Actively Engaged and Advanced Certification

Last November 5, the FAA issued Notice of Proposed Rulemaking (NPRM) 2010-1060, “Policy Clarifying Definition of Actively Engaged for Purposes of Inspector Authorization.” The original deadline for comments was December 6, but the FAA extended the comment deadline to January 17. Either deadline was too early for a call to action in this column, but I wanted to make some comments on the NPRM, Inspection Authorization, and advanced certification.

The intent of the NPRM was to clarify (for the FAA and industry) the definition of “actively engaged” as it relates to Inspection Authorization.

To help clarify “actively engaged,” the FAA proposed to amend FAA Order 8900.1, Volume 5, Chapter 5 as follows:

1. Amend Section 7, Paragraph 5-1279 by adding a Note after subparagraph A to read: 5-1279 ELIGIBILITY. The ASI must establish the applicant’s eligibility before allowing the applicant to test. None of the requirements of Title 14 of the Code of Federal Regulations (14 CFR) part 65, Sec.  65.91 can be waived by the ASI.

A. The applicant must hold a current mechanic’s certificate, with both airframe and powerplant ratings, that has been in effect for at least 3 years. The applicant must have been actively engaged in maintaining certificated aircraft for at least the 2-year period before applying.

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.

As of January 9, there were 83 comments to the NPRM. Most of the people commenting shared their concern that the definition clarification would leave many without the ability to renew their IAs because of their jobs as consultants, tech. support, executive management, or other non-wrench turning jobs. Some were upset that FAA ASIs were exempt from the requirement.

Then a thought hit me. Is this all about advanced certification?

You see, for years, Inspection Authorization was the only “advanced certification” A&P mechanics could obtain. We got our A&Ps, worked hard for at least three years honing our skills until we could take the test to reach the next level – getting our IA. It was a badge of honor. The late Bill O’Brien once called IAs the 800 pound gorillas in aircraft maintenance.

The problem is that obtaining an IA is often a stepping stone to other job opportunities. Some IAs move on to became maintenance controllers, teachers, consultants, sales reps or even writers. But as they transition out of their full-time maintenance jobs, they are often hesitant to give up their IA — their badge of honor. After all, it is the only “advanced certification” they have to show for their hard work, and they don’t want let it go, even though they aren’t exercising the privileges of the authorization and aren’t actively engaged in maintaining type-certified aircraft.

Is it unreasonable to suggest that if an IA isn’t actively engaged in aircraft maintenance and has no need to exercise the privileges of an IA that he or she surrender it?

We should turn our frustration to creating a clearer path for advanced certification in our career field. There are some industry efforts that have a good start and are building momentum. One is NCATT. It offers certification in avionics and other skills. Project Bootstrap is another plan for advanced certification that is pushing forward. Other certification efforts exist such as Master Aviation Educator accreditation by Master Instructors, LLC. 

So, is it all about advanced certification? If so, where do we go from here?

Thanks for reading, and we appreciate your feedback!   – Joe

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