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 firstname.lastname@example.org.
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 email@example.com.
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!
New policy rules will be in effect
Some practical observations on the Pilots Bill of Rights
In case you missed it … the FAA has published a proposed new policy change regarding the issuance and renewal of the Inspection Authorization (IA) authority routinely issued and renewed now...
The revised latest directive with broad definition of actively engaged