In no other occupation is there a requirement to be actively engaged, I feel it is wrong to have the requirement on aircraft technicians with an inspection authorization and quite possibly could be challenged in court, when compared to other safety sensitive occupations.
Pilots do not face losing their license and having to retest if they do not maintain a full time job. Just in case you are wondering, the FAA is defining a full time job (actively engaged) as 2080 hours per year. If you look at the hours that some flight departments are flying you have to ask, how in the world can a pilot flying 150 hours a year or less be proficient and actively engaged? In fact, a pilot can go for years and never fly, get a flight review and medical and fly again never having to retest. You cannot argue that a bi-annual flight review is the same as a test; I know this because I have had several. In fact doctors that we trust with our life, never risk losing their certification based on time in their practice. Neither do nurses, lawyers, medical technicians, truck drivers or any other profession. Yet an aircraft technician laid off from his job, changing location, suffering from an extended illness, can have his IA taken away, and have to retest. No other profession does this. I believe that training or getting recurrent (FAA IA renewal seminars) have been accomplishing the desired results. Just to show how completely ludicrous this policy is, the FAA has granted an exemption for its own employees.
This being said I like to see older technicians showing up at IA renewal seminars, it shows that mechanics and pilots (yes many pilots hold an A&P, IA) work in aviation for the love of the flying, not just the pay check.
Maybe the real question should be is, should the phrase “actively engaged” be removed completely from the FAR’S.
Tim Begeot A&P, IA, SEL, ATS