In case you missed it … the FAA has published a proposed new policy change regarding the issuance and renewal of the Inspection Authorization (IA) authority routinely issued and renewed now every two years by your local FSDO. It has published this proposed policy change on the date noted above and it asked for your comments by Dec. 6, 2010.
Due to the large number of expected comments the cutoff date has now been extended to Jan. 17, 2011 to allow for further comment which of course will have passed by the time you read this. There may however be some people who are not even aware of this proposed change as they read this article. Late filed comments will be considered if they do not cause delay or added expense. So file your comments as soon as you can.
The Federal Register piece sets out a definition of “actively engaged” as follows …
Actively engaged means exercising the privileges of an airframe and powerplant mechanic certificate in the maintenance of civil aircraft. Applicants who are employed full time in inspecting, overhauling, repairing, preserving, or replacing parts on aircraft are considered to be actively engaged.
However, the definition goes on to say that part-time or occasional work will have to be evaluated by an ASI to determine if the applicant is “actively engaged.”
The problem here is simply that the regulation in Part 65 clearly provides for renewal of the IA authority with the attendance at approved continuing education programs as an alternative to hands-on work. The proposal fails completely to address this critical aspect of Part 65.
Policy change not regulatory
This policy change is not a change to any regulation, at least at this time. What is being proposed is a more current understanding of what constitutes “actively engaged” which is in the language of the Part 65 regulation … A regulatory change would clearly be opposed in a most vigorous fashion and take much longer to implement. That is the reason the use of a policy change is perceived by FAA to be an easier route to a change.
The proposal states that the term “actively engaged” has caused confusion among ASIs and maintenance personnel, although if you talk to the many IAs in the field this is a non-issue and is not confusing to anybody. This seems to many as simply an excuse to do what they want to do, if in fact one is needed. The field personnel simply say that the system as presently existing has served us well and should be left alone. There are many other more significant matters to address rather than one that is a non-issue, so say many working technicians. Many IAs have stated, for example, that the regulatory alternative of sanctioned and approved training programs are more important and produce equally qualified IAs vs. hands-on employment.
One can only speculate what the real reason for raising this non-issue at this time? Some have suggested that since there is a similar change in the works for flight instructors, as discussed recently during a meeting in Washington, D.C., adding to the requirements to renew their certificates.
Some say that it is being prompted by an ill-timed and poorly thought out attempt to harmonize our regulations with European EASA regulatory mandates. Who knows? It could even be all about training money. But the action is certainly felt by many to be suspiciously related to EASA regulatory schemes. We will see what develops on this front.
FAA’s Guidance Document 8900.1
The document being proposed for amendment is the FAA “guidance” (to the FSDOs) for the issuance of Inspection Authority, in the Flight Standards Information Management Systems (FSIMS), FAA Order 8900.1, Vol. 5, Chapter 5, Sections 7 and 8. The reference ASIs means FAA aviation safety inspectors. Here is the way the proposal in the Federal Register reads regarding renewal …
New policy rules will be in effect
It is our opinion that, while the goal has some merit, the consequence is not in the best interest of our constituency or, as a matter of fact, the general aviation industry.
The revised latest directive with broad definition of actively engaged
Some practical observations on the Pilots Bill of Rights