ARSA: EASA Proposal Abdicates Government Responsibility

ARSA applauds EASA’s efforts to provide better access to maintenance data, but says it does not go far enough to address disconnect between the design and maintenance rules.

Printed headline: Design Disconnect


The European Aviation Safety Agency (EASA) recently solicited industry feedback on a notice of proposed amendment (NPA) to clarify regulatory requirements surrounding instructions for continued airworthiness (ICA). Industry advocates at the Aeronautical Repair Station Association (ARSA) say that while they applaud the agency’s effort to provide better access to maintenance data, the proposal does not go far enough to address the long-standing disconnect between the design and maintenance rules.

Since an initial EASA tasking was issued in 2009, the agency and ancillary groups have worked toward establishing clear requirements and responsibilities for all parties involved in the production and implementation of ICA. The activities culminated in the NPA, which recommends a regulatory revision that would make ICA part of the design approval holder’s (DAH) type certificate. The intent is to standardize the manner in which ICA are identified, approved, formatted and made available to end users.


ARSA contends that the proposal gives the DAH too much leeway to determine what should be included in the ICA. It asserts that if the DAH uses remove-and-replace instructions in the ICA, eliminates certain repairs from component maintenance manuals, imposes source approval requirements or directs that the article be returned to it for maintenance, the data would effectively be made unavailable even under the new proposal. ARSA also points out that the proposal does not deter the DAH from charging exorbitant fees for the data.

In its comments, ARSA recommended language that would allow a DAH to charge “reasonable fees” and impose certain restrictions such as nondisclosure agreements, while providing a safety valve for organizations to submit restrictive-practice complaints to EASA for investigation and resolution. “Left unchecked, the component manufacturers will eventually perform all the maintenance on their articles, and the government-imposed monopoly represented by a design approval will be perpetuated,” ARSA concludes.

EASA has said it will utilize industry feedback to develop an opinion submission to the European Commission, which will ultimately prepare the final regulation. Rulemaking is anticipated next year. 

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