IAs Get Ready for March 31, 2013

New policy rules will be in effect

Most technicians with Inspection Authority should know by now that the two-year long controversy regarding IA renewal procedures has been finalized. After receiving almost one thousand comments from technicians in the field, Flight Standards was forced to make serious revisions to its proposed policy change. The new “guidance” for FAA safety inspectors (ASIs) and aviation safety technicians (ASTs) has finally been published in what is now called the Flight Standards Information Management Systems (FSIMS) cited as Order 8900.1 Chg. 211, (Vol. 5 Section 8 and Section 7), or better yet, commonly known as the Inspectors Guidance Manual.

This is the bible that is an interpretation of the regulations for use by the inspectors. Up until the last renewal period (March 31, 2009 – March 31, 2011) , the old policy applied … the period of 2011-2012 and renewal on March 31, 2013 starts the application of the so-called new policy interpretation of the regulation and guidance for FAR 65.91c(1) thru (4).

This policy guidance was published and released May 13, 2012, and this writer reviewed his copy during this past August. This timing raises a question of whether or not this revised policy can apply to the past two years … the guidance was not published until May 2012 … does it apply retroactively to the past two years rather than the upcoming two years? Some have questioned this application. Can the policy change apply to a period of time when it was not in existence in the guidance manual, notwithstanding the arbitrary policy effective date published in the Federal Register of Sept. 6, 2011?

The new guidance Section 8 of Vol. 5 Chapter 5 is the part that describes the Renewal of Inspection Authorization. Interestingly however, it refers you to Section 7 (Initial Application for IA authority) for further instruction: 5-1309:

Renewal of IA: 1) Show evidence and/or the applicant’s ability to meet the requirements of FAR 65.91(c) (1) through (4). Note: Refer to Volume 5, Chapter 5, Section 7, subparagraphs 5-1279A through C for additional information on meeting 65.91(c)1 through (4) requirements during renewals to include actively-engaged guidance.

Note: Refresher training attendance alone does not satisfy those requirements.

The key element that is focused on in this new policy is the actively-engaged part of the requirements for initial issuance of inspection authority.

Somehow, after all the years that IA authority has been in existence, the wizards at Flight Standards in Washington have decided that there should be the same requirement for active engagement in work in both instances, i.e. initial issuance and renewal. (Even though regulation seems to support it.) The reasoning given for all this concern is …”it has caused confusion among ASIs and aircraft maintenance …” We have never found any confusion from any of the technicians we have talked with, however.

Most of the complaints came from IAs who have been in the business for many years and have either moved up the ladder or reduced their hands-on mechanic work as they grew older. (All of these complaints can be read on the web.) They may have left maintenance as such and did nothing but inspection work which is, needless to say, the function of a mechanic in the first place. Whether or not he actually turns a wrench, IAs are inspectors first and foremost.

Inspectors in industry and indeed in the military are just that, inspectors. I can remember in the USAF we mechanics were in awe of the inspectors because of their power to create more work for us. The inspector was never expected to do mechanic work and at the same time be an inspector.

The FAA has made broad provision for many of these circumstances in its revised policy statement however, and others as noted in the Federal Register and the new guidance cited below.

New renewal requirements

There are basically two requirements now for renewal:

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