Case of a company being the original equipment manufacturer (OEM) - so supplier for a Type Certificate Holder (TCH) - and having their own DOA. If we take the example of the Component Maintenance Manual (CMM), provided that the CMM is in that case considered as an ICA, could you clarify if the OEM DOA can or cannot make changes to the CMM using e.g. Part 21 / Subpart E?
Standalone changes to ICA: could it be clarified which are the expectations in terms of DOA’s involvement activities before release of the standalone changes to the ICA (review by compliance verification engineer, other Office of Airworthiness involvement, etc.)?
The applicability of 21.A.7 AMCs/GMs is not clear in the case of TCH without new production. Could you please clarify?
With reference to AMC2 21.A.7(a) point (d): ‘(d) If the maintenance data made available by a DAH includes data from an operator (i.e. in order to customise the data for the operator, and created under the authority of the operator), the operator’s data should be identified as such, and the DAH is not required to additionally evaluate it. Could you give an example for operators’ data included in ICA?
With reference to GM2 21.A.7(a) point (4): ‘(4) 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: (i) 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. […]’ What does it mean “In such case the supplier data is not part of the ICA, since the aircraft ICA already contain all the required information”? Is that avoiding duplication and potential disagreement?
With reference to GM2 21.A.7(a) point (4), what does it mean “In such case the supplier data is not part of the ICA, since the aircraft ICA already contain all the required information”? Is that avoiding duplication and potential disagreement?
What is the purpose of the point (a)(2)(vii) in the AMC1 21.A.7(c)?
With reference to AMC1 21.A.7(c) point a3 ix, does that mean EASA wants to see all ICA which are furnished (irrespective what option) at entry into service?
Can design approval holder's (DAH’s) SB or Vendor Service Bulletins (VSB) be ICA or is this limited to Manuals, like CMMs?
For scheduled tasks like restoration or functional check, which are performed off-aircraft, are the Aircraft Maintenance Manual “remove” and “install” instructions, as part of the ICA, enough?
With reference to GM1 21.A.90C Stand-alone changes "[...] When a non-ALS ICA change is triggered by a change to the type design, this does not affect the overall classification of the type certificate change as per point 21.A.91 […]." What is the purpose of this paragraph?
With reference to GM1 21.A.90C 'Also, when the ICA are completed after the product (or change to the product) was approved, this is considered to be a stand-alone change to the ICA.' Is this to be understood that non-ALS ICA provided at EIS (and even after EIS) should be handled as standalone?
Does point 21.A.90C(c) imply that we may encounter non-ALS changes which can be minor with/without additional work to demonstrate compliance and major? Should a TCH process start with the identification of the affected requirements, to determine, for non-ALS ICA changes, if they can take benefit of point 21.A.90C(c)?
With reference to GM1 21.A.90C, what is meant by the terminology “to provide alternatives”?
How does a Part 145 Maintenance Organisation know, if a Component Maintenance Manual (CMM) is released / approved by the design approval holder (DAH)?