Updated December 6, 2010

The FAA has issued a Notice of Proposed Policy which is intended to clarify the definition of “actively engaged” for purposes of issuing and renewing the Airframe and Powerplant (A&P) Inspection Authorization (IA). The proposal, which was published in the Federal Register on November 5, 2010 would amend the aviation safety inspector (ASI) guidance found in the Flight Standards Information Management System, FAA Order 8900.1. It will not modify the 14 CFR §65 regulations applicable to inspection authorization.

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.

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.

The 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.

NBAA encourages its Member companies to submit comments that include specific information on the potential effect and impact to its operation of this policy proposal. Comments can be submitted through the Federal eRulemaking Portal, www.regulations.gov. The deadline for public comment on this proposal has been extended to January 17, 2011. The originally published deadline for public comment was December 6, 2010.

Resources for Understanding, and Commenting on, the FAA’s Proposed Policy Notice