Tech Forum

Here are a few of the comments AMT has received from readers on the FAA’s policy change proposal regarding the definition of “actively engaged.”

Actively engaged
In no other occupation is there a requirement to be actively engaged, I feel it is wrong to have the requirement on aircraft technicians with an Inspection Authorization and it quite possibly could be challenged in court, when compared to other safety sensitive occupations.

Pilots do not face losing their license and having to retest if they do not maintain a full-time job. Just in case you are wondering the FAA is defining a full-time job (actively engaged) as 2,080 hours per year. If you look at the hours that some flight departments are flying you have to ask: How in the world can a pilot flying 150 hours a year or less be proficient and actively engaged?

You cannot argue that a biannual flight review is the same as a test; I know this because I have had several. Doctors, that we trust with our life, never risk losing their certification based on time in their practice. Neither do nurses, lawyers, medical technicians, or truck drivers. Yet an aircraft technician laid off from his job, changing location, or suffering from an extended illness, can have his IA taken away, and have to retest.

I believe that training or getting recurrent (FAA IA renewal seminars) has been accomplishing the desired results. Just to show how ludicrous this term is, the FAA has granted an exemption for its employees. Maybe the real question should be, should the phrase “actively engaged” be removed completely from the FARs?
— Tim Begeot, A&P, IA, SEL, ATS

IA renewal
I just received my IA renewal letter from the North Florida FSDO 15. It is my understanding that the comment period for “Actively Engaged” has been extended to Jan. 17. Tampa claims this “Significant” change is now in effect and unless employed full time, one will have to be evaluated with “documentation or evidence” by their ASI for renewal.
— Tim Begeot

Ed Hall from the FAA says the policy change is still a proposal (as of press time), and it is extremely remote that any changes would be enforced this year.

Won’t make aviation safer
This new rule won’t make aviation safer. It is just another way the little guy gets pushed aside. In this country where unemployment is out of control how can the FAA now see fit to target people who have worked hard to achieve the highest machanic rating there is.

Also exempting FAA employees who have their IA ratings is a real smack in the face. Just how do these people stay actively engaged? I think the FAA needs to rescind this new attack on mechanics as I do not feel this will make aviation any safer. If the FAA thinks it will, then let them prove it.
— Roger Pries

Inconsistency will result
Let us not fool ourselves in thinking the “streamlined” ASI requirements for IA renewal will result in anything other than a nightmare for both the general aviation community and the poor IA himself.

Inconsistent interpretations of “active” between one FAA office and another will most certainly result in personal and subjective elements at renewal time. We don’t need added problems like these.

I’ve made a career out of aviation since I was 16 (currently crewmember at major airline) and spent much time, money, and effort obtaining licenses and degrees in both the pilot and maintenance side and have utilized both during varying career paths.

Many individuals, such as myself, continue to devote their support (regardless of their current status within the industry) to the maintenance side of aviation. There aren’t many left who choose to put up with the bureaucratic headaches to continue this effort and those who do should be valued and their dedication should be supported. Our attention to detail, knowledge of the regulatory process, and compliance with this process should result in recognition by the agency, not suspicion. We pride ourselves in serving as an “arm” of the very agency that is proposing to eliminate us. I would emphasize our proficiency has no tie to the “full time” or “part-time” interpretation being proposed and should only be tied to our knowledge and performance.
— Bruce Quinby

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