I feel lousy. I just spent three months on the road, staying in hotel rooms with complimentary mildew smells in the carpet and fuzzy black stuff on the bathroom tile that likes to eat soap. Let us not forget that every one of my trips begins and ends with a ride in a jump seat (See September 2005), and every frequent flyer knows that an airplane is a Petri dish with wings. Travel is not fun. Travel is a foretaste of Hell. And when you are on the road a lot the chances of getting sick are always high.
So it was on the last week of my travels in March — despite swallowing lots of aspirins, engaging in frequent hand washing, and gargling with the green stuff every morning and night — that I lost my thumb wrestling contest with Typhoid Mary and I got sick.
Oh, it’s not the “at death’s door” kind of sick, it’s more like, “sitting in a parked car in the street just outside his house,” kind of sick. Just when I thought it could get no worse, my editor called. “We need an article for the next issue,” she said cheerfully. I will not tell you what my reply to her was, but leave it up to your imagination. In my weakened condition, she won the contest of wills. Now, sick and beaten, I had to find something to write about.
In between fighting the fog of congestion and coughing so hard my chest hurt, I had a moment of clarity. You know the kind, it’s just like the moment of clear headiness you have after filling a handful of tissues with a lot of green snot. In that instant, I decided to write a briefing on what is happening in Headquarters. So I made it happen.
The PAMA request to increase the Inspection Authorization (IA) renewal period from one year to two years has been signed off by Flight Standards Service and has gone to the rulemaking committee. The committee will decide whether or not to revise 14 CFR section 65.93 to allow for a two-year renewal period. I wrote the justification in Appendix 1 to the proposed rulemaking document and we have good grounds for a rule change.
First, standardization. The current one-year IA renewal period does not match the two-year renewal periods for Designated Airworthiness Representative, Designated Mechanic Examiner, Designated Engineering Representative, Flight Instructor, etc. This IA renewal period does not follow the standardization of procedures and policy requirement of ISO-9002, and Flight Standards Service recently became an ISO 9002 compliant organization.
Second, economic benefit. It is conservatively estimated that the government would save somewhere in the neighborhood of 7,500 man-hours in processing the applications and $8,000 in postage costs every two years. The economic benefits to the 15,000 IAs are almost impossible to compute because half of the IA population just mails in their applications and the other half either drives a long distance or stays overnight to attend an FAA eight-hour IA renewal meeting. I argued that just cutting these travel costs in half and saving time spent on the application process will save the IA community a bunch of money.
Third, no impact on safety. While the draft rule change will allow for the IA application for renewal to happen every two years instead of ever year, the IA must show that he has done eight annuals, or 16 Form 337s, or two progressive inspections, or completed 16 hours of FAA accepted training at the end of the two-year renewal period. Why? The rulemaking committee had to be satisfied that we were not lowering the standards for IA so the basic yearly requirements for renewal are still in place.
While I am hopeful that this revision will go through I must warn you that all rule making is a crapshoot. There is no such thing as a sure thing in Washington. But we should have a good idea if the rule change is going forward into the formal rulemaking process by the end of May.
On May 21, 2003, seven months after the Federal Aviation Administration (FAA) made the first substantive revision to field approval policy in 20 years
My father was a big man, straight from the old sod. He was a lot smarter than I and a card-carrying survivor of the depression years.
In Part 2 of my tome on field approvals, we will cover current field approval policy found in Change 16 to FAA Order 8300.10.