Everyone of us has heard the time-worn expression, “Once in a lifetime opportunity,” that is used to describe a single event or series of events that can have a profound change on one’s life, career, job satisfaction, and income. For we the technicians, as a profession, this once in a lifetime opportunity has arrived. This opportunity is cleverly camouflaged as a Notice of Proposed Rulemaking (NPRM) titled: Revision of Certification Requirements: Mechanics and Repairmen.
The NPRM was published on July 9, 1998, in Volume 63 Number 131, pages 37171 to 37210. If enacted, its numerous and specific rule changes will have a profound impact on the maintenance community. This NPRM is quite different in many areas from the NPRM published in August 1994 that first raised the issue of the Part 66 mechanic certification rule. The new NPRM is so different that the FAA had to cancel the old one. So, if you think you know what is going to happen with mechanic certification based on old information, be ready for a surprise because the rules have changed! So please, take the time and STUDY the new NPRM!
Once in a lifetime opportunities do not last forever. Technicians and interested parties will have 120 days from the date of publication to Nov. 5, 1998, to comment on the proposed rule changes. It is absolutely vital for the future of our profession that every certified technician, repairman, instructor, IA, and student technician comment on this rule. Why? Because I firmly believe that this rule will not be changed to such an extent again in our lifetime.
The NPRM is big, even by government standards. It is almost as long as The Iliad, filling 39 pages of tiny print in the Federal Register. So, plan at least a couple of evenings to wade through the fine print of the NPRM pages. It will be a painful, but educational experience, and for many of you, your first introduction into our legal system of rulemaking. The complexity of rulemaking in this country is a result of our Federal Aviation Regulations (FAR) that have the force of the law, and you will have to read the NPRM several times to separate the sum and substance from the legal jargon. Once your two- or three-day legal review is completed, copy down your notes on the changes you are interested in and discuss it with your fellow technicians at work during lunch or break. PAMA chapters and unions might consider this a subject for debate and discussion at several monthly meetings, so get input from others before you submit your comments.
For those of you who have seen me give IA renewals and maintenance presentations, or have read an article or two that I have written, you may have noted that I am rarely shy about offering my opinion on aviation maintenance-related subjects. However, for the rest of this article, I will provide you with an outline of the significant changes being offered in the NPRM without interjecting a personal comment or two. I must hold comment for two good reasons. First, as an FAA employee it would be unprofessional for me to publicize any personal comments, good or bad, about an NPRM that is still open for public comment.
The second, and most important, reason is I believe the average technician has more than enough common sense to make up his or her own mind on this NPRM, and doesn’t need my help to see how any new rule would impact their job, career, and long-term ambitions. However, as a certificated mechanic, I do plan to make my own private comments to the rules docket on this NPRM, and I hope I am not alone.
This overview of the NPRM is just what it means, an overview. It is limited in size and scope because of lack of personal comment and this publication’s limitations on the number of words per article. Please do not use this article as your only source of information. I urge you to take the time, invest two or three evenings studying and commenting on the proposals in the NPRM. If we, the maintenance community, become indolent on this very important issue, or worse yet, believe that 125,000 active technicians are impotent and their comments cannot effect change in the proposed rules that sets the standard for our profession, then we will certainly deserve what we get.
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Well fellow mechanics and repairmen, here is your first opportunity to get involved.
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