A look at the IA renewal process

In the politics of running for office the candidates of both major parties love to talk about change. But we all know that change can be a good thing — or a bad thing — or wind up just being change for change sake with absolutely no impact good or bad on the way things are done.

This March 2009, IAs are going to experience a change in their IA renewal process. This change is the result of the Jan. 30, 2007 Direct Final Rule that changed FAR 65.93 IA application for renewal requirements from one year to two. This was the first major change to the IA rule since the Inspection Authorization was created by the Civil Aviation Administration when it signed the CAR 24.43.1 rule, way back on June 17, 1956.

The March 31 IA renewal date has been with us for the past 52 years. No one knows for sure why the March renewal date was picked, but since I was involved in rulemaking for more than 20 years in FAA headquarters, it would not surprise me a bit if the March 31 date was picked because it was the guy-in-charge’s birthday. Mock me if you must but I am not kidding when I make that statement.

Prior to the change, for 52 straight years IAs turned in their renewal paperwork by March 31. That date was all we had to remember. Life was predictable, and therefore comfortable. Now under the new IA renewal rule change we have to reset our memory hard drive so that it is now every second year ending with an odd number we have to turn in our paperwork. So in March of 2009 we have to renew.

Now I know and you know that mechanics hate change. We are process-oriented folks and no one likes a long-term process like IA renewal being messed with. However, there should be no complaints. All of us had two years to get ready and the basic IA renewal requirements have not changed. You still need to have the four annuals or eight Form 337s or eight hours of training each year of the new two-year renewal period. Because of the serious consequences of sending a screwed up application to the FSDO in March, I have copied the “Official” IA renewal requirement from the FAA inspector’s Flight Standards Information Management Systems Order 8900.1 for your review.

5-1309 Renewal of Inspection Authorization
A. Application for renewal may be required to comply with following:

1) Complete Federal Aviation Administration (FAA) Form 8610-1, Mechanic’s Application for Inspection Authorization, in duplicate; and

2) Show evidence of meeting the requirements of §65.93(a) for both first and second year.

B. Meeting the requirements of §65.93(a) does not mean that the applicant has to meet all five of the listed requirements. To be eligible for renewal of an IA for a two-year period, the applicant must show evidence of having performed four annual inspections during each 365-day period prior to March 31 of each year for a total of eight annuals prior to the renewal date to be able to qualify for renewal. The same logic applies for major repairs and major alterations. However, the number of annual inspections, major repairs, and major alterations performed cannot be mixed simply because §65.93 does not provide for such combinations. The following chart demonstrates this system:
NOTE: An inspection program required under 14 CFR Part 91, §91.409(e) is not acceptable as IA activity. Partial inspections such as phases or events on more than one aircraft are not acceptable as activity.

A progressive inspection is a complete inspection on one identified aircraft.

1) Successful completion of an eight-hour refresher course, acceptable to the Administrator, for each of the 12-month period preceding the renewal application.

a) The refresher course must contain subjects directly related to aircraft maintenance, inspection, repairs, and alterations. In addition, some non-technical subjects, such as human factors or professionalism as they relate to aviation maintenance personnel, may be acceptable. Training must not be used to promote a new or existing product.

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