If you attended the Cygnus Aviation Expo in Las Vegas you probably sat in on the IA renewal seminars. If you did not, here is a brief summary of two of the topics discussed.
The discussion relating to renewing your IA authority (not a certificate) was of particular interest to those in attendance to say the least. There is still a lot of concern on the part of IA’s regarding renewal of their authority come next March 31, 2013. The waters are still a little muddy and we still do not have a copy of the new guidance for ASI’s which is to be published later this year.
According to Edward L. Hall, ASI, FAA Airworthiness, Eastern Division, who was present, he said that the expanded (second revision) of the “guidance” Order 8900.1, Vol. 5, Chapter 5 will not be printed until later this year and that both he and his FAA counsel, a Mr. Hawk, have been involved in the drafting of the revision to the guidance order. Hall works out of the FSDO located at the Richmond International Airport in Virginia and is an ASI as well. He can be reached at email@example.com.
Ms. Carol E. Giles, a former FAA employee who worked with Hall and now has her own consulting business in Washington, said that she had reviewed my AMT article (February/March 2012) with apparent approval of my comments regarding the issue of being actively engaged. Based on her reading, my comments should track the ASI guidance manual closely. It would appear from Hall’s comments, that the thrust of the changes to the order is directed more toward the issuance of new authorizations and less to the renewal process. Ms. Giles’ consultancy can be reached through firstname.lastname@example.org.
Federal Register Aug. 4, 2011
In the early policy statement that was published in the Federal Register on Aug. 4, 2011, actively engaged was broadly defined as … “someone who has an active role in exercising the privileges of an airframe and powerplant mechanic certificate in the maintenance of civil aircraft …” Needless to say, this has been expanded to include even those involved with aircraft maintenance on a part-time, or even occasional basis. Additionally, we should recall that anyone directly related to airworthiness issues, like technical representatives, IA seminar presenters, all can be considered actively engaged.
As I have stated, it seems clear that the proposed revised policy is designed to include as many people as possible who have something to contribute to aviation safety, and or possessed of the required expertise in the maintenance of civil aircraft.
No change to basic regulation
Keep in mind that the regulation has not been changed. For example, an eight-hour seminar attendance is still sufficient and has always been one of several ways to renew your authority. The regulation citing the eight-hour seminar, by itself, still meets the recency requirement for renewal (14CFR 65.93 (a)(4).
This has always been an option for renewal without having even performed any annual inspections or other pertinent labor. The addition of annual inspections or other labor active items, simply supports your position as being actively engaged! You should attend a renewal seminar even though some say that it is insufficient as a renewal component. Nothing can be further from the truth. The regulation is still crystal clear. Attend a seminar. This can be done online or in person and clearly satisfies the renewal regulation! Save your attendance confirmation and attach to your renewal applications. Keep in mind also that next March you should prepare two applications and have at least two (one for each term) seminar attendance documents. (Make and keep extra copies for your records.) Again, physical work component can simply be support for being actively engaged, the real renewal force comes from the regulation, i.e., the seminar attendance!
Also, doing certain other things can also satisfy this engagement requirement. Note that this active engagement requirement has always been connected to getting initial IA authority and never in the past has been attached to those who already have gone through the application and testing process for his or her authority. (Although mentioned in the renewal section of the regulation), Hall told me quite clearly that anyone who was renewed last year and in years past need not be concerned, you will be approved so long as your A&P certificate is current and valid. An IA is not valid unless accompanied with a valid A&P certificate.
The current and latest guidance as I understand it so far, after listening to Hall, the FAA person who set it all out, is that anyone who has been renewed in the past will have to be considered as being actively engaged going forward under any new guidance interpretation so long as his or her A&P certificate is valid.
Aging aircraft issues — corrosion
Like all of us, all of our aircraft are aging if not gracefully, with great speed. Cessna has been for some time now very concerned with structural internal corrosion in particular and component integrity in general. Beth Gamble from Cessna Aircraft in Wichita, (email@example.com) presented interesting details of the present ongoing aging aircraft structural program progress at Wichita.
We should be aware of the massive Supplemental Inspection Documents (SIDs) that have been published for the 300 and 400 twin model series aircraft. Keep in mind that SIDs are not mandatory for any of the Cessna products except those in commercial service that volunteer to include them or are required in their operations specifications. They set out in detail the additional inspections, checks, and various servicing steps that Cessna feels should be performed, the bulk of which concern internal corrosion that can attack the structural integrity of any aircraft. They are very basic in some parts and in others can be very time consuming and or expensive to complete as well. Nondestructive testing is an integral part of the inspections.
C210 AD note
A good example of Cessna’s concern shows in the recent AD on certain Cessna 210 series aircraft, to inspect the wing lower spar cap for stress cracks on all 1967 through 1986 C210s, AD 2012-10-04 effective June 5, 2012. This was a result of finding some C 210 aircraft in Australia with cracks at this location. Although there has been very few known structural wing spar failures, Cessna is urgently concerned about structural failure because of the single wing spar construction of the C 210 series.
Cessna has stated that the SID for the 210 series is valid for aircraft with less than 30,000 hours … It further states that beyond 30,000 flight hours the airworthiness of the aircraft cannot be assured. This apparently means that after these hours are reached the aircraft should be retired from service. I doubt this life limit has been reached by any C210s so far.
SID structural inspection requirements are added or will be added to the published Service Instructions manuals for each of the models concerned.
Ms. Gamble, as a senior manager, heads up part of the engineering structures group at Cessna and is concerned with the preparation and publishing of the SIDs and told us that the new inspection requirements for the 200 series aircraft are now published. The instructions for the 100 series aircraft are or will be available very soon. Since I am an owner of an older “legacy” C182 I am particularly interested in seeing what the inspections for my model would recommend. All of the publications including the SIDs can be conveniently found at Cessna.com which contains all you ever wanted to find out about Cessna publications and everything else concerned with Cessna aircraft.
Stephen P. Prentice is an attorney whose practice involves FAA-NTSB issues. He has an Airframe and Powerplant certificate and is an ATP rated pilot. He is a USAF veteran. Send comments to firstname.lastname@example.org.