ICAs during Annual?

[BrettKS]

My mooney is in the shop for an annual currently. The mechanic has identified several ICAs, instructions for continuing airworthiness, that apply for the Avionics installed--GTN 750 and GTX 330. He has stated that these have to be checked during the annual and he cannot sign off on the plane being airworthy without having his avionics shop confirm these. This isn't something I've heard of before, declaring a plane not airworthy due to avionics issues like this.. Is this accurate?

[jaylw314]

For part 91 operators, ICA's are not mandatory.  If the service manual for the equipment has an Airworthiness Limitations section, that would be mandatory for everyone, but not ICA's.

Edit: To clarify, when the ICA's are performed is not mandatory for part 91.  AFAIK, if you did ask them to go ahead and perform such an inspection, they would have to follow the specific ICA instructions, though.

Edited August 7, 2019 by jaylw314

[BrettKS]

I didn't ask him to perform any kind of inspection on the Avionics. I am part 91. So imagine it should not be mandatory for me? If I follow what you're saying correctly.

[jaylw314]

Just now, BrettKS said:

I didn't ask him to perform any kind of inspection on the Avionics. I am part 91. So imagine it should not be mandatory for me? If I follow what you're saying correctly.

That is correct.  My understanding is that there is no legal requirement for an ICA to be followed during an annual for part 91.  That being said, knowing that may not stop your IA from believing it is necessary, and if he believes it is necessary he would have to inspect it in the way specified in the ICA

Obviously, if he wants to follow an ICA that involves major disassembly of components, you're going to want to insist that he stop the annual, sit down and discuss with you how to proceed.  Hopefully, a gentle reminder that you are a part 91 operator would be sufficient to remind him to back off.

There are other threads here discussing how to resolve disagreements and conflicts with IA's, so it's worth a read...

[hypertech]

Without conceding that this is necessary, what is it that he is wanting the avionics shop to do?

https://static.garmincdn.com/pumac/GTN625_STCGTN6XX_7XXandGMA35ICA.pdf

Just by google looked at this doc.  Seems to suggest a visual inspection of the equipment, wiring and antenna.  Can't he just do that and move on?

[kortopates]

I believe it is necessary but is mostly only a visual inspection to verify the security of the attaching screws as discussed in the ICA. But there are more checks less frequent than every annual. The reason for it being required is that the Airworthiness Limitations section of the Garmin Service manual is FAA approved data (see attached page) and regs per 43.16. 43.16 applies to all aircraft. Also I bet if you look at your 337 for it, it will also reference ICA's. The FAA started requiring ICA information on ANY 337 Form submitted in the late 90s. That ICA information becomes a permanent part of the aircraft's records. Specific avionics installs such as Garmin and others have ICAs contained in the installation manuals and/or flight manual supplements. 

Edited August 7, 2019 by kortopates

[EricJ]

I think the key point is that the Airworthiness Limitations sections for most stuff like this says what the above linked docs say, something like "There are no additional Airworthiness Limitations...that result from this modification."   In other words, you don't need to do anything special as a result of installing that equipment.   All of the stuff I've put in recently has been this way.

There's also a thing called "Certification Maintenance Requirements" that shows maintenance required as an operating limitation determined during Type Certification or STC.   My understanding is that CMRs are essentially the Airworthiness Limitations section in the manual or are, or can be, contained there.   The location of CMRs is supposed to be referenced in the TCDS or STC, although the only ones I've seen were pretty well hidden, i.e., you had to really be paying attention.

A lot of this stuff is really confusing or, at a minimum, non-obvious.   It's not that surprising to me that different IAs may have different ideas about whether or how to deal with them.

Edit:   The ICA shows the required maintenance, and my understanding is that even "life limited" parts aren't really life limited unless they appear in the ICA or the Airworthiness Limitations.    This was a noted source of confusion even for stuff that shows up in the TCDS as "life limited".   This stuff isn't straightforward it seems.

 

Edited August 7, 2019 by EricJ

[MB65E]

I’m kinda impressed he’s asking for the ICA’s 

Most don’t or forget. I’d stick with him!! Some time’s there are neat/important things that come up in the ICA’s. Most of the time it’s ultra basic required stuff for an STC to get approved. 

-Matt

[jaylw314]

6 minutes ago, MB65E said:

I’m kinda impressed he’s asking for the ICA’s 

Most don’t or forget. I’d stick with him!! Some time’s there are neat/important things that come up in the ICA’s. Most of the time it’s ultra basic required stuff for an STC to get approved. 

-Matt

I think the part that gets him (and me) is that he is claiming to have to have the ICA's complied with by the avionics shop.  Imagine how that would sound if your IA demanded this and he did not happen to have an avionics shop on site?  What's he going to do, pull the equipment and send it out every year claiming that is required?

[Prior owner]

Here’s a link (below) to a discussion regarding ICA compliance at annual for a part 91 operator. It’s an old thread, but Bob Pasch is correct, I believe.

It is my understanding that compliance with all ICA’s is necessary at annual inspection, regardless of which part you operate under. That said, I can think of only one reason why an IA would refer you to an avionics shop- because the ICA requires the use of special equipment to comply with it. Read the ICA in its entirety to determine what equipment you would need.

As an example- an IA can perform an annual inspection on an altimeter, even though he is not authorized to open it or perform any maintenance on it- Why could he not perform an annual inspection on avionics (provided he has the equipment necessary to complete the ICA)? He performs annual inspections on old Narco and King NavCom radios all the time...whether he realizes it or not!

Compliance with ICA’s

Edited August 8, 2019 by PilotCoyote

[bradp]

I would 1) get educated.  All your Garmin equipment has ICAs and airworthiness limitations in the STC documentation and you can download the information easily for virtually all Garmin equipment.  It should also kind of be available to you with your POH supplements. Most all your equipment says do nothing and or like a G5 make sure the battery hits 80% or greater charge or somesuch 2) ask the IA to either do it himself as part of the annual inspection cost or back off on it.  What’s he expect you to do... ferry it over to an avionics shop during annual and then have him complete the logbook entry?   Is he going to go there with you to the shop?  I have zero references to ICAs in my 42 years of logbook entries.   I don’t ask if the IA includes that as part of his inspection.   

My spidey sense says you’ll be looking for a new shop next year. The pessimist in me says he has a favored avionics shop at >100/hr that he will direct you to. 

Example here’s my transponder.  Check grounding / bonding every 10 years.  Visually inspect every year. It says you need a biennial transponder check just like everyone else  

Even better this is the same ICA for your transponder.

 

Here’s the ICA for a GTN 750.  Composite  Mooneys don’t exist.  So visually inspect every 12 months unless you got struck by lightning.  

 

My new conclusion is your IA is either a ninny, doesn’t know what he’s taking about, or is trying to take advantage of you.  Either way I’d get out of there. 

If it gets awkward just placard the things INOP and tell him to buzz off. 

[EricJ]

1 hour ago, PilotCoyote said:

Here’s a link (below) to a discussion regarding ICA compliance at annual for a part 91 operator. It’s an old thread, but Bob Pasch is correct, I believe.

It is my understanding that compliance with all ICA’s is necessary at annual inspection, regardless of which part you operate under. That said, I can think of only one reason why an IA would refer you to an avionics shop- because the ICA requires the use of special equipment to comply with it. Read the ICA in its entirety to determine what equipment you would need.

As an example- an IA can perform an annual inspection on an altimeter, even though he is not authorized to open it or perform any maintenance on it- Why could he not perform an annual inspection on avionics (provided he has the equipment necessary to complete the ICA)? He performs annual inspections on old Narco and King NavCom radios all the time...whether he realizes it or not!

Compliance with ICA’s

That's an interesting exchange, for sure.

A couple observations:   I've not seen anything that clarifies that ICA checks must be done as part of an annual inspection.  I can certainly see that ICAs could and probably should be used if they exist for the items covered by the inspection list used by the IA, but if an item isn't on the inspection list how does the ICA affect the annual?   Also, my understanding is that IA's are not supposed to delegate any part of the inspection; they are responsible for doing the inspecting and determination of condition.   So in the case in point how can the IA send something to another shop for determination of status relevant to the annual inspection?   If the GTN isn't on the MEL or required equipment does it need to be part of the annual?   I don't think my IA touches my IFD at all and only touches the comm radio and audio panel to check the ELT.

[Prior owner]

The ICA becomes part of the “inspection list” by virtue of the fact that it was stated  in the 337 form filed with the FAA- it is part of the FAA approved Supplemental Type Certificate, which is now part of the airplane. You modified your plane to the extent that it doesn’t technically meet the TCDS anymore- hence the need for an STC. Mooney doesn’t have anything to do with these STC’s, and so has no duty to create a new inspection list, and There are too many STC’s out there for the FAA to create different inspection lists under part 43, so you must follow The manufacture’s FAA approved inspection criteria in the STC in order for the equipment installed under the STC to remain airworthy. An ICA is not the same thing as a service bulletin, which may be disregarded if you are under part 91.

The fact that many IA’s don’t bother with ICA’s is no indication as to whether or not ICA compliance is required under part 91.... it is indicative of somethIng else.

As stated above by another, ICA’s are usually simple to perform and sometimes very necessary, like testing the backup battery in a G5- a perfect example of an ICA that isn’t on any inspection list, but that will be critical to safety of flight if the aircraft is operated IMC.

 

 

 

Edited August 8, 2019 by PilotCoyote

[MB65E]

Great older fourm by Bob!! ICA’s are required. But, The ICA is just a part of the language that is used for the STC. Changing standby batteries, checking for current versions of software,  It’s a long winded versions and checks of everything that’s probably already been looked at. So it’s not really an issue to comply with the items. As an IA I can not do a 91.411/.413 Check, but it’s also not part of an annual inspection so I’m not really delegating that inspection. The Garmin “ periodic maintenance” schedule lists the checks not ICA, is there a separate listing of the ICA, or is that all it says? 

 

It’s all probably part of some paper reduction act too. ;-)

Some may think the more paperwork we do, the less flying we are capable of, therefore doing paperwork makes us safer, because we are not flying. 

-Matt

[EricJ]

8 hours ago, PilotCoyote said:

The ICA becomes part of the “inspection list” by virtue of the fact that it was stated  in the 337 form filed with the FAA- it is part of the FAA approved Supplemental Type Certificate, which is now part of the airplane. You modified your plane to the extent that it doesn’t technically meet the TCDS anymore- hence the need for an STC. Mooney doesn’t have anything to do with these STC’s, and so has no duty to create a new inspection list, and There are too many STC’s out there for the FAA to create different inspection lists under part 43, so you must follow The manufacture’s FAA approved inspection criteria in the STC in order for the equipment installed under the STC to remain airworthy. An ICA is not the same thing as a service bulletin, which may be disregarded if you are under part 91.

An IA is required to use "a list" to do an annual inspection, that must include, at minimum, the items in Part 43 Appendix D.   It is not required to use Mooney's, or anybody else's, list.   App D doesn't say anything about ICAs or 337s.   Inspecting the sun visors does not appear to be required even if they have a 337 filed for the aircraft from when they were installed.

8 hours ago, MB65E said:

Great older fourm by Bob!! ICA’s are required. But, The ICA is just a part of the language that is used for the STC. Changing standby batteries, checking for current versions of software,  It’s a long winded versions and checks of everything that’s probably already been looked at. So it’s not really an issue to comply with the items. As an IA I can not do a 91.411/.413 Check, but it’s also not part of an annual inspection so I’m not really delegating that inspection. The Garmin “ periodic maintenance” schedule lists the checks not ICA, is there a separate listing of the ICA, or is that all it says? 

The link that hypertech posted above goes to the ICA for the GTN, which includes a "Maintenance Intervals" table in the ICA section similar to what bradp posted above.   Most of the items are "On condition" but there are also entries for "12 calendar months", "24 calendar months", after a lightning strike, and after 2000 hours or ten years.   I'm guessing it is the owner's responsibility to make sure those get done, since they're not really part of an annual?

Most of the non-visual stuff isn't anything an avionics shop could do remotely, anyway, since it includes things like inspecting the antenna cable braids, the bonding for the rack, etc.

 

[Prior owner]

Appendix D to Part 43

(i) Each person performing an annual or 100-hour inspection shall inspect (where applicable) the following components of the radio group: 

(1) Radio and electronic equipment - for improper installation and insecure mounting. 

(2) Wiring and conduits - for improper routing, insecure mounting, and obvious defects. 

(3) Bonding and shielding - for improper installation and poor condition. 

(4) Antenna including trailing antenna - for poor condition, insecure mounting, and improper operation.

(j) Each person performing an annual or 100-hour inspection shall inspect (where applicable) each installed miscellaneous item that is not otherwise covered by this listing for improper installation and improper operation.

———————

Maybe we need to define the term “where applicable” in paragraph (j)......?

I think that the question that must be answered with a straight face is: “How do you fully meet the requirement to inspect for “improper installation” and “improper operation”, without referring to the manufacturer’s approved data ?” If you don’t refer to it, then you are just drawing from whatever data you can recall from your own memory and experiences. To rely entirely upon your own memory or the basic list in Appendix D to determine the airworthiness of all components in a modified aircraft, seems unwise.

I never said that an IA must use a list from Mooney to conduct an annual inspection-  I was simply stating that one cannot use a list from Mooney for 100 hour/annual inspections and hope to cover inspections of equipment installed after the aircraft was certified.

 

 

[jaylw314]

Mike Busch addressed this issue of ICA's and SB's vs Airworthiness Limitations and AD's in one of his webinars, but I can't look up YouTube right now.  Anyone have that link?

To paraphrase what he was saying, the IA at annual has two requirements for declaring an aircraft "airworthy" 

1. The aircraft is in a condition that meets his subjective definition of "airworthy"
2. The aircraft meets the objective specifications listed in its type certificates (TCDS and STC's), AD's and AL's

Time-based requirements listed in MM, SI's, SB's and ICA's are not required for part 91

Again, I'm not saying that the IA should not be inspecting the items in an ICA as part of the annual, and I agree the items of inspection in the ICA could certainly be required to meet #1.  But AFAIK it is never required to meet #2.

So my beef would be with an IA telling me he needs to comply with the ICA's because they are required by regulation.  I believe that is incorrect, just like it is not required to log that you complied with any ICA.  OTOH, if he told me he will proceed with complying with the ICA's because they are consistent with assuring himself the aircraft is in airworthy condition (or in simpler language), I would probably be fine with that (and probably respect his thoroughness).

My other beef is with his statement that he needs the avionics shop to confirm compliance with ICA's.  If he said he needed to have a quick consultation with his avionics guy, that would be ok, and I might even be ok with paying for it if there was a complication.  But to say an avionic shop is somehow required to rubber stamp an annual is flat out wrong.

Edited August 8, 2019 by jaylw314

[BrettKS]

Great discussion, appears it is a grey area depending on why he is requiring the ICAs.

I get the feeling I'm being squeezed for money from this place, and that's why I ask. There are many ICAs beyond the avionics that are being billed at about a half hour per check. One for alternator, one for brackett air filter, and a few other misc items. He referred me to the avionics shop he is affiliated with who estimated a half hour (at 100/hr) to do the ICA for the GTN, which is only a visual inspection. Also a half hour to "check for compliance" of the GTX transponder AD back in 2005 for a software update. Clearly it doesn't apply because I have documentation that it was installed in 2014. And the fact that he's saying an avionics shop needs to confirm that seems silly, because simply turning on the transponder would reveal that the version makes the AD not applicable.

Everyone raves about these Mooney Service Centers being the way to go.. but maybe they aren't all of the same caliber. My annual estimate was nearly $8.5k--with no major engine work needing done. Just high labor rates and times quoted (Half hour to replace O rings?). And is checking for tubular corrosion typically billed separately? $250 charge for something that seems it should be part of the annual inspection rate..

[hypertech]

The bare annual should not cost $8500 but I hear its not unusual for an MSC to find enough stuff that needs fixing to get to $8500 especially if its the first time they've seen the plane.  The referral to the avionics shop seems a little funny, but if its only a half hour and they are next door, seems like you'd be paying them a half hour instead of the mechanic a half hour so what's the difference.

All those things may need to be done - the question in my mind would be if you already paid a flat rate for an annual that should include that and you are getting charged on top or if they are just giving you line item detail into what is done at the annual that you normally don't see.

 

[Prior owner]

As far as your historical Record of Compliance with AD’s - was your entire AD compliance history contained in list form for the airframe, engine, prop, accessories? If he had to read through individual logbook entries to total up the AD compliance history, that could take some time $$. 

 

[jaylw314]

My first annual I had done at an MSC, and they are known locally as being pretty expensive.  That annual was about $3400, with about two-thirds of that being their flat-rate annual fee, and the rest being a bunch of little squawks.  Yes, they charged a minimum of 0.5 hours for some little items, but it wasn't like they came up with 50 of them--I think there were only 3-4 items at 0.5 hours.

If you paid a flat-fee for the annual inspection, getting charged for additional "inspection" items is BS, unless you have a highly unusual aircraft or modifications.

[BrettKS]

1 minute ago, jaylw314 said:

My first annual I had done at an MSC, and they are known locally as being pretty expensive.  That annual was about $3400, with about two-thirds of that being their flat-rate annual fee, and the rest being a bunch of little squawks.  Yes, they charged a minimum of 0.5 hours for some little items, but it wasn't like they came up with 50 of them--I think there were only 3-4 items at 0.5 hours.

If you paid a flat-fee for the annual inspection, getting charged for additional "inspection" items is BS, unless you have a highly unusual aircraft or modifications.

Yes, line items were on top of an $1800 flat fee.

[philiplane]

When an airplane is altered by installation of an STC'd product, the STC may contain Instructions for Continued Airworthiness. If it does, they are mandatory if they are listed in Chapter 4, Airworthiness Limitations. 

Field Approvals may also contain ICA's, and they would also be mandatory, if they have a Chapter 4 limitation.

Because ICA's contain work instructions, work performed requires a log entry under part 43.9. A compliance statement would be required in the annual inspection entry, referencing the applicable ICA's. 

Where this gets sticky is when something fails, and the pilot or their survivors go to court. If the mechanic ignored those ICA's, he is going to be sued and lose. You will see some shops list everything under the sun, and have the owner decline them and sign for the deferrals. That protects the shop from future litigation.

A flat fee annual normally covers only the original configuration airplane. If you have a highly modified plane, there will be extra inspection & maintenance items associated with the mods, and those are rightfully billed separately, once the shop confirms what has to be done. That would be after the initial inspection, where they were using the Mooney specific checklist. 

Edited August 8, 2019 by philiplane

[jaylw314]

14 minutes ago, philiplane said:

When an airplane is altered by installation of an STC'd product, the STC may contain Instructions for Continued Airworthiness. If it does, they are mandatory. 

Field Approvals may also contain ICA's, and they would also be mandatory.

Because ICA's contain work instructions, work performed requires a log entry under part 43.9. A compliance statement would be required in the annual inspection entry, referencing the applicable ICA's. 

A flat fee annual normally covers only the original configuration airplane. If you have a highly modified plane, there will be extra inspection & maintenance items associated with the mods, and those are rightfully billed separately, once the shop confirms what has to be done. That would be after the initial inspection, where they were using the Mooney specific checklist. 

OK, here's the article version of the presentation I was thinking of:

https://www.savvyaviation.com/wp-content/uploads/articles_eaa/EAA_2011-12_intervals.pdf

from the article:

"The general rule is that Part 91 (noncommercial) operators are never required to comply with such manufacturer specified intervals (when-to’s) simply because there is no regulation in the FARs requiring them to do so. There are two— and only two—exceptions to this general rule: If such intervals are mandated by an FAA airworthiness directive (AD) or if they are set forth in an FAA-approved airworthiness limitations section (ALS) of the manufacturer’s MM or ICA, then compliance is required by regulation. Otherwise, it isn’t. The regulatory reference that covers these two exceptions is FAR 91.403...

§ 91.403 GENERAL.

(a) The owner … of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with Part 39 of this chapter [Airworthiness Directives].
(c) No person may operate an aircraft for which a manufacturer’s maintenance manual or instructions for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section … have been complied with."  (my emphasis added)

In other words, the only things required by regulation are the items in the Airworthiness Limitations section of an ICA, which is not common and does not apply to the Garmin ICA above.

[bradp]

So the service intervals for garmin are not part of the Airworthiness Limitations section.

Counter this to the dumb AD about the Trig based transpoders needing to be checked for panel orientation.