressed. For example, if an STC installs a Global Positioning Satellite (GPS) system, supplemental ICA for the engine will not be affected. However, the submitted supplemental ICA must include all items potentially affected by the installation, even where no actual change is required. In the case of the GPS installation, that will include information necessary to maintain the GPS antenna and its installation.
- If the design change does not affect the existing ICA or maintenance documentation, the applicant can submit an assessmentshowing no need for supplemental ICA. The assessment must show that the design change does not alter any information, procedures, process, requirements or limitations as found in the current ICA.
The Supplemental Instructions for Continued Airworthiness must contain the required manuals including the sections and information as identified in the appropriate regulatory standard. The ICA should include as a minimum, instructions for all maintenance, elementary work and servicing requirements affected by the design change. The sample statement of compliance check-sheets in Appendix A, shows individual line items that must be identified for applicability with each application.
ICA must be specific to the product. Standard practice information or references to advisory material such as: “Refer to FAA Advisory Circular (AC) 43-13, Acceptable Methods, Techniques and Practices – Aircraft Inspection and Repair” may be acceptable for specific tasks, but are not acceptable as the “complete set” of ICA. The various manuals or sections that make up the complete ICA must include the following information:
- General description
This section must address the requirements of the applicable design standard. Introduction information should include an explanation of the design change features and data to the extent necessary for maintenance or preventive maintenance. In particular, the section should address the affect of the design change on the existing ICA.
The general description should include servicing information that covers details regarding servicing points, capacities of tanks, reservoirs, types of fluids to be used, pressures applicable to the various systems, location of access panels for inspection and servicing, locations of lubrication points, lubricants to be used, equipment required for servicing, towing instructions and limitations, mooring, jacking, and levelling information.
- Maintenance Instructions
For each part of the aircraft, balloon, engine and propeller, plus its components or appliances, this manual or section must include:
- Recommended times for cleaning, inspecting, testing, lubricating and adjusting, including the depth of inspection required, the wear tolerances and tasks performed;
- Location of access panels for inspection and servicing;
- Diagram of structural access plates and how to gain access when access plates are not provided;
- Replacement / overhaul schedule outlining the recommended times for removal, replacement or overhaul of specific parts. If the ICA include an overhaul requirement for a part, then they must also include appropriate instructions for performance of the overhaul;
- Primary structure identification and recommended inspection times and types, such as ultrasonic, eddy current and so forth;
- An inspection program with the frequency and extent of inspections to sustain continued airworthiness; and
- All data on structural fasteners, such as identification, discard recommendations and torque values.
- Airworthiness Limitations Section
For those design standards identified in 3.2 above, there must be a separate and distinguishable ICA section, called “Airworthiness Limitations.” If the supplemental ICA consist of multiple manuals, the applicant must include the limitations section in the principal manual of the supplemental ICA. The principal manual is the manual used for day-to-day maintenance of the aircraft, engine, or propeller, as opposed to overhaul manuals, component maintenance manuals, MRB reports or service bulletins. This section must contain a legible statement in a prominent location that reads: "The Airworthiness Limitations section is approved by the Minister, and lists any life limits or maintenance tasks that are mandatory as a condition of the type certificate." The applicants must record within the Airworthiness Limitations section any mandatory component replacement times, inspection times, Certification Maintenance Requirements (CMR) or other limitations specified as mandatory in the design change approval.
Note: While published in the ICA, Airworthiness Limitations do not arise directly out of the ICA development process, but are actually conditions of the design approval. Unlike the ICA in general, they are not recommendations, but mandatory requirements. Failure to comply with Airworthiness Limitations will invalidate the terms of the design approval and is a specific offence in its own right. Compliance with Airworthiness Limitations is considered critical, because failure to comply could result in catastrophic failure. Applicants typically identify potential Airworthiness Limitations as they assess the affect of their proposed changes on the structure and systems of the aeronautical product concerned. The Minister’s delegate approving the design change will make the final determination as to whether to make the approval conditional upon compliance with these items. Examples of items that would be considered for classification as airworthiness limitations in the case of changes to Transport Category Aeroplanes include structural inspections to show compliance with paragraphs STD 525.571 and fuel system requirements developed in accordance with STD 525.981.
Certification Maintenance Requirements (CMR) are required inspections or maintenance tasks that are part of the ICA and fall within the definition of Airworthiness Limitations. They are tasks performed at certain times to detect or correct safety significant latent failures (failures not known to the crew). These latent failures, combined with one or more other specific failures or events, can cause hazardous or catastrophic failures. CMR are identified within the type certification process and usually developed as an alternative means to meet compliance requirements when the actual design in its own right cannot meet the design requirements. See FAA Advisory Circular AC25-19, Certification Maintenance Requirements, for additional information.
9.1 Persons who are assigned responsibility for determining the acceptability of supplemental ICA should be familiar with:
- This Staff Instruction;
- The ICA review procedure;
- Supplemental ICA contents;
- Supplemental ICA arrangement in terms of practicality, manual(s), format, and subject matter, and
- Aeronautical product ICA developed and approved through the Maintenance Review Board process.
9.2 The Aircraft Evaluation section, (AARPG), provides training in the above subject areas. Persons interested in receiving training should contact the responsible officer above to arrange for this training.
10.1 Appendix A Statement of Compliance Check Sheet. (Includes samples of Statement of Compliance check sheets.
10.2 Appendix B Sample Manual Content Description. (Includes a representative content description of various manuals, which may be produced by the design approval holder as their means of complying with their respective ICA requirements.
10.3 Appendix C TCCA/FAA Supplemental ICA Liaison Procedure. (Includes procedures for TCCA and FAA to follow when reviewing supplemental ICA for products moving between the two countries.