IA Renewal 101

The change

After discussing and listening to the hundreds of people directly concerned, the FAA published the most recent revised directive (Federal Register August 2011) which thankfully took into consideration most of the commentators’ objections. FAA now says OK lets include many more people in the actively engaged definition … it is now much larger, as it said in the directive a broad definition, which seems to satisfy most of the concerns raised by the commentators. It would appear at this time that anyone presently holding an inspection authorization, must of necessity, be renewed because of this new broad definition, unless they died, or were seriously incapacitated.

There were other changes to the directive. One is the change to the seemingly automatic granting of inspection authority and renewal to FAA’s maintenance inspector employees under the initial directive. In the first proposal it had “carved out” a specific exception for its own inspectors who would be granted automatic authority. This of course meant FAA employees could work on and annual their own aircraft only, since they are prevented from doing any “commercial maintenance” activity for ethical reasons (more likely government liability reasons). Therefore, working on their own aircraft was then the only real reason for the ASI to have inspection authority.

In the revised directive the “carved out” exception was removed because it was not necessary … most if not all ASIs would be actively engaged under the new broad policy as would any applicant, because of their inspectors job description. Of course, at the same time, by removing the carved out exception the FAA also removed any suggestion of special treatment for its employees, which could have had some specific legal problems down the road.

Examples of those included

The new policy directive continues and describes a listing of individuals who would be afforded renewal privileges and includes, but is clearly not limited only to such people as:

• individual IAs, like ASIs, engaged in their own personal aircraft inspection and maintenance
• retired mechanics providing occasional or relief IA and maintenance services
• individuals providing maintenance service in rural areas not serviced regularly by many IAs
• individuals providing specialized maintenance and IA services (fabric, composites, etc.)
• those who do part-time or occasional maintenance and IA work to inspect vintage or rare aircraft
• aviation instructors at Part 147 schools, public and private (they weren’t included in initially)
• anyone directly related to airworthiness, i.e. technical representatives, instructors at seminars related to IA renewal and airworthiness, maintenance coordinators, (all on full-time, part-time, or occasional basis).

It seems clear that the policy is to include as many people as possible who have something to contribute to aviation safety, and or otherwise possessed of the requisite experience in the maintenance of aircraft.

There will be other questions that come up due to the great number of variations in the way people work. As the FAA said in its policy statement … ”It is problematic to list every situation that could be considered actively engaged and that approach may exclude situations where an ASI would determine meets the regulatory requirements. Additionally, as indicated in the proposed policy, the FAA values the substantive nature of experience rather than a strict quantity formula.”

Appeal available

In the remote event an individual feels that he or she has been unfairly denied either an initial or renewal IA authority because of arbitrary, capricious, or discriminatory action by the FAA, he or she has the opportunity to appeal such denial.