But FAA Employees Are Apparently Exempt
The FAA has issued a policy which is intended to clarify the
definition of "Actively Engaged" for purposes of issuing and
renewing the A & P Inspector Authorization. "Actively engaged"
means 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 AEA has issued a statement saying it is "disappointed"
with the initiative.
"For decades, the FAA, as well as industry, has been frustrated
by the lack of career recognition of the Airframe and Powerplant
mechanic. And now, the FAA proposes to remove this recognition from
those who are in senior management positions with corporate flight
departments, repair stations and air carriers who are not
exercising their A & P privileges to "inspect, overhaul,
repair, preserve, or replace parts on aircraft," the statement
reads. "In an unprecedented addition, the FAA, while minimizing the
recognition of publicly employed A & P mechanics, has exempted
its own employees from this flawed policy.
"According to this proposal, because other FAA policy limits the
type of maintenance that ASIs can perform (they may only exercise
their IA on their personal, non-commercial aircraft), the FAA
employees are exempt from this new policy, and "an ASI may renew an
IA regardless of volume of maintenance work performed."
AEA encourages every member who may be affected by this policy
to send comments to the FAA. Comments on docket number
FAA-2010-1060 are due on or before December 6th