The FAA has issued a Notice of Policy that clarifies the term “actively engaged” for the purposes of application for and renewal of an inspection authorization, and industry groups have expressed concerns about the definition. It states, “Actively engaged means an active role in exercising the privileges of an airframe and powerplant 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, overhauling, repairing, preserving or replacing parts on aircraft or supervision of those activities. This evidence or documentation when required could include employment records showing performance or supervision of aircraft maintenance, return-to-service documents and/or copies of maintenance record entries. Technical instructors or individuals instructing in an FAA Part 147-approved AMT schools, who also engage in the maintenance of aircraft certified and maintained in accordance with 14 CFR, can be considered actively engaged. Individuals instructing in an FAA Part 147 AMT school, who also engage in the maintenance of aircraft-related instruction equipment maintained in accordance with 14 CFR standards, can be considered actively engaged.”

Dale Forton, president of the Professional Aviation Maintenance Association (PAMA), told AIN, “We are unsure as to why this interpretation was issued from such an uninformed position. It is a very poor definition of actively engaged or actively involved. A FSDO in Texas defined it at a recent IA renewal by saying if an A&P worked as an instructor, was teaching in the aircraft field, pulling wrenches, completing aircraft records and logbooks, supervising maintenance or anything dealing with aircraft maintenance, regulations, etc., then he is actively engaged as far as they were concerned. The problem is the definition doesn’t include individuals involved in any training capacity, parts manufacturing, technical advice or regulatory even though they are still using their A&P skills and knowledge.”