Changing Your World

March 1, 2001
The path to Inspection Authorization

Sooner or later, there comes a time in every mechanic’s career when a random thought from nowhere hits you between the eyes and burns into your brain. First reaction to such a thought is "What the hey?" This reaction is followed quickly by a voice from deep within, whispering seductively, "Why not get an Inspection Authorization (IA)?" This is followed by a more extroverted sounding internal voice similar to a used car salesman that says "Man, with that ticket, you could be the big guy on the hangar floor," or even better, the ever popular, "You could change your world."
Some mechanics see visions of themselves sitting in a warm office, drinking coffee and filling out 337s instead of working outside on the ramp, stamping cold feet on unyielding snow. Others see a pay rise in their future, so they can buy their kids some shoes. Still other mechanics see getting an IA as an individual step, a natural progression if you will, in becoming a consummate professional.

History of the IA
In the beginning of this IA quest, most mechanics do not have a true understanding of what an IA is, not to mention where the IA came from. For example, the predecessor of the IA is the Designated Aviation Maintenance Inspector (DAMI), who first saw the regulatory light of day on January 15, 1946. DAMIs worked directly for an individual Civil Aviation Administration (CAA) inspector and was selected on a "need" basis only. A DAMI could do everything a CAA inspector could do except process enforcement actions.
Back in the 1940s and 1950s, an aircraft owner was required to have two inspections on his aircraft every 12 calendar months. The first inspection was a 100-hour inspection performed by an A&E mechanic. When that inspection was signed off, the DAMI would do an annual inspection of the aircraft. If the aircraft was airworthy, the DAMI would then issue a brand-new airworthiness certificate. Because of legal actions taken against the government, the 10-year existence of the DAMI was cancelled on June 17, 1956 by the issuance of a new rule, CAR section 24.43.1 This rule replaced the DAMI with the "Inspection Authorization" and all current DAMIs were grandfathered into IAs. At the same time, the yearly 100-hour requirement was dropped and the term "annual inspection" was replaced with the term "periodic inspection," which was now performed by the IA. Private owners now had to comply with one periodic inspection a year instead of the original two.

CAA is now spelled FAA
On April 1, 1958, the FAA took over from the CAA and the recodification of the CARs into the FARs began. During the 8-year rule updating, the FAA retained the IA rule along with its privileges and limitations. In July 1966, in one of the last recodification actions, the FAA made some changes to the IA. At the same time the IA requirements were put in Part 65, FAA dropped the term "periodic inspection" and brought back the old term "annual inspection."
This little bit of history should explain some strange looking entries in old logbooks.

IA regulations
So much for history. Now to the nitty gritty. What is an IA? Why should a mechanic want to become an IA? What makes an IA stand out from his peers? There are several answers to these questions. A regulatory answer would point to CFR 14, Part 65, sections 65.91, 92, 93, 95. Here one would find the eligibility requirements for an IA, its duration, renewal, and its privileges and limitations. If I may, I would like to paraphrase each rule.

How to apply
Section 65.91: Inspection Authorization explains how to apply for the IA. The applicant must hold a current A&P certificate and be active in the trade for the two years prior to making application. The applicant must have a fixed base of operation where he can be reached by telephone. The fixed base requirement does not necessary mean the place where he performs the inspections and besides with cell phones an IA can be reached anywhere. The applicant must have the equipment, facilities and inspection data available to him. This rule does not require the IA to own all the data, equipment, etc., just have it available for his use. The applicant must take a written test of 3 hours duration and if the applicant fails, he or she cannot retest for 90 days.
Section 65.92 Duration explains that an IA expires on March 31 of each year, and is effective only when the IA has a current A&P certificate. The IA also ceases to be if the IA no longer has a fixed base of operation, or if the IA is surrendered, suspended, or revoked, or when the IA no longer has a facility, data, or equipment to perform the work.
Section 65.93 Renewal explains that for an IA to renew, he or she must show that for each 90 days the certificate was held, the IA must have done one of the following:
• Performed one annual inspection (total of four per year)
• Performed two major repairs or major alterations (total of eight per year)
An IA can also show that he has done one of the following as basis for renewal:
• Performed or supervised a progressive inspection
• Complete an IA 8-hour refresher course acceptable to the FAA
• Pass an oral exam given by a FAA Inspector
Many IAs believe you can mix and match the requirements in Section 65.93, which is not the case. The most popular renewal option is the 8-hour IA renewal classes given around the country. The least popular is the oral exam. I wonder why?
Section 65.95 Privileges and Limitations explains that an IA can inspect and approve for return to service major repairs and major alterations, perform annual and progressive inspections, present his certificate upon request to the FAA, NTSB or any federal, state or local law enforcement officer. This section requires an IA, who changes his fixed base of operation, to notify the local FSDO in writing before exercising his IA.
What should also be mentioned here is an additional privilege that is not covered by the regulations but is covered by FAA policy. An IA can approve "acceptable" repair data found in AC 43.13-1B Acceptable Techniques and practices, Aircraft Inspection and Repair, as long as the repair data is appropriate and applicable to the repair and not contrary to the manufactures instructions. This policy statement is found on the signature page of AC 43.13-1B.

How to become an IA
First, you have to be eligible for the IA so that means you need to read section 65. 91 and see if you meet the requirements. Okay, that yes/no exercise was bloodless. If you are eligible, the next thing is to get a hold of a FAA document titled: Inspection Authorization Knowledge Test Guide, FAA-8082-11. In another life, it was the AC 65.19G the IA Study Guide. The IA Knowledge Test Guide is presently available on the Internet at http://AFS600.faa.gov/data/knowledgetestguide/faa-g-8082-11.pdf and printing out the 36 pages, or, pick up the test guide at the local FSDO or get a copy from the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402-9325.

More than just a test
The Knowledge Test Guide has all the information to prepare to take the test, including additional publications and ACs that help fill in those knowledge gaps. Let me try to make a point: Both you and I know there are plenty of other books, courses, and seminars that advertise that they prepare one to take the IA test. All will pretty much give you all the information needed to pass the test, but passing the IA test does not make you an IA in the real world anymore than passing a state driver’s license gets you ready for the Daytona 500.
Being an IA requires a lot more from an individual than taking a test. IAs must bear the awesome burden of additional duties and responsibilities and make the hard airworthiness decisions that other mechanics are not authorized to make. So, a "cram school" or seminar is always limited to passing the test. Nothing but nothing takes the place of burning the midnight oil, delving into the books, taking practice exams, in short, preparing for the job you will do for the rest of your life.

Study tips
Before I would take the IA test, I would pay special attention to the regulations called out on the Airworthiness Certificate (Parts 21, 43, and 91). I would also memorize the IA rules. Know the difference between "approved" and "acceptable" data. Know the difference between a Form 337 and a Field Approval. Also, commit to memory Sections 43.9-11-13. Know how ADs are revised, the kinds of AD, and how type certificates and STC figure into the term "airworthy." The additional preparation time will give you the strong self-reliance to make the tough calls that will come your way, instead of the shallow confidence that comes with preparing only to pass a single test.

Data collection
Okay, you’re prepared. Next, take yourself to the local FSDO, because now you have to prove that you meet the requirements of the rule, which also includes personal identification — so have a driver’s license and your A&P certificate ready. Also, you have to show that the data, such as AD, TC data and spec sheets, manual, etc., is available to you. I remember back in 1972 BC (before computers), that I had to haul 14, three-ring binders of data down to the FSDO. Today, I just shake my head as I watch applicants walk in with a laptop and a couple of CDs.

On to the testing center
With your ID and data availability confirmed, the FAA inspector will have you fill out FAA Form 8610-1 Mechanic Application for Inspection Authorization and he will mark the endorsement block and sign the form. The inspector will then give the name and location of the nearest computer-testing center that, for a fee, will give you the IA test. For the curious among you, a list of all the testing centers can be found on the Internet at http://afs600.faa. gov/data/computertestingsite/allactivesites.pdf.
Next, call the testing center and make an appointment to take the test. Make sure you know what the current fee will be to take the test. If you do not make it to the testing center at the appointed time, you could be charged a cancellation fee. The testing center will have to see some form of ID and your FAA Form 8610-1. You do not have to bring your data with you as it will be provided. You can use test aids like scales, straightedges, non-programmable handheld computers, and printed formulas. However, the handheld computer instruction book is not permitted. And for reasons known only to a few, a dictionary is not allowed.

The IA test
The IA test is 50 questions and is limited to 3 hours. While taking a multi-choice test may seem easy; the test has been so refined that the applicant must have a strong core knowledge of maintenance and regulations to succeed. By the way, forget the old saw that the longest answer is the right answer. One good thing about a computer- driven test is that you get the test results right away in a document called the Airman Test Report. So in this computer age, you can walk out the test center door standing on top of the world or buried under it.
If you fail the IA test, and many A&Ps miss the first time, go stand in a corner and allow yourself 30 seconds of self-pity. Then, promise yourself that in the next 90 days (time allowed before one can take the test again), that you will be even better prepared. If you pass, take the Airman Test Report (ATR) to the local FSDO and an FAA inspector will go over the test results with you to ensure that you know what mistakes you made. Once satisfied, the inspector will issue you the FAA Form 8310-5 IA Certificate.

The payoff
It is only when you stand there outside of the FSDO, holding on to the little buff-colored IA card that you realize the United States Government has given you some awesome new powers along with some terrible new responsibilities. What you do with these new powers and responsibilities, IA, depends on your strength of character, training, and your personal commitment to safety. I wish you the best, for you have taken the first step to change your world.