The FAA has extended the date for responses from December 6 to January 17 on its recent Notice of Proposed Policy regarding IA renewal clarification. The Notice, which was published on November 5, would amend aviation safety inspector (ASI) guidance by clarifying the term “actively engaged” for the purposes of application for, and renewal of, an inspection authorization. The phrase is included in the FAA’s Flight Standards Management System Order 8900.1 Volume 5-1279 A Certification. According to the Notice of Proposed Policy, the definition of “actively engaged” would include 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. Part-time or occasional workers in these areas 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 and quantity of maintenance activity performed, including any special expertise required. The ASI will also use evidence or documentation provided by the applicant showing inspection, overhauling, repairing, preserving or replacing parts on aircraft. FAA regulations require that an individual A&P seeking inspection authorization “be actively engaged, for at least the prior two-year period, in maintaining aircraft to be eligible to either obtain or renew an IA.” In the past, FAA ASIs have allowed IAs who do not work on the shop floor, or who clearly do not work full time with aircraft, to renew their IA after complying with the minimum annual eight-hour training requirement. This proposed policy is a significant change to the long-established practices for IA qualifications and threatens to eliminate the renewal process for A&Ps currently employed in management positions.