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Follow-Up: Changes to New IA Policy Clarified

August 25, 2011 – As promised in a previous story, EAA has followed up on a statement included in the FAA’s revised Inspection Authority (IA) policy slated to go into effect on September 6 that reads, “Refresher training attendance alone does not satisfy those (renewal) requirements.”

When published in the Flight Standards Information Management System (FSIMS) FAA Order 8900.1., Section 5, the revised section will read:

A. Application Requirements. Application for renewal may be required to complywith the following:

1) Show evidence the applicant still meets the requirements of §65.91(c)(1) through (4).
NOTE: Refer to Paragraph 5-1279(A)-(C) of this document for information onmeeting § 65.91(c)(1) through (4) requirements. Refresher training attendance alone does not satisfy those requirements.
2) Complete Federal Aviation Administration (FAA) Form 8610-1, Mechanic’s Application for Inspection Authorization, in duplicate.
3) Show evidence the applicant meets the requirements of § 65.93(a) forboth the first and second year in the form of an activity sheet or log, training certificates,and/or oral test results, as applicable.

According to the FAA, the requirement for other activity besides a refresher training course has always been an FAA regulatory requirement per FAR 65.93(a) that requires the applicant continue to be “actively engaged” as a mechanic by meeting FAR 65.91 paragraphs (c)(1) through (c)(4), but the documentation for that requirement has been inconsistently applied by the FAA field offices due to the previous definition lacking clarity. Part of the reason for issuing the revised policy is to make the requirement for “actively engaged” beyond the refresher course clearer. When revised the new language clarifying the definition of “actively engaged” within 8900.1 will read:

NOTE:Actively engaged means an active role in exercising the privileges of anairframe and powerplant mechanic certificate in the maintenance of civil aircraft.Applicants who inspect, overhaul, repair, preserve, or replace parts on aircraft, orwho supervise (i.e., direct and inspect) those activities, are actively engaged. TheASI may use evidence or documentation provided by the applicant showinginspection, overhauling, repairing, preserving, or replacing parts on aircraft orsupervision of those activities. This evidence or documentation when required couldinclude employment records showing performance or supervision of aircraftmaintenance, return to service documents, and/or copies of maintenance recordentries.

Technical instructors or individuals instructing in a FAA part 147 approved AMTschool, who also engage in the maintenance of aircraft certificated and maintained inaccordance with 14 CFR, can be considered actively engaged. Individualsinstructing in a FAA part 147 AMT school, who also engage in the maintenance ofaircraft-related instruction equipment maintained in accordance with 14 CFRstandards, can be considered actively engaged.

Read the second sentence carefully (we’ve put it in bold type); it does notquantify the amount of work that must be done - it simply states thatany of those activities is viewed by the FAA as “actively engaged.” In other words, if you touch an aircraft once a year to perform maintenance within the scope of practice as an A&P–IA, you’ve met the definition of “actively engaged” and need only to meet the requirements of 65.91 (the regulation under which an Inspection Authorization is initially issued)and 65.93 (a) (1), or (2), or (3), or (4) or (5) to be eligible for renewal.

65 93 reads, in part:

(a)…In addition, during the time the applicant held the inspection authorization, the applicant must show completion of one of the activities in Sec. 65.93(a) (1) through (5) below by March 31 of the first year of the 2-year inspection authorization period,and completion of one of the five activities during the second year of the 2-year period:

As explained to us by the FAA, this means that an A&P mechanic with an Inspection Authorization who performs a single annual, replaces a single part on an aircraft, supervises A&P activities, etc., each year (which means they are, as defined by the new note added to the policy, now “actively engaged”) and attends a yearly refresher course during each one-year period within the two-year renewal cycle (one of the five activities listed in 65.93 (a)) will be eligible for renewal of their Inspection Authorization. The requirements for activity have been met under 65.91 (c) (2), meaning that only one more of the follow-up requirements for renewal specified in 65.93 (a) 1 though 5 needs to be accomplished.

We’ll continue to monitor the implementation of the new policy published for the FAA’s Flight Standards Management System FAA Order 8900.1. We welcome feedback from members who are directly impacted by this policy to vintageaircraft@eaa.org, or you can post your comments on the VAA's Red Barn section of www.eaaforums.org.


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