The FAA has issued a Notice of Policy that clarifies the term “actively engaged” for the purposes of application for and renewal of an inspection authorization, and industry groups have expressed concerns about the definition. It states, “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. Technical instructors or individuals instructing in an FAA Part 147-approved AMT schools, who also engage in the maintenance of aircraft certified and maintained in accordance with 14 CFR, can be considered actively engaged. Individuals instructing in an FAA Part 147 AMT school, who also engage in the maintenance of aircraft-related instruction equipment maintained in accordance with 14 CFR standards, can be considered actively engaged.”

Dale Forton, president of the Professional Aviation Maintenance Association (PAMA), told AIN, “We are unsure as to why this interpretation was issued from such an uninformed position. It is a very poor definition of actively engaged or actively involved. A FSDO in Texas defined it at a recent IA renewal by saying if an A&P worked as an instructor, was teaching in the aircraft field, pulling wrenches, completing aircraft records and logbooks, supervising maintenance or anything dealing with aircraft maintenance, regulations, etc., then he is actively engaged as far as they were concerned. The problem is the definition doesn’t include individuals involved in any training capacity, parts manufacturing, technical advice or regulatory even though they are still using their A&P skills and knowledge.”

John Wicht, engineering and FAA certification manager for Rapco, said he is “deeply concerned” with the FAA’s interpretation. “[The agency has] forgotten the thousands of A&P mechanics like me who work in aviation manufacturing. I use my A&P and IA skill set daily when performing my job functions. I think the FAA needs to take another look at this.” Wicht holds both A&P and IA credentials and is an FAA-designated engineering representative, designated manufacturing inspection representative and designated airworthiness representative.

Terry Michmerhuizen, a certification engineer for Duncan Engineering in Battle Creek, Mich., posed the question, “If the FAA succeeds with this approach, who is going to be left to conduct the eight-hour renewal training events? Will the FAA drop them too or perhaps allow them to be taught by people without IA privileges? I would expect that to be less than appealing to most IAs who have to take the class,” he said.

Michmerhuizenpointed out that many vendors currently conducting renewals might also “fade away.” “Many of us have progressed to jobs that no longer have us turning a wrench daily, yet we have a lot to offer the aviation community. While I agree there may be a need to cull the ranks of the IAs of those who are ghosting along, I firmly believe that this is a tremendous step backward and will have a negative effect upon the aviation industry from loss of morale to an outright loss of personnel,” he said.

“There are many good technicians who can turn a wrench and inspect the aircraft, but it takes a special skill to be able to communicate technical issues and regulatory requirements to a diverse audience. Not every A&P, even with an IA, would make a good classroom instructor. With this definition Part 147 instructors, who usually have both the experience and talent to do this type of teaching, could be excluded. How does that make any sense?” Michmerhuizen concluded.