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.
b) The instructional requirements of §65.93(a)(4), may be met by accumulating at least eight hours of maintenance training each year. Each course or seminar must be at least one hour long and completed in the 12-month period between April 1 and March 31 prior to IA renewal.
c) Each person who intends to use eight hours of instruction each year to meet §65.93(a)(4) must provide proof of attendance for instruction received at the time of renewal. Acceptable proof of attendance consists of a certificate of training or similar document showing the name of the course, name of attendee, course identification number assigned by the Airworthiness Regional Safety Program Manager (RSPM), expiration date, description of the course content, time in hours, the date, location, and course instructor’s name and affiliation. The proof of attendance should be reviewed by inspectors at renewal time to ensure that both the training organization and the IA have met the appropriate requirements. The training organization must keep a list of all attendees for a period of two years. This list must be provided by the training organization to FSDO inspectors upon request.
2) Passing of an oral test given by an aviation safety inspector (ASI) to ensure that the applicant’s knowledge of regulations and standards is current.
NOTE: An IA issued less than 90 days before the expiration date need not comply with §65.93(a)(1) through (5) for that quarter, but still needs to apply for renewal.
C. If an IA holder does not meet the renewal requirements at the end of the first year, the holder must take and pass an oral test prior to exercising the privileges of their certificate in the second year.
NOTE: If an IA is issued less than 90 days before March 31 of the even numbered year, the holder does not need to comply with §65.93(a)(1) through (5).
D. If the applicant applies for renewal at an office other than the jurisdictional office, the receiving office should withhold renewal until the applicant’s activities can be verified.
E. When the applicant is employed by a repair station, credit for renewal activity can be claimed only for those aircraft that the authorization holder personally inspected. Evidence supporting the activity should be presented in addition to the signed application.
A few problems
Now being the seer that I am I can foresee a couple of problems popping up in the new process. First, you have to remember that the new IA renewal period runs from April 1 to March 31 for two consecutive years. Each year of the two-year period has identical renewal requirements which have not changed from the old way of doing business.
So some IAs are either going to get all of the two-year requirements in the first year or some will only get a few of the requirements for both years. If this is the case and you have not met the rule requirements for the first year, you cannot exercise the privileges of the IA in the second year. So if you signed off any aircraft inspection or Form 337 after March 31, 2008 and you did not meet the first year IA requirements those aircraft are un-airworthy and you and the owners of those aircraft have a major problem on your hands.
Take an oral
Let’s say for argument sake that you did not meet the IA requirements above in the first IA year (April 1, 2007 to March 31, 2008) now what? You will have to take an oral test by the FAA inspector to meet the requirements for the first year that you missed or if you think you will not meet the requirements for the second year. If either of these scenarios have your name on it, please call up the FSDO and get on the list for an IA oral renewal test and do it NOW! You don’t want to be sweating getting an appointment for the test during the last week of March 2009 to get qualified because after March 31 you will have to take the IA test all over again.
Be advised that the FSDO inspector who is going to do your oral test did not hire on to the FAA just to save your butt. He is well aware that you had a year to meet the renewal requirements. So you will not be dealing with a happy camper. So show the inspector a little respect at test time because I am sure he or she has a thousand other things he could be doing other than pulling your fat out of the fire.
The oral test by rule is left to the FSDO inspector to design. If it was left up to me I would design a 10 question test. You don’t need a 50 question test to know if an IA is still at the top of his game. I would then notify the IA on the subjects that I would cover and the date and time of the test so he could prepare for the test without wasting his time or mine. My test would cover at least the following areas:
What you need to know for the test
The Test: The first three questions should cover the four FARs in Part 65 that establish the IA’s privileges, renewal, and responsibilities, (FARs 65.91-65.95). Next, I would ask about the scope and detail of an annual and progressive inspection found in FAR 91.409 and the recommended logbook entries in FAR 43.9 and 43.11. This would be followed by a couple of questions on how to fill out a Form 337. I know, I know, you have been filling out 337 forms forever, but there is a new AC 43.9-1F: Instructions for filling out a FAA Form 337 that came out in January 2007 and it has some new policy in it. So whether you met the IA renewal rule already or not it is well worth a few minutes of your time to read it.
Next, I would hit on the “approved data” requirements found on the signature page of AC 43.13-1B and AC 43.13-2B. Make sure you read the signature page of AC 43.13-2B! This is important because since March of 2008 it now allows the data in the AC to be used for major alterations if it meets the three conditions on the signature page. I would ask the last three questions on how to obtain field approvals of data found in AC 43-210, Standardized Procedures for Requesting Field Approval of Data, Major Alteration and Repairs, and at least one question on Instructions for Continuous Airworthiness (ICA) for a Major Alteration performed under a field approval. Policy on ICA is found in FAA Order 8900.1 Volume 4 Chapter 9.
If you really want to ace the test, I recommend that you just google the FAA.Gov website and pull up the Regulatory and guidance library site and download all the above referenced ACs and chapter in Order 8900.1 along with any other material you think you need to pass the FAA oral test.
In closing, this change to IA renewal rule is not the end of the world. It is just a different way of doing business. In the long run, this new change may turn into a good thing and surprise us all.