The Grand ICA Debate...

ARFlyer

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So I’ve found myself in a standoff between myself, my IA, and work over freaking ICAs.

I’m coming up on our annual and I’ve spent the last year or so redoing our MX logs into a online system for easier tracking and backup. The system allows for tracking of non standing things like ICAs and I don’t disagree with most of the ICA recommendations.

Few days ago, I was doing some research on Aspen Backup Batteries as the ICA says to replace it every four years. I strive to do proactive maintenance on my 172 as it’s cheaper in the long run. However, I was having trouble sourcing the battery so my IA said to just disregard the ICA until we can find it. I didn’t disagree as my understanding is that ICAs aren't required for Part 91 unless the ICA Airworthiness Limitation Section has something written beyond “No Changes”. The IA also said most IAs and owners never even know or care about the ICAs for the various STCs they have. So I’m in reality going way above and beyond anything most people do.

The next day I found myself in a meeting at work over ADS-B Transponder requirements and I made the comment that ICAs mean diddly squat to 91 guys unless, as I stated above, the ICA changes a limitation. You would have thought my boss, who is on the maintenance side, witnessed me throwing the Bible into a bonfire.

He said everything in ICA is mandatory and anyone found without the ICA complied with and documented in the logs deserves an enforcement and their aircraft grounded. I shot back that the ICA for my ADS-B transponder is not mandatory nor does it having anything beyond “on condition” language. Additionally 43.16 states that ONLY the Airworthiness Limitation Section applies so my ADSB ICA is a recommendation only.

So who do y’all think is right?

Also I can see what the GA community has to deal with sometimes because damn...
 
Your boss is incorrect. While ICAs and complying with them is a good idea, the only section that is binding is the airworthiness limitations section.

What I find that is the most annoying are the safety items that have limitations in their ICAs that cannot be easily complied with by the average mechanic/shop. All that does is get people to ignore what they should be doing or get people to remove the equipment.
 
So who do y’all think is right?
As indicated, you are correct. Only the ALS of any "ICA" is mandatory in the 91 world. But keep in mind ICAs are a relatively new requirement from the early 80s and for just posterity "maintenance manuals" have only been required since the 60s. So there are aircraft flying around with no ICAs at all.:eek:

FYI: there is a bunch of guidance out there on ICAs on purpose, requirements, etc. if you need it.
 
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