Sec 65.91 Inspection Authorization

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cchenry01
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Sec 65.91 Inspection Authorization

Looking for some advice please.  Last year I approched my local FSDO office with the intent of having my application for Inspection Authorization approved.  At that time my contact requested that I come back in a year with some solid inspection experience. 

To satisify the request of the FSDO I had contracted out to a local flight school and had completed six 100 hour inspections as well as several conditional inspections for a few home built experimentals located at the airport.

Some background, I am a 23 year retired Air Force Crew Chief on KC 135R aircraft.  Since my retirement I have been working for myself in my own shop as an A&P working on GA aircraft.  A year had passed and I returned to my FSDO with application in hand as well as a history of what I had completed. 

His reply this time was that I did not pass the "actively engaged" statement of Sec 65.91.  He felt that actively engaged was 40 or more hours a week for at least two years.  I asked to see the reference and he said he could not remember where it was but that he had seen it.

My question to the forum, is there anyplace a definition of "actively engaged" that I might review?  Anybody else have a simular problem and how did they work through it? Thanks for the help..

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carol
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Actively engaged means employed in the aviation industry and exercising the privileges of
their mechanic certificate.

I read the FAR (posted below) and I would agree that "actively engaged" means full time for two years. You did not say how long it has been since your retirement? The order to issue the authorization leaves room for the inspector to use his judgement. However- I would not consider 6-8 inspections equal to two years experience.

FAR Part 65.91
You are eligible for the Inspection Authorization Knowledge Test if you meet the requirements of Title 14 of the Code of Federal Regulations (14 CFR) part 65, section 65.91(c). The section states that you must:

Hold a currently effective mechanic certificate with both an airframe rating and a powerplant rating, each of which is currently effective and has been in effect for a total of at least 3 years;

Have been actively engaged, for at least the 2-year period before the date he applies, in maintaining aircraft certificated and maintained in accordance with this chapter;

Have a fixed base of operations at which he may be located in person or by telephone during a normal working week, but it need not be the place where he will exercise his inspection authority;

Have available to him the equipment, facilities, and inspection data necessary to properly inspect
airframes, powerplants, propellers, or any related part or appliance.

Anonymous (not verified)
Anonymous's picture

Actively engaged means full time for two years.Full time means 35 hours a week.This Info is not in the regs, but it is correct.

Stacheair1
Stacheair1's picture

I happen to teach an IA renewal course myself, just so everyone is on the same page Annual Condition Inspections do not count toward your IA renewal. The annual inspection counts because it is on a type-certificated aircraft. Condition inspections are usually on non-type certificated aircraft such as home built aircraft, experiment light sport and special light sport aircraft that do not have type certificates.

Stacheair1
Stacheair1's picture

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.

There has been numerous requests to clarify the term "actively engaged" as used in section 65.91 (c)(2) of the Federal Aviation Regulations (FAR).

The phrase "actively engaged" means that for the 2 year period before applying for an inspection authorization (IA) the applicant has been employed full-time in inspecting, supervising, overhauling, repairing, preserving, or replacing parts on aircraft certificated and maintained in accordance with the FAR.

"Full-time employment" is defined by the Department of Labor as employment averaging at least 35 hours a week. The FAA, when determining whether or not an applicant has been "actively engaged," will make allowances for absences due to sickness, vacation, and interruptions in employment caused by external factors.

Work performed on U.S. military aircraft does not meet the requirements of section 65.91 (c)(2) because these aircraft are not maintained under the FAR. IA applicants who maintain public aircraft that hold a current Federal Aviation Administration airworthiness certificate and are maintained under the FAR are considered to meet the requirements of section 65.91 (c)(2).

I hope this will clear up any gray area’s.

Richard Wyeroski (not verified)
Anonymous's picture

you are misleading this person when you say 2 years 35 hours full time employment.

No FAA certificate, rating designation or authorization requires full time employment.

65.83 does not have this language in it!

Rich Wyeroski

Stache (not verified)
Anonymous's picture

Since I posted the full time requirement the rules have changed and now part of 8900.1 Vol. 5.

August 18th, 2011 IA Renewal received news from the FAAST concerning the issue of Actively Engaged. This softened stance is helpful to those who do not work full time in aviation. Below is the quote . . .

FAA Clarifies "Actively Engaged" for IAs In a notice of policy dated Aug. 04, 2011, the FAA has clarified the term "actively engaged" with regards to those applying for and renewing an inspection authorization (IA). Current regulations state (among other requirements) that an IA must be actively engaged in maintaining aircraft for a two-year period before obtaining or renewing an IA. The new policy notice addresses the confusion caused by the term "actively engaged" and has broadened its application to cover IAs providing maintenance in rural areas, and those offering specialized expertise with rare or vintage aircraft. The definition also recognizes part-time employment and occasional activity, which does not require employment and may occur on an infrequent basis, valuing the substantive nature of experience rather than a strict quantity formula.

The order will allow FAA maintenance inspector some wiggle room to appoint IA that are not full time. This is a new change to the guidance and is why it is important to stay current on FARs and 8900.1 procudures.

I am teaching a IA renewal course November 3, 2012, in Oakland, CA and will covering the new material the FAA has published. I will be covering the part time requiement, but keep in mind this will be up to the local FSDO to determine.

The old requirement for full time was in the old procedures and legal interpurtations. You also have to go back to the preamble and you will fine information about full time. The government full time standars was set by the Dept. of Labor and that is where the hours came from. Needless to say it was confusing for FAA inspectors as well, so it was easy to just say no to an A&P wanting there IA. Now we have some releif.

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