A & P/ IAs, Get ready to justify the use of your Privileges

[51fixer]

1st is Aircraft Registration.
Now it is your A&P/IA.
Next your PPL?


From a local PAMA chapter leader-

FAA to Restrict A & P Recognition

SUBJECT: FAA to Restrict A & P Recognition

SUMMARY: The FAA has issued a policy which is intended to clarify the
definition of ''Actively Engaged'' for purposes of issuing and renewing the
A & P Inspector Authorization.
[Federal Register
<http://r20.rs6.net/tn.jsp?llr=ox9kgedab&et=1103909052608&s=1141&e=001Kj99hH
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Fu> ]

MAJOR HIGHLIGHTS: This FAA action proposes to clarify the term ''actively
engaged'' for the purposes of application for and renewal of an inspection
authorization, as contained in Flight Standards Management System Order
8900.1.

Of particular interest to AEA members is the criteria contained below:

Note:
Actively engaged means exercising the privileges of an airframe and
powerplant mechanic certificate in the maintenance of civil aircraft.
Applicants who are employed full-time in inspecting, overhauling, repairing,
preserving, or replacing parts on aircraft are considered to be actively
engaged.

Applicants who are employed or participate in inspecting, overhauling,
repairing, preserving, or replacing parts on aircraft on a part-time or
occasional basis will be evaluated by the ASI to determine whether the
applicant is actively engaged. The ASI will evaluate the scope of part-time
or occasional activity based on the type of maintenance activity, including
any special expertise required, and the quantity of maintenance activity
performed. To evaluate the scope of the part-time or occasional maintenance
activity, the ASI will use evidence or documentation provided by the
applicant showing inspection, overhauling, repairing, preserving, or
replacing parts on aircraft.

Comments must be received on or before Dec. 6, 2010, through the Federal
eRulemaking Portal:
http://www.regulations.gov
<http://r20.rs6.net/tn.jsp?llr=ox9kgedab&et=1103909052608&s=1141&e=001Kj99hH
0E7ze4dQ-r2DPc1LDAa_4zGn8_NEcQETNkf2hm95gfOZPvSUvnav_sXq9Yn6OyOzhq7Xf7BVjupk
6soZCzSStwD_pVFaQywGOuA9d0dxzXS7xSUw==> .

You may send comments identified by docket number FAA-2010-1060.

AEA COMMENTARY:
The Association 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."

In an unprecedented addition, the FAA, while minimizing the recognition of
publically employed A & P mechanics, has exempted its own employees from
this flawed policy.

According to this proposal, because other FAA policy limits the type of
maintenance that ASIs can perform (they may only exercise their IA on their
personal, non-commercial aircraft), the FAA employees are exempt from this
new policy, and "an ASI may renew an IA regardless of volume of maintenance
work performed."

AEA encourages every member who may be affected by this policy to send
comments to the FAA.

For More Information:
Contact Ric Peri, vice president of government and industry affairs for the
AEA, by e-mail at ricp@aea.net or by phone at 202-589-1144.

[CH2Tdriver]

Rich,

For those of us who aren't A&P/IA's could you clarify the issue here? What exactly is involved when you renew your ticket? Are you saying that unless you are employed full time, that the FAA has to review your sign off's and they alone determine if the amout of work you did is suitable for a renewal?

Does an A&P have other avenues for renewal?

As a CFI I instruct freelance/PT and only have a few students a year. EVery two years I have to renew at a clinic which costs $200. IF I had numerous sign offs (I think 8?) over that period, I could go to the FSDO with that info and they would renew it on that basis.

Does an A&P have similar options? I'm interested as any time I hear of FAA draconian tactics my ears perk up.

Pete

[Enemy Ace]

From what I have been reading about this, I think the primary effect this rule will have will be to discourage any A&P's who have left the aviation world from returning.
I would say that during hard economic times like we have been having, most of the certified A&P's are not working out at the airport. They take refuge at car dealerships, handyman services etc. to keep their heads above water when there is nothing going on at the airport.
So, if a mechanic is laid off then he has to jump through regulatory hoops to come back to work later? Not gonna happen with most of the guys I know.....They will just stay working outside of Aviation.
Last time I checked there was a technician shortage. This Rule is not going to help matters.
-Robert

[Matt Gunsch]

Nasty comment left...............

[51fixer]

Rich,

For those of us who aren't A&P/IA's could you clarify the issue here? What exactly is involved when you renew your ticket? Are you saying that unless you are employed full time, that the FAA has to review your sign off's and they alone determine if the amout of work you did is suitable for a renewal?

Does an A&P have other avenues for renewal?

As a CFI I instruct freelance/PT and only have a few students a year. EVery two years I have to renew at a clinic which costs $200. IF I had numerous sign offs (I think 8?) over that period, I could go to the FSDO with that info and they would renew it on that basis.

Does an A&P have similar options? I'm interested as any time I hear of FAA draconian tactics my ears perk up.

Pete

This is primarily aimed at the A&P requirements to keep the IA privileges current.
There is an annual performance requirement of 4 annuals or 8 major repairs or alterations as reported on 337 forms or Supervise a Progressive Inspection or attend an 8 hour approved course. This is done each year but renewal now takes place on a bi-annual basis.
In the past actively engaged only pertained to qualifying for 1st applying for the IA Privilege,

IA FAR section reads thus-
§ 65.91 Inspection authorization.

(a) An application for an inspection authorization is made on a form and in a manner prescribed by the Administrator.

(b) An applicant who meets the requirements of this section is entitled to an inspection authorization.

(c) To be eligible for an inspection authorization, an applicant must—

(1) Hold a currently effective mechanic certificate with both an airframe rating and a powerplant rating, each of which is currently effective and has been in effect for a total of at least 3 years;

(2) Have been actively engaged, for at least the 2-year period before the date he applies, in maintaining aircraft certificated and maintained in accordance with this chapter;

(3) Have a fixed base of operations at which he may be located in person or by telephone during a normal working week but it need not be the place where he will exercise his inspection authority;

(4) Have available to him the equipment, facilities, and inspection data necessary to properly inspect airframes, powerplants, propellers, or any related part or appliance; and

(5) Pass a written test on his ability to inspect according to safety standards for returning aircraft to service after major repairs and major alterations and annual and progressive inspections performed under part 43 of this chapter.

An applicant who fails the test prescribed in paragraph (c)(5) of this section may not apply for retesting until at least 90 days after the date he failed the test.


§ 65.92 Inspection authorization: Duration.

(a) Each inspection authorization expires on March 31 of each odd-numbered year. However, the holder may exercise the privileges of that authorization only while he holds a currently effective mechanic certificate with both a currently effective airframe rating and a currently effective powerplant rating.

(b) An inspection authorization ceases to be effective whenever any of the following occurs:

(1) The authorization is surrendered, suspended, or revoked.

(2) The holder no longer has a fixed base of operation.

(3) The holder no longer has the equipment, facilities, and inspection data required by §65.91(c) (3) and (4) for issuance of his authorization.

(c) The holder of an inspection authorization that is suspended or revoked shall, upon the Administrator's request, return it to the Administrator.

§ 65.93 Inspection authorization: Renewal.

(a) To be eligible for renewal of an inspection authorization for a 2-year period an applicant must present evidence during the month of March of each odd-numbered year, at an FAA Flight Standards District Office or an International Field Office, that the applicant still meets the requirements of §65.91(c) (1) through (4). In addition, during the time the applicant held the inspection authorization, the applicant must show completion of one of the activities in §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:

(1) Performed at least one annual inspection for each 90 days that the applicant held the current authority; or

(2) Performed at least two major repairs or major alterations for each 90 days that the applicant held the current authority; or

(3) Performed or supervised and approved at least one progressive inspection in accordance with standards prescribed by the Administrator; or

(4) Attended and successfully completed a refresher course, acceptable to the Administrator, of not less than 8 hours of instruction; or

(5) Passed an oral test by an FAA inspector to determine that the applicant's knowledge of applicable regulations and standards is current.

(b) The holder of an inspection authorization that has been in effect:

(1) for less than 90 days before the expiration date need not comply with paragraphs (a)(1) through (5) of this section.

(2) for less than 90 days before March 31 of an even-numbered year need not comply with paragraphs (a)(1) through (5) of this section for the first year of the 2-year inspection authorization period.

(c) An inspection authorization holder who does not complete one of the activities set forth in §65.93(a) (1) through (5) of this section by March 31 of the first year of the 2-year inspection authorization period may not exercise inspection authorization privileges after March 31 of the first year. The inspection authorization holder may resume exercising inspection authorization privileges after passing an oral test from an FAA inspector to determine that the applicant's knowledge of the applicable regulations and standards is current. An inspection authorization holder who passes this oral test is deemed to have completed the requirements of §65.93(a) (1) through (5) by March 31 of the first year.

§ 65.95 Inspection authorization: Privileges and limitations.

(a) The holder of an inspection authorization may—

(1) Inspect and approve for return to service any aircraft or related part or appliance (except any aircraft maintained in accordance with a continuous airworthiness program under part 121 of this chapter) after a major repair or major alteration to it in accordance with part 43 [New] of this chapter, if the work was done in accordance with technical data approved by the Administrator; and

(2) Perform an annual, or perform or supervise a progressive inspection according to §§43.13 and 43.15 of this chapter.

(b) When he exercises the privileges of an inspection authorization the holder shall keep it available for inspection by the aircraft owner, the mechanic submitting the aircraft, repair, or alteration for approval (if any), and shall present it upon the request of the Administrator or an authorized representative of the National Transportation Safety Board, or of any Federal, State, or local law enforcement officer.

(c) If the holder of an inspection authorization changes his fixed base of operation, he may not exercise the privileges of the authorization until he has notified the FAA Flight Standards District Office or International Field Office for the area in which the new base is located, in writing, of the change.

[robkamm]

I have a A&P only. do i need to do anything? im non currently working in the field other than on my own stuff. Im in the Auto repair field.thanks for the info .

[51fixer]

I have a A&P only. do i need to do anything? im non currently working in the field other than on my own stuff. Im in the Auto repair field.thanks for the info .

Shouldn't affect you at this time.
Not until they want to purge non active mechanics and airmen from the register.

[51fixer]

More info at AMT online and directions to the GOV site for comments-

http://www.amtonline.com/interactive/20 ... o-clarify-“actively-engaged”/

They have given just a 30 day period for comments on this. EAA has requested an extension.
Please post a comment. They need to be flooded with responses.

The IA has been a very important part of Aviation for many decades.
Many Warbirds that are Standard Category registered, (P-51/T-6- ect), rely on part time IA's for annuals and repair sign offs.
This proposal puts a possibly arduous task on a semi retired or part time aircraft mechanic to be able to convince an ASI at an FSDO that he really needs to keep his IA.
I know of several semi retired aircraft mechanics who have decades of experience. That knowledge is useful in dealing with older aircraft that are rarely seen or worked on by newer mechanics or by those who work in shops that don't repair P-51s or the like.
Under this proposal they might not qualify for the IA they currently have. They would then have to get an ASI at the FSDO to allow them to keep the IA. That could be a big issue.
This will increase the workload at the FSDO for their ASI's.
Currently an IA doesn't have to perform the actual work. He is responsible to "Return To Service" an aircraft after an Annual Insp or after a Major Repair or Alteration. This is a process that involves inspection, research, compliance with FARs, manuals and mfg instructions, ect. It is often more paperwork than actual mechanical work.
It seems the FAA has the perspective that an Mechanic that is working full time maintaining aircraft and currently involved in manufactures and industry training on a ongoing basis is the only one that can qualify for the IA. All others will have to petition the local FSDO for it's blessing.
This will include many corporate mechanics, (many corporate bizjets have a type of inspection program that doesn't require an IA to return the jet to service after maint.) who the FAA can say you don't need the IA and most of your work is done by a service center so you don't qualify for the IA. Many of those had to have an IA to even apply for that job even though an IA isn't required to perform the job.
The IA is one of the highest ratings in aviation. It isn't helpful to all of the various types of aircraft operation that the FAA wants a one size fits all type of person for the important position that is the IA.
Again, please post a comment on the GOV site.

[skymstr02]

Currently an IA doesn't have to perform the actual work. He is responsible to "Return To Service" an aircraft after an Annual Insp or after a Major Repair or Alteration. This is a process that involves inspection, research, compliance with FARs, manuals and mfg instructions, ect. It is often more paperwork than actual mechanical work.

That is a wrong statement. The regulations clearly state that inspections shall not be delegated, and must be performed by the certificate holder.

If you want to get your pee-pee in a wringer with the Federalies, tell your POI thats what you do.

[51fixer]

Currently an IA doesn't have to perform the actual work. He is responsible to "Return To Service" an aircraft after an Annual Insp or after a Major Repair or Alteration. This is a process that involves inspection, research, compliance with FARs, manuals and mfg instructions, ect. It is often more paperwork than actual mechanical work.

That is a wrong statement. The regulations clearly state that inspections shall not be delegated, and must be performed by the certificate holder.

If you want to get your pee-pee in a wringer with the Federalies, tell your POI thats what you do.

To clarify, the mechanical work to repair or rectify any mechanical deficiency isn't the IA's function or requirement even if it involved with an annual or major repair.
The inspection is the duty of the IA in regards to the return to service.
If the IA finds a frayed cable while inspecting an aircraft for an annual inspection. If he is there to inspect the aircraft in regards of an annual he informs the owner (and hopefully the mechanic, but the FARs do not require this) of a list of items that need repair or be rectified. The IA doesn't have to be the one to replace the cable.
If the IA is called in to return an aircraft to service for an annual that aircraft typically has been looked over by an A & P 1st and everything wrong hopefully has been fixed when the IA shows up. The IA function is different than a mechanics function in this sense. There is nothing to stop an IA from doing both the repair and inspection functions, after all the IA was an A & P for at least 3 years before adding the IA privileges and is still an A & P to keep the IA.

In the above skymstr02 copied from my previous post I did say this about an IA's duty-
"This is a process that involves inspection, research, compliance with FARs, manuals and mfg instructions, ect."
I didn't infer the inspection was to be delegated just that the IA doesn't have to do the work the IA is signing off.

[walkerarmyairfield]

Wonder if I will get a patt down at the free IA refresher meeting this year in March. Would hate to be starting out in Aviation today. Aviation has been fun over many years but things starting not be fun anymore. Even the EAA is teaming up with the AMA model airplane folks to try to keep things growing. The FAA inspectors that were once helpful are hard to find nowdays. When you go to flyins and see all the gray and white hair this tells you something. Old General Aviation going the way of Big Block Chevrolets and Corvettes.
Phillip

[engguy]

I disagree with the above statement.

How far are you going to break down the priveleges? Airframe metal, airframe fabric, airframe composite, aircraft pressurized/non-pressurized?

The FAA does not need to cater to the current/former military for certification purposes. Either they can pass the tests or not. There are many training opportunities to get the required education in regards to reciprocating engine theory and maintenance, some of which are paid by the military.

Don't get me wrong, I appreciate their service to the country, but in many cases, military aircraft maintenance is not the same as civil aircraft maintenance, and military protocol does not have a place in civil aircraft maintenance.

We do not want to get into the quagmire like Canada and the Europeans where we have to have an endorsement for each type model and series airplane.

This is one reason that the proposed FAR part 66 failed back in the 90's. That's where we would have been heading.

Back on topic, I know of one individual that holds an IA, and is a full time physician. Where does "actively" engaged in aircraft maintenance come into play here? What was going thru the mind of the FAA inspector that reviewed his application and approved it for testing?

The main thing is there is absolutly zero relationship between a recip engine and a turbine engine in operation or mechanics and service techniques, other than heat and some form of power extracted from them. What mechanical practices that apply to one does not apply to the other, (well yeah bolts and lockwire, dimensional measurements etc), they are completly separate entitys.
Just like the avionics is separate from airframe or engine, so should be Jet/Turbine and Reciprocating since again they are no more related to eachother than a resistor is to a rivet from a mechanics point of veiw. That is why they should each be a different rating. In the end, depending on what type of engine that a AP ends up servicing during his/ her life, any knowlege or experience gained learning the unrelated one, will be lost anyway. And it seems the FAA is concerned about the knowlege and skill loss with this latest move on AP licenses.
And the how far to break down comment? Airframe is just that AIRFRAME. And the smart guys at the FAA figured out that there should be a separate rating for it and the engine, since again in no way are they RELATED any more, again than electronics is to the mechanics of either engine or the mechanical practices of airframe mechanics.
The Key here is Related. It makes more sense to separate the 2 engine types and expand into accessory within each class, than to mix and confuse the 2 engine types. If anyone here can relate a Reciprocating firing order and the associated timing, with a turbine engine then I will shut up.

[robkamm]

so according to you we should split up CPAs, lawyers etc anything with a certification?. they are all doing similar jobs but different. come on now. What do you do so we can discuss how to take away your college degree /schooling you did to be were you are today.

[airknocker]

The latest from the Feds:
http://www.eaa.org/news/2010/2010-11-24_ia_policy.asp

[engguy]

so according to you we should split up CPAs, lawyers etc anything with a certification?. they are all doing similar jobs but different. come on now. What do you do so we can discuss how to take away your college degree /schooling you did to be were you are today.

Well if you needed your heart operated on I'm sure you would rather a heart specialist than someone that spent most of their time learning how to remove toe nails!

Yes as far as power plants it should be a speciality thing. Either you know how to deal with say timing a cam and setting the proper ignition advance, or you know how to properly install a turbine blade on a jet .
So would you like to have a guy that has worked his whole AP life on small cessna's and the engines, suddenly working on the jet engines you are about to be pushed through the sky on? Yeah he learned about them things in school or maybe he never even saw one in real life, since he learned the old fashioned way on the job, at an FBO that had only cessna's, and studied the book real good to past the test.