MOC VTOL.2625 Instructions for Continued Airworthiness

MOC VTOL.2625 Instructions for Continued Airworthiness

1.      General

The holders of type certificates are responsible for ensuring that there is sufficient and accurate information in the ICA and that they are delivered in a timely manner to maintain the continued airworthiness of the product. ICA is one of the key elements to keep the product airworthy.

ICA provide documentation of necessary methods, inspections, processes, and procedures.

This Means of Compliance (MOC) provides a set of general guidance that, when used in their entirety, are accepted to ensure adequate preparation of Instructions for Continued Airworthiness (ICA).

CS 27.1529 Amdt. 6 and referenced CS-27 Appendix A is accepted as means of compliance together with additional associated guidelines given in FAA AC 27-1B Change 7 Appendix A and complemented by those elaborated below.

In regard to FAA AC 27-1B Change 7 Appendix A chapter 4 “Airworthiness Limitation Section” paragraph 1.(a)(2) the regulatory reference (i.e. CS 27.571) should read VTOL.2240(a).

2.      List of abbreviations

3.      Format and content

ICA can be published in documents or in a manner that is outside the traditional understanding of a document, for example, as a series of web pages, or in a publishing format linked to tasks or data modules rather than pages. The data containing the instructions is itself the ICA, not any particular type of publication.

Adapted to the VTOL requirements, applicants may apply the latest ATA or ASD standards (e.g. ATA iSpec 2200 or ASD S1000D), which are recommended to be used by EASA for a clear structure. Basic manuals are defined by using those standards. However, manufacturers may arrange differently the range of manuals and their content.

There is no requirement for any specific format or arrangement of the manual or manuals. However, the specific arrangement and format chosen by the applicant should be used in a uniform manner.

The ICA content should be provided in English (Simplified Technical English, as e.g. in accordance with ASD Specification ASD-STE100). If manuals are produced in different languages, master copies in English should be provided to the Agency.

4.      Timely availability of ICA

The EASA Certification Memorandum CM-ICA-001 “Completeness and timely availability of Instructions for Continued Airworthiness” provides guidance on the completeness and timely furnishing of ICA to the operator/owner and any other person required to comply with any of those instructions. This CM is deemed applicable to VTOL capable aircraft as well.

From 18 May 2022 (c.f. Art. 3 Regulation (EU) 2021/699) Point 21.A.7 of Annex I to Regulation 748/2012, along with the associated AMC1 21.A.7(c), will become applicable to cover this aspect of timely availability of ICA.

5.      ICA Provided by Suppliers for an appliance

The ICA for the VTOL capable aircraft should include the information essential to the VTOL capable aircraft’s continued airworthiness. When parts of the ICA are produced by a supplier, there should be clear agreements between TCH and suppliers established to ensure the availability of the relevant ICA.

Certain information from the suppliers and their interfaces should be considered ICA.

Either this information is directly integrated in the TCH VTOL capable aircraft-, Lift/thrust unit- or ETSO-“top-level” ICA, if applicable in accordance with the technical standard applied, or it is provided in the supplier documentation (as for example Component Maintenance Manuals (CMM), Vendor Service Bulletins (VSB)).

The supplier documentation which is integrated in the “top-level” ICA of the TCH, or is referenced in there, is considered part of the complete ICA package.

If “top-level” ICA contains “discard” or “remove and replace” instructions for certain components (including system testing and other instructions ensuring that the product will be put in an airworthy state by such replacement), and do not refer to supplier documentation for necessary airworthiness actions, then the VTOL capable aircraft airworthiness is maintained by discard/replacement action, and the supplier documentation is not part of the ICA.

6.      Multiple Manuals

It is not the intent of the Agency to enforce a specific selection/range of manuals, names and their abbreviations, apart from manuals/sections, which are referenced in requirements, like the “Airworthiness Limitations” in VTOL.2625(c). The selection of manuals, names and their abbreviations used in this MOC should be considered as examples only.

In case of segregation of information dedicated to a specific subject from a principal manual (like the Aircraft Maintenance Manual (AMM) or Standard Practices Manual (SPM)) into a separate manual, e.g. “Cable Fabrication Manual”, “Duct Repair Manual” or “Instrument Display Manual”, these manuals are considered as ICA. On the other hand, certain information dedicated to a specific subject may be integrated in a principal manual (as e.g. trouble-shooting information as part of the Aircraft Maintenance Manual (AMM) instead of a separate Trouble Shooting Manual (TSM)).

When reviewing the different requirements of CS-27 Appendix A, it should be noted that in the majority of the cases there is more than just one manual produced to provide the required information. To facilitate the compliance finding an applicant should provide an overview of the publications and manuals produced.

In this context, it should be clearly defined which manual is intended to be the “principal manual”.

7.      Service Documentation, Information

The TCH can use their customer service documents as a method of making changes to ICA available and to deliver them in a timely manner. Typical publications could include, Alert Service Bulletin, Inspection Service Bulletin, Service Bulletin, Service Information Letter, etc.

An applicant should demonstrate which of its service documents may be used as ICA or may be used as a means of communication to provide information to the operator other than ICA.

These documents do not replace publications required for EASA type certification needing approval, such as the Airworthiness Limitations Section (ALS).

8.      Electronic Media

Some applicants provide their documentation in an electronic format, e.g. CDs, internet, etc.. Manuals may be provided in such an electronic format instead of paper copies. Eventually, in integrating and cross-linking documentation into a common database, a classical manual structure (e.g. in accordance with previous ATA 100 standard), a set of manuals like AMM, WDM, TSM…, may be not visible. Therefore, an integrated documentation provided in a database may increase the difficulty to identify ICA related information. Nevertheless, the applicant should demonstrate which of its elements are required as ICA.

Within the EASA Part-21 (Regulation 748/2012) and CS-27 (and other documents), the term “manual” is used. For an integrated documentation provided in a database, the applicant should define and clarify the composition of documentation data for equivalent visibility as to a classical manual structure.

In the context of data base management, aspects like the production of data, its validation and verification, data submission, traceability of updates, data security and relevant operational requirements should be defined and explained by the applicant.