The FAA has issued a proposed policy change that would clarify the definition of the words "actively engaged" as they relate to application for and renewal of the Inspection Authorization (IA) certificate. Airframe and powerplant mechanics (A&Ps) can qualify to take the IA test if they have held their mechanic certificate for at least three years and have been "actively engaged" as a mechanic for the previous two. The two-year actively engaged requirement also applies to IAs who seek to renew their certificate, which expires after two years. According to the FAA, "an individual must be actively engaged, for at least the prior two-year period, in maintaining aircraft to be eligible to either obtain or renew an IA." In the past, FAA aviation safety inspectors (ASIs) have allowed IAs who don't work on the shop floor or who clearly don't work full time with aircraft to renew after complying with the minimum annual eight-hour training requirement. The FAA is soliciting comments on the proposed policy change, and these are due by December 6.
The plans to change the policy began in 1988. Before then, the FAA applied a full-time-employment-in-aircraft-maintenance standard to the definition of actively engaged. The FAA allowed ASIs to evaluate part-time employment on an individual basis. After 1988, the agency issued new guidance "tightening the definition of actively engaged to include only those individuals employed full-time in inspecting, supervising, overhauling, repairing, preserving or replacing parts on certified aircraft," according to the FAA. In April this year, the FAA rescinded that policy because it found that it was applied inconsistently. The new policy change is a result of efforts to clarify the situation.
One estimate, from a commenter on the new policy, puts the number of IAs at about 22,000 and suggests that 60 percent of these IAs are not employed full-time. Like flight instructors, many IAs maintain their certificate's currency because once it lapses, they must endure an onerous process to regain the certification. However, flight instructors can renew their certificates every two years by either qualifying a minimum number of new pilots or by completing 16 hours of training. IAs must not only meet the minimum qualifying requirement (a certain number of inspections and/or major repairs or alterations or 16 hours of training every two years) but also the actively engaged standard. There is no similar actively engaged requirement for flight instructors. Many in the aviation maintenance community have long worried that if the FAA seriously examined whether IA renewal applicants were truly actively engaged in aircraft maintenance, a large number would not meet the strict requirement and would be forced to give up their IA certificate.
It should be noted that FAA regulations also stipulate that an IA is effective only if the holder's A&P is kept current. For A&P mechanics, the definition of currency is again much stricter than that required of pilots. Mechanics must in the preceding 24 months either have been found able to do the work by the FAA or for at least six months have served as a mechanic, technically supervised other mechanics or supervised in an executive capacity the maintenance or alteration of aircraft (or a combination of these). If IAs are not working at an aircraft maintenance facility, the FAA could easily call into question the likelihood of their being current as A&Ps, further threatening their IA certification and their careers.
The new policy could mean that many flight department or maintenance department managers might have to relinquish their IA certificates. While this might not seem like a large issue to the FAA, some believe that it will have a negative effect on the morale of the maintenance community. The Aircraft Electronics Association (AEA) noted that it "is disappointed with this 'labor saving' initiative. For decades, the FAA, as well as industry, has been frustrated by the lack of career recognition of the airframe and powerplant mechanic. And now, the FAA proposes to remove this recognition from those who are in senior management positions with corporate flight departments, repair stations and air carriers who are not exercising their A&P privileges to 'inspect, overhaul, repair, preserve or replace parts on aircraft.'"
The AEA also pointed out that the new policy includes a "carve-out" that exempts FAA ASIs from the FAA's own policy. According to the FAA, "Order 8900.1 restricts the types of maintenance that ASIs can perform because of ethical concerns. The FAA does not intend for ASIs to lose their IAs because of these limitations."
While the new policy doesn't exclude part-time mechanics from retaining their IA and allows ASIs to evaluate the quality of the maintenance performed instead of the volume, it fails to address those who aren't working on aircraft but are employed in management positions. And as the AEA noted, the policy doesn't address the fact that the IA has become a career stepping stone for A&P mechanics and an important form of recognition and career development.
In comments posted to the docket on the proposed policy, a San Antonio FAA FSDO ASI noted, "There needs to be some real, objective guidance for the ASI. It would be helpful to have metrics of some sort. Examples of what is acceptable and what is not would be extremely helpful."
Another commenter wrote, "Problems will exist where the ASI may not properly determine equally or fairly whether an applicant is qualified. This procedure does not exist for the CFI renewal. For example: A [flight instructor refresher clinic] will renew a CFI no questions asked. Why would the FAA now require an extensive procedure to renew an IA when the eight-hour approved course is successful? I believe it will open the door for harassment and problems for the industry."
With regard to the carve-out for FAA ASIs who hold the IA, explained another commenter, "If an ASI would like to keep his IA he should have to follow the same rules as all IAs have to follow. There should not be two rules for maintaining an IA due to who the individual is employed with. The rules already confirm this and do not need to be changed to benefit a certain group of IAs. This is unfair and unethical. And it does not maintain the standard of professionalism we all strive to achieve."
Aviation associations–including the NBAA, NATA, AEA, Professional Aviation Maintenance Association and AMTSociety–are aware of the proposed policy change and are developing their own comments to add to the docket. Anyone who wishes to can petition the FAA for a rulemaking change to align the IA renewal requirements with those for flight instructors on the FAA's Web site.