With respect to the “Alternative means of Compliance” provision in TCO.105(a), can we deviate from an ICAO standard if we submit a risk assessment to EASA?
No. Alternative means of compliance cannot be used to establish compliance with ICAO standards (ref. Guidance Material GM1 TCO.105).
TCO.105 (a) solely refers to the situation where an operator intends to deviate from so called Acceptable Means of Compliance (AMC). Currently, EASA has published only three AMC provisions related to Part-TCO, namely AMC1 TCO.105(a), AMC1 TCO.200(b) and AMC1 TCO.210. If the operator is compliant with these three, then TCO.105 is not applicable.