IAs Get Ready for March 31, 2013

• You must complete one of the four classic ways to renew, i.e. oral exam, four annuals, eight 337s, or attendance at eight-hour seminar. Yes, the eight-hour seminar is still one of the four ways to renew.
• The change is simply that you now must also meet the actively-engaged part (that is part of the initial application requirements). For more than 25 years this has never been a requirement to my knowledge. No renewal applicant has ever been asked for proof that he has done mechanic work in addition to inspection work. This is the new policy change. Go figure.

FAA definition of actively engaged

“Actively engaged means having an active role in exercising the privileges of an A&P mechanic certificate in the maintenance of civil aircraft. Applicants who inspect, overhaul, repair, preserve, or replace parts on aircraft, or who supervise, i.e., direct and inspect those activities, are actively engaged. The ASI may use evidence or documentation provided by the applicant showing inspection, overhaul, repair, preservation, or replacement of parts on aircraft or supervision of these activities.”

Many senior IAs assist the smaller segments of the maintenance business … will they now be forced to spend time turning wrenches … sheer nonsense! Again, they are inspectors, they inspect.

Other significant parts of the ASI guidance manual

In addition, special attention is to be given to the volume of work that you perform … according to the guidance, it says: “... the volume of work performed or quantity of maintenance work activity demonstrates if the applicant (for renewal) was actively engaged …”

Again, we should note that this is “guidance” not regulation. No where in the history of IA renewal, or regulation, is volume of work mentioned as a demonstration of actively engaged (that’s the reason there was a reference back to the initial requirements to find it). As a matter of fact, the contrary is clearly stated in the Federal Register.

Before this change was effective the policy was well discussed in the description of the proposed change.

In the Federal Register Vol. 76, No. 150, for Thursday, August 4, 2011 Rules and Regulations page 47059, it says rather clearly … “the FAA values the substantive nature of experience rather than a strict quantity formula …” This means what it says … substance rather than volume prevails …

And, the Register goes on to state … expanding on actively engaged … “The FAA agrees that supervision of maintenance activities provides the same sort of experience that the actively-engaged requirement was intended to require. For that reason, the FAA will include technical supervision and supervision in an executive capacity on either full-time, part-time, or occasional basis in the definition of actively engaged. A technical instructor or a Part 147 school instructor may maintain aircraft or supervise the maintenance of aircraft in addition to instruction, in which case the instruction could be considered actively engaged depending on the activity demonstrated.

Also, procedures in the Guidance at 5-1312 Part B restrict aviation safety technicians (ASTs) and prohibit them from signing off anyone who is renewing based on the eight-hour seminar attendance. That person must be renewed by an aviation safety inspector (ASI).

“An aviation safety technician (AST) not holding an A&P mechanic certificate may renew an IA and sign form 8610-1 block 14 only when the IA has been determined to have met 65.91 and 65.93 (a)(1), (2) or (3) eligibility based on activity for the first and second years. Refer all other IA renewal eligibilities based on oral test or training attendance (eight-hour seminar) to an ASI for determination and Form 8610-1 block 1-14 authorizations. The AST authority with reference to an IA is limited to renewals only and further limited to renewal based solely on activity for both the first and second years.”

There seems little doubt that the FAA is attempting to discourage renewal by the use of the eight-hour seminar. It apparently will now give greater scrutiny to one who is renewing by way of a seminar.

Many in the trade have seen this two-year effort on the part of Flight Standards as a colossal waste of money and other resources to effectuate some sort of policy that was not needed and indeed serves no useful purpose, except of course to discourage some senior IAs to pack it in, which may have been the purpose in the first place, otherwise why have the FSDO sponsored IA renewal seminars quietly disappeared?