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Vintage Aircraft Online
Special Issue 11  November  2010

Part Time Inspector Rule Change Raises Alarms
Public comments on proposal welcomed through December 6

Inspection EAA and the Vintage Aircraft Association this week quickly moved for FAA clarification on a policy proposal that is causing confusion among maintenance professionals and owner/operators who rely on a part-time Airplane and Powerplant (A&P) mechanic with an Inspection Authorization. A number of members have contacted EAA and two of its special interest divisions, the Vintage Aircraft Association (VAA) and EAA Warbirds of America, fearing that the proposal could mean the end of Inspection Authorizations for part-time mechanics.

The primary concern was that the revised policy would allow an FAA Air Safety Inspector (ASI) to subjectively reject an application for an Inspection Authorization, or its renewal, if that ASI deems his or her level of mechanic’s work does not meet the FAA standard for “actively engaged.”

As published in the November 5, 2010, issue of the Federal Register, Docket No. FAA-2010-1060, the “Policy Clarifying Definition of ‘Actively Engaged’ for Purposes of Inspector Authorization” is intended to provide an ASI with a more tightly defined definition of “Actively Engaged.”  The FAA intends to enforce the new policy when the IA renewal cycle begins on March 31, 2011.

H.G. Frautschy, executive director of VAA, contacted the FAA’s Flight Standards Service - General Aviation & Avionics Branch, for further clarification.  This FAA division “owns” the policy related to Inspection Authorizations.

Frautschy inquired, “If a part-time A&P-IA satisfies the requirements set forth in 14 CFR §65.91 and §65.93(a), para. 1-5, are they deemed to be ‘actively engaged’?”

“Yes, absolutely,” the FAA stated, and further explained that the proposed policy clarification is meant to make the decision more objective, removing any ambiguity related to the definition of “actively engaged.” If a mechanic meets the requirements set forth in the Code of Federal Regulations, an ASI is directed by the Flight Standards Information Management System, FAA Order 8900.1 Volume 5, Chapter 5, to issue the Inspection Authorization.

To put it simply, if your activity meets one of the five different criteria outlined in 65.93, you’re “actively engaged” in the FAA’s eyes. 
For certain segments of the General Aviation community and many EAA members, the part-time A&P-IA is the backbone of a deeply knowledgeable corps of mechanics who have solid expertise within a certain aircraft type.  Since they often have a very high level of knowledge regarding vintage or warbird aircraft, their abilities to “keep ‘em flying” are prized among owners.

EAA  members are urged to review the proposed policy, check with their IA, and submit comments to the Federal Docket no later than December 6, 2010.  For additional information and continuous conversations on this topic, visit Oshkosh365. Further updates will also be included in future issues of EAA’s online newsletters, e-Hotline, Vintage Aircraft Online, and Warbirds Briefing.

We welcome your comments and suggestions to vintageaircraft@eaa.org.
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