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August 8, 2011
By Dan Namowitz
The FAA has adopted many of AOPA’s recommendations for its newly published policy to clarify the term “actively engaged” as it is used for purposes of airframe and powerplant mechanics’ inspector authorizations (IA).
The FAA issued the clarifying language in a notice of policy Aug. 4 in the Federal Register. AOPA reported Nov. 11, 2010, that the FAA planned to write a formal definition of the term, which has generated confusion in its application. The clarification will affect IA renewals as of the March 2013 renewal cycle.
The FAA said it accepted AOPA’s request for the clarification to specifically address individuals engaged in personal aircraft maintenance, as well as retired mechanics providing occasional or relief maintenance; individuals providing maintenance in rural areas; and those offering specialized expertise in electrical, composites, and rare or vintage aircraft.
“The FAA also values the experience of individuals who are available on a part-time or occasional basis to inspect vintage or rare aircraft or aircraft that may be located in rural areas of the country not serviced by an abundance of IAs. The FAA does not intend to eliminate eligibility or renewal opportunities of these individuals. Accordingly, the FAA has adopted a broad definition of ‘actively engaged’ to include not only part-time employment but also occasional activity, which does not require employment and can occur on an infrequent basis,” said the notice of policy.
The FAA also accepted the position that supervision meets the recency of experience requirements for an airframe and powerplant (A&P) certificate.
“The FAA will include technical supervision and supervision in an executive capacity on either a full-time, part-time, or occasional basis in the definition of actively engaged,” it said in the notice of policy. “A technical instructor or Part 147 school instructor may maintain aircraft or supervise the maintenance of aircraft in addition to instruction, in which case the instructor could be considered actively engaged. Individuals employed as a manufacturer’s technical representative, maintenance coordinator, or maintenance auditor also could be considered actively engaged depending on the activity demonstrated.”
AOPA is encouraged that the notice of revised policy has clearly been broadened to include as eligible for renewals those IAs who perform specialized or occasional maintenance inspections. How the policy will be implemented remains a concern, however, as specifics were not addressed in the “note” section being added to the guidance document. Maintaining a robust IA population benefits the GA community by lowering maintenance costs due to IA availability.
With the next IA renewal cycle coming in March 2013, it is important that aviation safety inspectors understand that even IAs that perform specialized or occasional maintenance inspections, who teach, or who have jobs requiring an IA but who do not directly perform inspections and maintenance are eligible for renewal, AOPA said.
Dan Namowitz is an aviation writer and flight instructor. He has been a pilot since 1985 and an instructor since 1990.
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