A recent change to the IA renewal period was recently published as a Final Rule in the Federal Register. The title of the rule is "2-year IA Renewal."
Upon first glance, it appears that this change means that Inspection Authorization holders (IAs) need only address their renewal requirements every 24 months. This is only partly true!
If you are an IA that is very active and renew your IA by completing the requisite number of annuals every year, you now need only visit the FAA once every 24 months.
Conversely, if you are an IA that renews your certificate through an approved IA renewal program, you will need to continue to attend (in person or online) these IA approval courses each and every year prior to March 31. No change!
Seems simple right? Well I've heard many IA's comment upon seeing the title of the new rule that they now only need to train once every two years. Let's assume that a certain small percentage of mechanics interpret this rule incorrectly — say 2 percent! According to the rule, these 2 percent would have their IA certificate expire after March 31 of the first year.
Now say that some of these inspectors decide to go out and do several annual inspections on several aircraft. Then, the 24-month renewal period comes up and they go to their local FSDO to renew their IA. Mr. FAA Inspector asks them for their 8-hour training certificate for the previous year —– and guess what? — no certificate!
No problem right? They just need to re-test. But what about the aircraft that were inspected while the IA was not valid? I'd say that these aircraft are (on paper) not airworthy and have been flying around for up to a year without a valid annual inspection.
Can you imagine the paperwork nightmare that would (will) ensue under these inevitable circumstances? The FAA says it will save hundreds of thousands of dollars in administrative costs by not doing the paperwork each year. I anticipate that the amount of paperwork, legal filings, etc., would quickly eat up the "Administrative Savings" offered by this extended renewal program!
Let me come clean on my position on this extended IA renewal program. I have fought (as many in the industry have) for increased training requirements for mechanics for many years. Although this rule doesn't technically change the amount of training each year for mechanics — it reduces the FAA's commitment and emphasis on training! Frankly, I am personally opposed to any reduction of training requirements — which this new rule or any proposed variant thereof implies! It takes away from our pursuit of professionalism — and again places the burden square on the back of the mechanic.
At local IA renewal meetings around the country, the FAA has traditionally supported the IA renewal programs by providing inspectors that attend and sign off paperwork. Some of the FSDO inspectors even organize the events. This saves the local offices from having to schedule and review individual filings — re-testings, etc.
The new requirements virtually ensure that the FAA will not be present every odd year! There's no need for them to be there as there are no paperwork requirements. So for these odd year IA renewal meetings, we have lost the support of the FAA — and thus, encouragement to train.
Since the rule was published as a final rule, I would assume that it is a done deal as far as the FAA is concerned. The rule is scheduled to become effective March 1, 2007!
I can only ask that our dedicated readers pass the word that the training requirements continue to be the same, and that all of you promote training as a critical part of being a professional mechanic.
Proud to be an A&P
Bill's take on the two-year IA renewal.
The path to Inspection Authorization
I just completed this year's round of IA renewal seminars.