The Ultimate Test: Inspection Authorization renewal

I just completed this year's round of IA renewal seminars. In nine weeks I visited 12 cities nationwide, tested the comfort of 33 jump seats, talked a total of 62 hours on regulations, and anesthetized by actual count 3,898 mechanics with my bureaucratic vocabulary and creative use of regulatory imagery.

But it was a hard nine weeks and I will need time to recover. I turned 59 in March, and found that I just don't bounce back anymore from these trips like I did when I was 58.

In March, as I sat strapped in a jump seat sitting upright like a baby in a high chair, I wondered if there was an easier way to do the IA renewal. I considered making the IA certificate a two-year authorization rather than a one-year. It made sense, good for the IA and good for the FSDO, but that two-year idea was shot down in the Part 66 notice of proposed rulemaking three years ago. Next, I figured that the pain of an IA renewal could be spread out over a year, like a progressive inspection, but getting all the IAs to four meetings a year is 10 times as difficult as getting them to one.

Short of rulemaking, the only other option left to the FSDO inspector and the IA for renewal is the oral test. But can you give an oral test to a large number of IAs? Yes you can. I watched the Rochester FSDO give most of their 188 IAs an oral test. Rochester's IA meeting lasted about five hours, and during the presentations, FSDO inspectors would tap an IA on the shoulder and they would disappear in a side room for about 10 minutes, and then another IA would be selected. The FSDO started this rather unique way of getting the IA renewed using a shorter IA renewal session coupled with an oral test because of the long distances the IAs have to travel to Rochester, usually over snow slick roads.

Flying to Philly, with a connection to MSP, I wondered, could this be done on a nationwide scale? The specific regulation that allows an oral test for IA renewal is section 65.93(a)(5). The rule states that a FAA inspector can give an oral test to determine that the applicant's knowledge of applicable regulations and standards is current. I checked FAA Order 8300.10, FAA Airworthiness Inspector's Handbook, and it provided no guidance on the length or subjects covered for the oral exam. What if I could design an Ultimate Oral Test? What would it look like? Despite being worn to a frazzle, I thought about it and here it is. The first part are the test questions, the second part are the answers. To see how good you think you are, cover up the answers and give it your best shot. If you can pass this, you can past any oral test given by any inspector anywhere.

Questions:

1.The airworthiness certificate is the most important document in the aircraft. True or False? Why?
2. What regulations are required to be complied with for the airworthiness certificate to remain effective?
3. How long are you held responsible for the airworthiness of a repair performed under Part 43?
4. How long are you held responsible for the airworthiness of an inspection performed under Part 43 and Part 91?
5. What kind of Field Approval requires Instructions for Continued Airworthiness?
6. Define the word "Airworthy."
7. Name four privileges of an Inspection Authorization (IA).
8. Name the three kinds of Airworthiness Directives?
9. A mechanic hands you a Form 337 for a major repair, you examine the work and determine it to be unairworthy, the mechanic will not correct it and says he will go to another IA. What do you do next?
10. A new rule in Part 43 went into effect on April 15, 2002. What requirements or standards does it speak to?

Answers:

1. False. The most important document is the registration certificate. If you check the airworthiness certificate Block 1, it asks for the N number of the aircraft. Also, in Block 6, Terms and Conditions, the Airworthiness Certificate requires that, in order for the certificate to be effective, the aircraft must be registered in the United States. So the registration is the most important, because no other U.S. airworthiness certificate or radio license can be issued to an aircraft unless it is U.S. registered.

2. In Block 5 of the Airworthiness Certificate it states that the maintenance, preventive maintenance, and alterations must be performed in accordance with Parts 21, Certification Procedures for Products and Parts, Part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration, and Part 91, General Operation and Flight Rules.

3. When you perform maintenance, you are held responsible for only that maintenance you perform until the part worked on is removed, repaired again, damaged, altered, meets its life limited, or inspected. For most Part 91 aircraft the longest time a mechanic is held responsible is 12 calendar months, when the next annual inspection is performed.

4. You are held responsible for the continued airworthiness of an aircraft that you just completed an annual on until the ink you used to make the section 43.11 entry dries. It is not fair for the U.S. government to hold a mechanic responsible for the future airworthiness of the aircraft when it is no longer in his care. What's the catch? The IA is not responsible for the future; he is responsible for the past. When a mechanic or an IA performs an annual/100-hour inspection he buys off every other inspection, major and minor repair and alteration, AD, service bulletin, STC, Field Approval, back to the date on the Airworthiness Certificate, be that date six weeks old, six months old, six years old, or 60 years old. He buys it all.

5. Field Approvals of Major Alterations require Instructions for Continued Airworthiness. Since a Major Alteration is a change to the type design of the aircraft there must be some way of maintaining the future airworthiness of that alteration. This is done by using Instructions for Continued Airworthiness that are attached to the Form 337 and accepted by the local FSDO Airworthiness Inspector.

6. Airworthy is defined as an aircraft or one of its component part(s) that meets its type design or properly altered condition (STC, Field Approval, or AD) and is in a condition for safe operation. (ref: Glossary AC 43.13-1b)

7. The four privileges are: Perform an Annual, perform or supervise a Progressive Inspection, approval for return to service either a Major Repair or a Major Alteration. (ref: section 65.95)

8. The three kinds of ADs are: Emergency/Priority Letter. It is a grounding AD that usually begins with the words: "Before further flight." The second kind of AD is the Immediate Adopted Rule. This rule allows the owner a short time to move the aircraft to a place where the repairs can be accomplished. The AD begins with words similar to: "Within the next 10 days, 10 landings, 10 cycles." The most common AD is the Notice of Proposed Rulemaking, that when it becomes an AD (a rule) it usually defines a one-time fix or requires recurrent inspections.

9. In this case the mechanic leaves the IA no choice but to mark the appropriate block of the Form 337 as unairworthy, and sign off block 7, and send it to the local FSDO. The IA has accomplished two things. First he has alerted the local FSDO of an unsafe aircraft and he has received credit for a Form 337 that he can use for his IA renewal.

10. The new rule in Part 43 is section 43.10. It deals with the disposition of life-limited parts. The long and short of it is anytime a mechanic has removed a life-limited part and will not install it back on the same aircraft after repairs are accomplished the life-limited part must be controlled. The life-limited part may have run out of time or still has time remaining. In either case the part is controlled by marking it with permanent markings, or non-permanent markings, or use a tag, or destroying the part (note: need owner's permission). If the part is stored, then the run-out, life-limited part must be stored away from like parts. The marking must contain at least the N number, serial number of the aircraft it came off of, the part's part number and serial number if any, total time, and date.

Well how did you do? Eighty percent is passing for my tests. Too tough? Just imagine what kind of test I could dream up if I wasn't fighting off exhaustion and old age.

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