Part Time Inspector Policy Change Raises Alarms
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May 2011 - In the November 5, 2010 edition of the Federal Register the FAA presented a proposal to clarify the existing Airplane and Powerplant (A&P) Inspection Authorization (IA) renewal requirements and process. The unintended consequences that the proposed clarification of “actively engaged” appeared to create caused an uproar within the IA community, especially among the part-time, specialized, and supervisory IAs. As stated in an earlier VAA story (see below), the FAA was quick to respond to an inquiry by H.G. Frautschy, Executive Director VAA, that the proposed change was simply a proposal that was being considered and would not affect the current IA renewal period (ending on March 31, 2011). The FAA was equally quick to respond to and stop the application of that proposal when a few Flight Standards District Offices (FSDOs) attempted to implement it as a completed action. |
Randy Hansen, EAA Government Relations Director, recently contacted the FAA’s Flight Standards Service – General Aviation & Avionics Branch for an update on the status of the IA renewal process. The division stated that they had received a very high number of public comments, over 950, and are still in the process of reviewing them. When the review is completed they plan on publishing their responses to those comments in the Federal Register sometime prior to December 31, 2011. Updates to the IA renewal issue will be posted to VAA’s online newsletter, Vintage Aircraft Online, and to this VAA web site. November 17, 2010 – Public comments on proposal welcomed through December 6, 2010. 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 the Red Barn Forum within EAA’s Online Community at Oshkosh365. Further updates will also be included in future issues of EAA’s online newsletters, e-Hotline, Vintage Aircraft Online, and Warbirds Briefing. | |
