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FAA Clarifies ‘Actively Engaged’ For Inspection Authorization Renewals
August 10, 2011
Noting there has been widespread misunderstanding of the term “actively engaged” for renewing an aircraft maintenance professional’s Inspection Authorization (IA), the Federal Aviation Administration (FAA) on August 4 issued a long-awaited clarification.
The enhanced definition will become effective with the next IA renewal expiration date of March 31, 2013. IA holders have the authority to sign off on aircraft annual inspections and “return to service” statements after major repairs or alterations.
The clarification of “actively engaged” in maintenance work added specifics to the definition, and for the first time stated clearly that supervisory personnel and managers could be eligible for IA renewal based on their role in the maintenance operation. NBAA has advocated for that addition, believing that the lack of specific guidance had led some FAA inspectors to define the term narrowly and deny renewals to those individuals.
The FAA’s clarification also affirmed that attendance at an eight-hour maintenance seminar would not automatically qualify an IA holder for renewal without also satisfying 65.91(c)(1) – (4), as many IAs had mistakenly believed. Those sections require an applicant to have held an A&P certificate for at least three years and have been actively engaged in aircraft maintenance for the prior two years. The applicant must also have a fixed base of operation and have the equipment, facilities and technical data to properly inspect aircraft and accessories.
“The FAA has adopted a broad definition of ‘actively engaged’ in maintenance to include not only part-time employment but also occasional activity which does not requirement employment,” the notice read. “As indicated in the proposed policy, the FAA values the substantive nature of experience rather than a strict quantity formula.”
The new wording will be added to FAA Order 8900.1, which gives guidance to FAA Aviation Safety Inspectors (ASI) for issuing or renewing IAs. The note will say:
“Actively engaged means an active role in exercising the privileges of an airframe and powerplant mechanic certificate in the maintenance of civil aircraft. Applicants who inspect, overhaul, repair, preserve, or replace parts on aircraft, or who supervise (i.e., direct and inspect) those activities, are actively engaged. The ASI may use evidence or documentation provided by the applicant showing inspection, overhauling, repairing, preserving, or replacing parts on aircraft or supervision of those activities. This evidence or documentation when required could include employment records showing performance or supervision of aircraft maintenance, return to service documents and or copies of maintenance record entries.”
The clarification was the outcome of the FAA’s notice of proposed policy, published in November 2010, which drew more than 950 comments.
“We thank the FAA for adding clarity to the definition and including NBAA’s suggestion for adding supervisory and management personnel in the revised guidance,” said NBAA President and CEO Ed Bolen.