GM2 21.A.7(a) Determination of which supplier data is part of the ICA
CAA ORS9 Decision No. 48
Note 1: For the purpose of this GM, the term ‘supplier data’ also applies to similar types of data when issued directly by the DAH (e.g. component maintenance manuals issued by the DAH).
Note 2: For the purpose of this GM, the term ‘supplier data’ has to be understood as data coming from the supplier and related to either a full CMM or to part of a CMM.
Note 3: The link between the aircraft ICA and the engine/propeller CMM, as detailed below, is similar to the link between engine/propeller ICA and the CMM of equipment fitted to the engine/propeller.
Note 4: If the supplier is also the DAH (for instance, an engine or propeller manufacturer), then the ICA for these items will be made available by virtue of the DAH obligations as type-certificate holder (TCH) and need not be included in the aircraft ICA.
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When determining whether supplier data is part of the ICA, the following should be considered:
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Supplier data related to the Airworthiness Limitations Section (ALS) of the ICA is part of the ICA. A typical CS-25 example is critical design configuration control limitation (CDCCL) items that are included in CMMs.
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Supplier data related to instructions on how to accomplish the scheduled maintenance part of the aircraft ICA (such as MRBR) are part of the aircraft ICA. A typical case is the periodical removal of a component to perform a workshop task.
Example: Escape slide removal for restoration in accordance with the supplier data instructions.
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Supplier data related to scheduled maintenance on the component should be endorsed by the DAH before becoming part of the aircraft ICA, to define and confirm that the supplier data is applicable and effective.
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If the ICA are defined at aircraft level, the following principles apply to the other supplier data that is not related to the ALS nor to scheduled maintenance:
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If the supplier data includes a maintenance instruction for an action identified in the aircraft-level ICA, including an engine or propeller, this supplier data should be referenced in the aircraft-level ICA and should be made available like any other ICA.
As an alternative to linking such supplier data to the aircraft-level ICA (e.g. with cross references), it is possible to include the relevant data directly into the aircraft ICA. In such a case, the supplier data is not part of the aircraft ICA since the aircraft ICA already contain all the required information.
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If an aircraft ICA task only requires a replacement task for an engine, propeller, part or appliance (i.e. ‘remove and replace’ or ‘discard’) and does not refer to the supplier data for further maintenance of the removed engine, propeller, part or appliance, this means that the aircraft airworthiness may only be maintained by replacement action, and that the supplier data is not part of the ICA for the aircraft. In such cases, the supplier data does not need to be referenced in the aircraft ICA.
Example: If supplier data provides off-aircraft maintenance instructions for an engine, propeller, or other article (i.e. workshop maintenance), then this data may not be considered as part of the complete set of ICA for the aircraft, but may be considered as part of the complete set of ICA for the engine or propeller. However, the procedure for removal from / installation on the aircraft is necessarily part of the aircraft ICA.
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However, for the above cases, aircraft-level ICA can provide, as additional or optional maintenance information, the references to the supplier data even if it is not considered part of the ICA. In such cases, it should be made clear that the supplier data references are provided as additional or optional maintenance information and is not part of the product ICA. Besides, it should be ensured that the use of additional or optional maintenance information not considered as ICA but referenced together with the ICA will not compromise the continued airworthiness of the product or article.
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For the supplier data identified as part of the ICA, the DAH should:
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identify the supplier data that is part of the ICA; this can be achieved either by creating a listing or by any other acceptable means that allow to identify which data is part of the ICA and which data is not part of the ICA (refer to AMC1 21.A.7(b));
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just as for any other ICA, ensure the publication of the supplier data;
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ensure the accuracy and the adequacy of the technical content of the supplier data (refer to GM No. 1 to 21.A.239(a), point 3.1.5).
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