Foreign (Non-U.S. Citizen) A&P Applicants

It’s simple supply and demand. U.S. registered business and general aviation aircraft are increasingly both operated and based around the world. Just as in the United States, servicing and maintenance for these aircraft require technicians who hold an FAA A&P mechanic certificate.

The need for local technicians overseas who hold an A&P certificate is not just due to U.S. air carriers maintaining aircraft in foreign countries. Even an overseas maintenance provider holding an FAA repair station certificate may require many technicians hold an FAA A&P certificate. This is especially true for inspectors, return-to-service technicians, supervisors, and managers. The process for non-U.S. citizens to prepare and test for the FAA A&P certificate is different from their U.S. citizen counterparts.

For any foreign mechanic it’s a challenge to meet the FAA requirements of Part 65 subparts A and D. Applicants for a mechanic certificate must meet all the same requirements as their counterparts in the United States, and must be able to read, write, speak, and understand English. The current edition of Advisory Circular (AC) 60-28, English Language Skill Standards Required by 14 CFR parts 61, 63, and 65, states for all certification testing, the applicant needs to read a section of a technical manual, and then write and explain his/her interpretation of the reading. (An appropriate technical manual in this sense means an airplane flight manual, maintenance manual, or other publication as appropriate for the certificate or rating sought.) FAA inspectors will determine this before endorsing an applicant to take the written tests.

Even if an FAA inspector endorses a foreign applicant, the Designated Mechanic Examiner (DME) makes the final decision if the applicant can in fact read, write, speak, and understand English. If a DME cannot understand the applicant’s English during testing they fail the applicant and send the paperwork back to the FAA to be processed.

There are two ways a foreign applicant can obtain an A&P rating:

1. The International Field Office (IFO) performs certification only for applicants located outside the United States for Part 65 Mechanic Certificates/Ratings where the English language is not required. Note: The oral and practical tests are administered by an inspector or examiner in the applicant’s language, or through the use of a neutral interpreter selected or accepted by the inspector or examiner. (Reference FAA Order 8900.1 Vol. 5, Chapter 5, Section 3.)

2. A foreign applicant located in the United States that meets the English language and experience requirements can be endorsed at any FAA Flight Standard District Office (FSDO). (Reference FAA Order 8900.1 Vol. 5, Chapter 5, Section 2.)

Almost all foreign applicants will come to the United States to be endorsed. This process is very expensive for the applicant costing as much as $10,000 or more. As a former FAA inspector and now a DME, I have worked both sides of this process through completion and it can be challenging with some applicants. The FAA inspector will perform an initial interview over the telephone with an applicant to determine their English ability and understand their experience. If the FAA inspector determines the applicant may meet the requirements, an interview date and time is scheduled. The foreign applicant must bring current photo ID, usually their passport.

Experience requirements

Developing a comprehensive portfolio with detailed documents for all work experience, training and education, and other certificates held, is a key part of the process. Documents should describe the type of hands-on work experience performed including dates and specific tasks. Many applicants include copies of work cards they have completed and signed-off. The portfolio is a personal history book and used to determine if the applicant meets Part 65 subparts A and D. The FAA inspector should explain to the applicant what he/she wants to see at the initial interview.

Section 65.77 requires the applicant to have documented practical experience in maintaining airframes and/or powerplants. At least 18 months of practical experience is required for the rating requested. For a certificate with both ratings, the requirement is at least 30 months experience concurrently performing the duties appropriate to both ratings. If the 30 months experience concurrently performing the duties appropriate to both ratings has not been met, then the FAA inspector will calculate each rating separately using the 18-month requirement for each.

Foreign military experience is acceptable toward authorization to take the knowledge test based on the context of 65.77. The applicant must present verifiable documentation from the foreign military or government substantiating the experience. Foreign military experience on aircraft that are not manufactured to U.S. standards is acceptable; the experience still has to meet the requirements of 65.77.

Foreign and U.S. applicants alike who have not graduated from an FAA-approved Part 147 AMT program must present documents from an employer, co-worker, or other sources satisfactory to the Administrator to establish the required record of time and experience.

1. Documented experience directly applicable to the certificate and ratings sought. The applicant must have verifiable experience in 50 percent of the subject areas listed for the rating sought (see Part 147, appendices B, C, and D) in order to be eligible.

2. The FAA inspector must evaluate the documents submitted to determine the applicants’ eligibility for a test authorization. There is no expiration for this eligibility.

After passing the written exams, the foreign applicant must take the practical test with a DME located in the United States; there is no exception to this rule.

The view from Japan

Here in Japan the Japan Civil Aviation Bureau (JCAB) license can only be obtained by attending a certified Japanese aviation school. Most of the instructors are former aviation mechanics of airlines or from the Japan Self Defense Force (JASDF). Students study aircraft systems, repair methods, and more to obtain a Level 2 basic aviation mechanic license. The Japanese mechanic license has many classifications broken down in levels one and two based on experience, aircraft weight, types, and purpose of use. Level 1 is an apprentice and Level 2 is a journeyman.

To enter the Japanese training school prospective students must pass a very difficult entrance exam unlike the U.S. Part 147 programs where no initial testing is required. The program teaches practical subjects for three years (about 1,350-hours per year) and is set up very much like a Part 147 school. Most foreign A&P applicants I have worked with are highly trained with years of work experience and are second to none when it comes to maintaining aircraft to the U.S. standards for safety. General or business aviation, air carrier or MRO, aviation is an increasingly global industry and non-U.S. citizen A&P certificated mechanics are necessary to support it. AMT

 

Denny Pollard was the FAA maintenance field Inspector of the Year in 2004 and holds the ratings Airframe and Powerplant (A&P), Senior Parachute Rigger and two authorizations — Designated Mechanic Examiner (DME) and Inspection Authorization (IA). He teaches an accepted Inspection Authorization refresher course on behalf of the FAA. He is an author of two aviation books, both of them have sold worldwide and reflect his devotion and interests in aviation safety.

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