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

June 19, 2013
Certificate foreign applicants located outside the United States for Title 14 CFR Part 65 mechanic certificates/ratings

As a follow up to my article Foreign (Non-U.S. Citizen) A&P Applicants in the May 2013 issue of Aircraft Maintenance Technology, I have been requested to discuss non-English speaking A&P mechanics with certificates “Valid Only Outside the U.S.”

Having a certificate “Valid Only Outside the U.S.” are special certificates and requires different procedures for both the FAA inspector, Designated Mechanic Examiner (DME), and the applicant.

After an applicant passes the written exams, the foreign applicant endorsed in the U.S. must take the practical test with a DME located in the United States in most cases. This only applies if you were signed endorsed by a Flight Standard District Office (FSDO) inspector. However, if you were endorsed by an International Field Office inspector (IFO) you can take the oral and practical test in your native language Outside the U.S. It sounds confusing, but keep reading.

FAA has procedures that are unique to foreign applicants located outside the United States.  The current edition of Federal Aviation Administration (FAA) Order 8900.2, General Aviation Airman Designee Handbook establishes certification policy.

This policy does not apply to foreign applicants in the United States. Any applicant who is in the United States and meets the English language and experience requirements is entitled to take the examinations for a mechanic certificate. The current editions of Advisory Circulars (AC) 65-2, Airframe and Powerplant Mechanic’s Certification Guide and AC 65-30, Overview of the Aviation Maintenance Profession provide further guidance regarding foreign applicants within the United States.

When foreign nationals are physically located outside the United States at the time of the examination, the FAA IFO inspector must determine that the mechanic certificate is needed for the continued airworthiness (maintenance) of U.S.-registered civil aircraft and that the applicant is neither a U.S. citizen nor a resident alien.

For an A&P authorization the FAA must determine the applicant’s ability to read, write, speak, and understand the English language. Applicants who do not meet this requirement but are employed outside the United States by a U.S. air carrier may be eligible if they present a certified statement (original document) from a company official or supervisor attesting to their employment status. Certificates issued to applicants shall be endorsed “Valid only outside the United States” and ensure the following are accomplished:

  1. The certificated U.S. air carrier has submitted documentation regarding the applicant’s employment status and need for certification.
  2. The knowledge test is accomplished in accordance with Order 8080.6 via the Computer Medium, current edition, as it relates to applicants who do not read, write, speak, or understand English.
  3. The oral and practical tests are administered by an inspector or examiner (DME) in the applicant’s language, or through the use of a neutral interpreter selected or accepted by the inspector or examiner.
  4. Applicants must be notified that the authorization to test is applicable only to Designated Mechanic Examiners (DME) who exercises privileges in the International Field Office (IFO) and the Flight Standards District Office (FSDO). Should the applicant wish to test with a DME in another district, additional FAA approval will be required.

The FAA must also determine the applicant’s experience eligibility. The FAA inspector must ensure foreign applicants provide a signed, dated, detailed statement substantiating the specific type and duration of experience.

  1. Determine that these statements come from both an employer and either the airworthiness authority of the country in which the experience was gained or an airworthiness advisor of ICAO.
  2. The FAA will not accept information that cannot be verified or documented. The FAA does require each document presented to verify experience to be a signed and dated original, traceable to the originator.
  3. If the foreign civil authority will not provide the statement listed above, the inspector may determine eligibility through whatever means he/she deems appropriate.

Note: If the applicant shows only foreign military work experience on aircraft that are not manufactured to U.S. standards, that is not an issue, the experience still has to meet §65.77.

In addition I should pointed out that Title 14 CFR part 187, appendix A, prescribes the methodology for computation of fees for certification services performed outside the United States. The actual fees are in the current edition of FAA AC 187-1, Flight Standards Service Schedule of Charges outside the United States. These fees will be charged to all applicants for such services outside the United States, whether U.S. citizens or foreign nationals. The payment of fees is addressed in §187.15. The IFOs do charge for all services outside the U.S. including A&P authorizations.

For additional information on foreign mechanics it can be found in FAA Order 8900.1 Volume 5, Chapter 5, Section 3 this order is available on the Internet at: http://fsims.faa.gov/.

At the time of this article there is one DME located in Germany that is allow to test foreign applicants out of the U.S. in his approved FAA testing facility. A DME can be approved to test in a foreign country if they have a facility, tools, and equipment that has been inspected and accepted by the IFO that has oversight of the host country. In addition the DME will have to pay a fee to the FAA for this inspection, which is passed on to the applicant or applicants as a cost of doing business in charging a reasonable fee for services in accordance with FAA Order 8900.2.

Denny Pollard is a retired FAA airworthiness inspector from the Western Pacific Region. He lives in Yamagata Prefecture, Japan, and can be reached at [email protected].

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.