Your Inspection Authorization is Now Renewable Every Two Years
However, the only thing that has changed is
the two year duration of your certificate.
All of the other requirements remain in place, specifically; FAR
Parts 65.91(C)(4)
& 65.93
As many in the Aviation Press have pointed
out, there is a potential trap for the IA who is doing only
limited activity. If you don't meet all the normal requirements by
March 31 of 2008, you can't act as
an IA as of April 1, 2008, even if you didn't have to prove to the
FAA that you met all of the normal
requirements. If you fail to meet all of the normal requirements by
March 31, and perform any IA functions
after March 31, 2008, not only are you in violation, but your client,
the aircraft owner, has a problem,
since your logbook entries are invalid. See: The
IA Renewal Trap and AC
Owner's Dilemma.
So, the only safe solution is to treat March 31, 2008 just as you did in 2007.
One way to meet the requirements of Section 65.93 is to complete a On-line Course of Study.
Below you will find three published explanations of the situation, followed by FAR Sections: 65.91, .92 & .93.
February 2007 The FAA has amended the regulations for the Inspection Authorization (IA), making renewals good for two years instead of just one effective March 1. Actually, the new IA period is made up of two one-year segments, each with an activity (work performed, training, or oral examination) requirement. During March of every odd-numbered year, an applicant for IA renewal must present evidence to the FAA that he or she meets the renewal requirements of Sec. 65.93(a). To maintain currency and ensure a consistent level of safety, IA holders must fulfill one of the activities of Sec. 65.93(a) (1) through (5) during the first year. If an IA holder does not complete the activity requirement by March 31 of the first year, he or she may not exercise the privileges of the authorization after that date. The IA holder may resume exercising inspection authorization privileges during the second year of the two-year IA period after the IA holder passes an oral test (65.93,a,5), which is administered by an FAA inspector to determine if the IA holder's knowledge of applicable regulations and standards is current. Upon passing the oral test, the IA holder will be deemed in compliance with the first year activity requirement. In reality, this means that the individual must continuously meet the requirements of Sec 91.63, a 1-5, year after year. However, the IA holder only needs to present evidence in every odd-numbered year. *********************************************************************************** March 06, 2007 FAA Issues Guidance On Two Year Inspection Authorization The FAA has issued Order 8000.354 providing guidance to aviation inspectors for dealing with the increase in duration of the Inspection Authorization ("IA") from one to two years. IA's must now be renewed by March 31 during odd years (2009, 2011 etc.). With respect to the activity requirements listed in FAR 65.93 (1) through (5) (which have not changed), if an IA is issued fewer than 90 days before March 31 of an odd-numbered year, the IA will still have to be renewed, but the applicant does not have to meet activity requirements to be eligible for renewal for that 90-day period. However, if an IA is issued fewer than 90 days before March 31 of an even-numbered year, the applicant does not have to meet activity requirements for that 90-day period in order to renew the IA. Starting in March 2009, in order to renew an IA, the IA must show the activity requirements for each year the IA was active. Additionally, if an IA does not meet the activity requirements at the end of an even-numbered year, the IA may not exercise the privileges of the IA certificate in the odd-numbered year without taking and passing an oral test with the local FSDO. *********************************************************************************** FAA CHANGES IA RENEWAL REQUIREMENTS TO TWO YEARS The Federal Aviation Administration (FAA) is amending the regulations for the Inspection Authorization (IA) renewal period. The current IA regulation has a one-year renewal period. This rulemaking changes the renewal period to once every two years. By changing the renewal period, renewal administrative costs will be reduced by 50 percent for both the FAA and the mechanic holding the IA. Aviation safety will not be affected because this rulemaking does not change the requirements of the prior rule for annual activity: including work performed, training, or oral examination. The amendment to § 65.92(a) changes the expiration date of an inspection authorization from March 31 of each year to March 31 of each odd-numbered year. The rulemaking is in response to concerns regarding the administrative burden associated with the renewal of inspection authorizations under § 65.93 and is effective immediately. ************************************************************************************ § 65.91 Inspection authorization. (a) An application for an inspection
authorization is made on a form and in a manner prescribed
by the Administrator. [Doc. No. 1179, 27 FR 7973, Aug. 10, 1962, as amended by Amdt. 65-5, 31 FR 3337, Mar. 3, 1966; Amdt. 65-22, 42 FR 46279, Sept. 15, 1977; Amdt. 65-30, 50 FR 15700, Apr. 19, 1985]
§ 65.92 Inspection authorization: Duration. (a) Each inspection authorization expires on
March 31 of each odd-numbered year. However, the holder may
exercise the privileges of that authorization only while he
holds a currently effective mechanic certificate with both a
currently effective airframe rating and a currently
effective powerplant rating. [Doc. No. 12537, 42 FR 46279, Sept. 15, 1977, as amended by Amdt. 65-50, 72 FR 4404, Jan. 30, 2007]
§ 65.93 Inspection authorization: Renewal. (a) To be eligible for renewal of an
inspection authorization for a 2-year period an applicant
must present evidence during the month of March of each
odd-numbered year, at an FAA Flight Standards District
Office or an International Field Office, that the applicant
still meets the requirements of §65.91(c) (1) through
(4). In addition, during the time the applicant held the
inspection authorization, the applicant must show completion
of one of the activities in §65.93(a) (1) through (5)
below by March 31 of the first year of the 2-year inspection
authorization period, and completion of one of the five
activities during the second year of the 2-year
period: [Docket No. 1179, 27 FR 7973, Aug. 10, 1962, as amended by Amdt. 65-50, 72 FR 4404, Jan. 30, 2007] |