The FAA has issued a Notice of Proposed Policy intended to clarify the definition of “actively engaged” for purposes of issuing and renewing the A&P Inspection Authorization. The proposal, which was published in the Federal Register on Nov. 5, 2010, would amend the aviation safety inspector guidance found in the Flight Standards Information Management System, FAA Order 8900.1.

The proposed policy would clarify the definition of actively engaged to mean 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 of maintenance activity performed, including any special expertise required. 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. The FAA has extended the comment period from December 6 until January 17.