2 Year IA Renewal & the Aircraft Owner's Dilemma

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Stache

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As we all know the aviation world is built and run on trust. The FAA has placed a lot of trust in the A&P/IA’s of the world by changing FAR 65 Section 65.93. This section covers the renewal requirements for Inspection Authorization holders to every other year starting with 2007 as the first odd year to sign their IA cards.

A&P/IA are still required to meet the requirements of Section 65.93 every year by performing at least 4-annual inspections, or 8- Major Repairs /Major Alterations or 1-Progressive, or 8-hours of instruction FAA seminar or take a FAA Oral exam.

In the past the FAA Inspector would sign their name on the IA card and date it so if a pilot want to know if their IA was current they could ask to review the A&P/IA card. This has changed the cards are only signed off every two years now. So how do you know if your IA still meets the requirement for the first year and is still authorized to sign off your annual inspection, major repair, major alteration, or progressive inspection?

An inspection activity report is not mandatory or regulatory. It is a means with which you’re A&P/IA may easily “present evidence” of their IA “activity”. It is as much a convenience for you as for your A&P/IA. Without this information you will not be able to properly determine you’re A&P/IA meets the eligibility during even years. Many A&P/IAs will attend a FAA seminar and receive a certificate indicating they received the required 8-hours of training for that year. This certificates means you’re A&P/IA is current and meet the intent of the rule.

The owners who don’t know what has happened or don’t comprehend the consequences will do “business as usual” and run the risk of dealing with an IA for their aircraft annual who is inadvertently, as a result of not meeting all of the requirements at the end of year one, not legal on the day he signs the aircraft logbooks. If the IA is not current the logbook entry for the annual is invalid; the annual is not complete and the aircraft is not legal to return to service.

So after March 31, 2008 I would highly recommend you ask you’re A&P/IA to provide proof they have meet the renewal requirement of Section 65.93 before they sign off your next annual inspection. This can either be a activity report of a certificate attending an FAA seminar or even a letter from the FAA FSDO for passing a oral exam.
 
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Let us say for the sake of this thread that I do not qualify for 2007, and sign off 3 Annuals in 2008, and not submit for re-qual in march of 2009.

How is the FAA going to tract the 3 I did in 2008?
 
Pray to God the aircraft owner does not have an incident or accident, which would have your local FAA and NTSB looking at the aircraft owner’s aircraft records real close seing who signed off the last annual and run a check on them.

Bottom line the FAA may not know.

Taking it one step further. The IA didn’t do required inspections and in the second year goes to the local FSDO to get renewed. If that IA cannot prove or show dates and N-number they performed inspections or maintenance repairs/alterations. seminar, oral test they don’t get renewed and will have to retest.

However the IA being a clever kind of guy lists 4-N-numbers on an activity sheet of some kind and fills out the FAA Form 8610-1 dates and signs it knowing the annual is false. This is called fraud. Many inspectors I know will run a check of the N-numbers and even in some cases contact the owner and review the aircraft records as a spot check to keep everyone honest.

I think there is going to be a learning curve here, but it still puts the aircraft owner in a pickle in some cases. Again this is just a heads up for all owners to beware of their responsibility and not get taken in by some low life individual who doesn’t care about any rules and will break them regardless.

Just one man's opinion, I could be wrong.
 
NC19143 said:
Let us say for the sake of this thread that I do not qualify for 2007, and sign off 3 Annuals in 2008, and not submit for re-qual in march of 2009.

How is the FAA going to tract the 3 I did in 2008?
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I find it interesting that aviation is so regulated, and yet they rely on the individual to provide their own documentation to maintain currency. I am thinking about trying to get my IA next year. I have had my A&P since 1970. I worked a couple of years in aviation, left for another career, then came back a couple of years ago. Who is to say whether I have been an A&P for thirty-six years, or four years? Myself, I would say for all practical purposes I have been and A&P for two years. Same thing with flying. I could write anything I want in my log book. Suppose I wanted to get my commercial. What examiner is going to go over the records for the last thirty years to verify my hours? I've seen pilots very casually round up to the nearest hour when they get back from flying. What is to keep a pilot from putting a little notation in his log book to indicate that he did three takeoffs and landings the last time he flew, to keep him current, instead of one? So back to the A&P, if you are a customer, and if you wanted to see my A&P, you would see that I have been an A&P since 1970. If you inquired about my experience, I could tell you that I have been active for the last two years, or I could tell you that I've been an A&P for thirty-six years. For myself, I am pretty honest with all of my documentation, however I have no reason to cheat on it. I can see a whole lot of room for abuse, if someone wanted to gain from it.
 
Hmm. On the one hand, we gripe about overregulation, and then when the regs are changed to dial back the regulation just a little, that's a problem too.

Yes, there are scumbags in the world. The regulation doesn't change that, it just changes how they short-circuit the rules.
 
Maxmosbey said:
I find it interesting that aviation is so regulated, and yet they rely on the individual to provide their own documentation to maintain currency. I am thinking about trying to get my IA next year. I have had my A&P since 1970. I worked a couple of years in aviation, left for another career, then came back a couple of years ago. Who is to say whether I have been an A&P for thirty-six years, or four years? Myself, I would say for all practical purposes I have been and A&P for two years. Same thing with flying. I could write anything I want in my log book. Suppose I wanted to get my commercial. What examiner is going to go over the records for the last thirty years to verify my hours? I've seen pilots very casually round up to the nearest hour when they get back from flying. What is to keep a pilot from putting a little notation in his log book to indicate that he did three takeoffs and landings the last time he flew, to keep him current, instead of one? So back to the A&P, if you are a customer, and if you wanted to see my A&P, you would see that I have been an A&P since 1970. If you inquired about my experience, I could tell you that I have been active for the last two years, or I could tell you that I've been an A&P for thirty-six years. For myself, I am pretty honest with all of my documentation, however I have no reason to cheat on it. I can see a whole lot of room for abuse, if someone wanted to gain from it.
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The fun part of this whole routine is, I can select 4 aircraft that I have placed in preservation do a inspection and call it annual, sign off the logs as being UNairworthy, place a list of discrepancies in the log, (separate sheet) and count that as my required 4 for that year.

or

I can go to the local FSDO training listen to the speakers that show up each year after year, get my signatures and use that as the required training and re-certify with that. (no activity sheet required) but I may have completed 25 annuals in that year.

Or

I can use the annuals I preform each year to complete the requirement, but the same 4 aircraft that I used in 2007 can be used again n 2008.

Think about this, If I declared the aircraft as unairworthy in 2007, and nothing changes 2008 annual is pretty easy.

Also, I can complete an annual in Jan, sone one else can do an other one in Feb, the third IA can do one in Mar, and so on, and all the IAs can count it.

As for 337 count, an A&P-IA can use 8 skin replacements and re-qual with those.(on their activity sheet) even though the 8 skins were replaced in the same repair, all the IA must do is make a 337 for each skin. and using the approved data in the maintenance manual send the 337 direct to OKC and never show it to the FSDO.

my suggestion is to go ahead and get your IA it's just way too easy to re-qual to avoid doing it because of the rules.
 
Ken Ibold said:
Hmm. On the one hand, we gripe about overregulation, and then when the regs are changed to dial back the regulation just a little, that's a problem too.

Yes, there are scumbags in the world. The regulation doesn't change that, it just changes how they short-circuit the rules.
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You are right, where there is a will, there is a way. There seems to be a lot of people out there who think that "creative interpretation" is going to save them. I realize that if there is a deep enough investigation, the truth might be found, but that is usually too late. There are not a whole lot of FAA investigations that go on before the fact, the are usually after the fact. In the mean time, people go around justifying in their own minds whatever they want to do, and don't think much more about it.
 
If you are an A&P and would like to obtain your IA authorization the rule says active at least two of the last three years. The key word here is actively engaged.

I have researched some legal interpretation concerning “actively engaged”.

The intent of the regulation is that an applicant for IA be an active, working A&P Mechanic, that the applicant be participating, occupied, or employed in inspecting, overhauling, repairing, preserving, or replacing parts on aircraft. Actively engaged may include supervising others. But this may have to be determined on a case-by case basis with your assigned Inspector.

If you have any questions as to whether you are “actively engaged”, or have any other experience, renewal or eligibility questions, please contact your local FSDO Inspector.

Here where I am the local FSDO encourages all A&P’s to obtain an IA because as you study to prepare for the IA written test and it will automatic raise you knowledge level. The test is open book and will test your skills on looking things up, reading and figuring things out. You can take up to 3-hours for the written test and in most cases it takes all 3-hours to complete. I happen to know the guy in Oklahoma City that writes the test questions and they change every 30-days that’s why the FAA does not publish it.
 
NC19143 said:
The fun part of this whole routine is, I can select 4 aircraft that I have placed in preservation do a inspection and call it annual, sign off the logs as being UNairworthy, place a list of discrepancies in the log, (separate sheet) and count that as my required 4 for that year.

or

I can go to the local FSDO training listen to the speakers that show up each year after year, get my signatures and use that as the required training and re-certify with that. (no activity sheet required) but I may have completed 25 annuals in that year.

Or

I can use the annuals I preform each year to complete the requirement, but the same 4 aircraft that I used in 2007 can be used again n 2008.

Think about this, If I declared the aircraft as unairworthy in 2007, and nothing changes 2008 annual is pretty easy.

Also, I can complete an annual in Jan, sone one else can do an other one in Feb, the third IA can do one in Mar, and so on, and all the IAs can count it.

As for 337 count, an A&P-IA can use 8 skin replacements and re-qual with those.(on their activity sheet) even though the 8 skins were replaced in the same repair, all the IA must do is make a 337 for each skin. and using the approved data in the maintenance manual send the 337 direct to OKC and never show it to the FSDO.

my suggestion is to go ahead and get your IA it's just way too easy to re-qual to avoid doing it because of the rules.
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I am not worried about keeping current, as you say, I can "go to the local FSDO training, listen to the speakers that show up each year after year, get my signatures and use that as the required training and re-certify with that." The only reason that I might not go after it is that I am retired, and I work as an A&P part time. I pretty much work to pay for my flying, and to hang around the airport. I am not sure that I want to put in the effort to get it. It is just that sometimes I think it would be something to do. It might be interesting.
 
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Ken Ibold said:
Hmm. On the one hand, we gripe about overregulation, and then when the regs are changed to dial back the regulation just a little, that's a problem too.

Yes, there are scumbags in the world. The regulation doesn't change that, it just changes how they short-circuit the rules.
Click to expand...

I see no problem with the new requirement for re-qualing every 2 years,

the good thing it does is not have my certificate in the mail half as much.
and we IAs can't operate with without the certificte in our position, that leaves each march an open month that we can't use our privledges.

This change gives us 23 months out of 24 that we can make a living.

I do enough annuals to requal plus enough 337's also. and I attend the training each year at Clover Valley community college to re-qual also.

and in the month of march our FSDO allows my PMI to hold a card signing day at a place where we don't have to go thru FSDO security, thus I can hand hiim my card, my requal sheets, and other paper work required, then he signs it and hands it back.

I had no problems with the once per year reg nor do I have any problems with the change, but it has now required me to hold my records 2 years rather than one.
 
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Stache said:
If you are an A&P and would like to obtain your IA authorization the rule says active at least two of the last three years. The key word here is actively engaged.

I have researched some legal interpretation concerning “actively engaged”.

The intent of the regulation is that an applicant for IA be an active, working A&P Mechanic, that the applicant be participating, occupied, or employed in inspecting, overhauling, repairing, preserving, or replacing parts on aircraft. Actively engaged may include supervising others. But this may have to be determined on a case-by case basis with your assigned Inspector.

If you have any questions as to whether you are “actively engaged”, or have any other experience, renewal or eligibility questions, please contact your local FSDO Inspector.

Here where I am the local FSDO encourages all A&P’s to obtain an IA because as you study to prepare for the IA written test and it will automatic raise you knowledge level. The test is open book and will test your skills on looking things up, reading and figuring things out. You can take up to 3-hours for the written test and in most cases it takes all 3-hours to complete. I happen to know the guy in Oklahoma City that writes the test questions and they change every 30-days that’s why the FAA does not publish it.
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I think that I meet the criteria for "actively engaged". The reason that you state in your last paragraph is probably the reason that I would try to get my IA. There is a lot that I would like to learn. I work for a certified repair station, and almost all I do is annuals and 100hr inspections. Every once in a while I get to help with a repair or alteration, but I spend most of my time going down the checklist and doing the ADs. There is a lot out there that I am not going to do without looking for it myself.
 
Stache said:
Pray to God the aircraft owner does not have an incident or accident, which would have your local FAA and NTSB looking at the aircraft owner’s aircraft records real close seing who signed off the last annual and run a check on them.

How can you hold an owner that see the proper entry in their logs responsible for an A&P-IAs currency?

Or how can you enforse a regulation on an A&P-IA that has retired? After all we do retire, and go away. home address on file with the FAA may or maynot be good.


Bottom line the FAA may not know.

Taking it one step further. The IA didn’t do required inspections and in the second year goes to the local FSDO to get renewed. If that IA cannot prove or show dates and N-number they performed inspections or maintenance repairs/alterations. seminar, oral test they don’t get renewed and will have to retest.

If the A&P-IA has retired you would have a hell of a hard time finding them, and if they did retire and leave 3 illiegal annuals out there The FAA would have an even harder time finding which 3 aircraft.

However the IA being a clever kind of guy lists 4-N-numbers on an activity sheet of some kind and fills out the FAA Form 8610-1 dates and signs it knowing the annual is false. This is called fraud. Many inspectors I know will run a check of the N-numbers and even in some cases contact the owner and review the aircraft records as a spot check to keep everyone honest.

I think there is going to be a learning curve here, but it still puts the aircraft owner in a pickle in some cases. Again this is just a heads up for all owners to beware of their responsibility and not get taken in by some low life individual who doesn’t care about any rules and will break them regardless.

Just one man's opinion, I could be wrong.
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My PMI once told me we IAs never know how many annuals we do, because we have owners that use our names to do their own annuals. And showed me a sign off I did on an aircraft in Ga. I never even saw that aircraft.
 
I'd bet very, very few owners are going to press their IA for proof of currency. Maybe after some people get stung over it, but right now there is a lot of trust. No one would know what they are looking at even if provided proof.
 
NC19143 said:
My PMI once told me we IAs never know how many annuals we do, because we have owners that use our names to do their own annuals. And showed me a sign off I did on an aircraft in Ga. I never even saw that aircraft.
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Having your name in a logbook that you didn't work on is fraud and I would be telephoning the FBI and have that person lock-up. My name is in a lot of log books and I want to make sure I was the one that put it there. Thats why I keep good records of every aircraft I work on and have the files to prove it.

I know a A&P who signed off over 40 annual using a dead guys IA cetificate and name. Just took one owner to turn him in and he was sent to the federal big house for a few years on fraud charges. At http://www.oig.dot.gov your can read about a bunch of the bad guys in aviation.

Its easy to cheat, but get caught and the government will throw the whole book at you. I keep telling myself this is a trust system we work in, but it just takes one to screw it up.
 
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Stache said:
Having your name in a logbook that you didn't work on is fraud and I would be telephoning the FBI and have that person lock-up. My name is in a lot of log books and I want to make sure I was the one that put it there. Thats why I keep good records of every aircraft I work on and have the files to prove it.

I know a A&P who signed off over 40 annual using a dead guys IA cetificate and name. Just took one owner to turn him in and he was sent to the federal big house for a few years on fraud charges. At http://www.oig..gov your can read about a bunch of the bad guys in aviation.

Its easy to cheat, but get caught and the government will throw the whole book at you. I keep telling myself this is a trust system we work in, but it just takes one to screw it up.
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For me, it isn't the threat of the big house, I don't want to do something that gets someone hurt or killed. No one is perfect, but to purposely do something is a different matter. It isn't just getting someone hurt or killed even. We all know how important those log books are. You got to be pretty self serving to screw up someone's maintenance history like that just for the bucks. I guess that I am lucky, but every mechanic I've ever worked with has always at least believed he was doing the right thing.
 
Stache said:
At http://www.oig..gov .
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Your link doesn't work, but the Franklin Engine club was a great example of what we speak of. Many Engines were overhauled using Tractor parts and a Dead A&P's name placed in the logs.

When the FAA found out every one stone walled them and nothing happened, the FAA couldn't prove who did it, so they came out with an AD stating any engine that the Franklin engine club overhauled was unairworthy and must be overhauled again using the proper parts.

We all know that there is no new parts for many of the Franklins and so a bunch of pages got ripped out of logs, and the owners fly on.
 
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Sorry about the web link, it didn't work so I found the new one that does;

http://www.oig.dot.gov/Room?subject=17

Just scroll down the list there are several aviation people involved. You may want to read the one in Oklahama it is about engine overhaul just this past year.
 
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gprellwitz said:
How about this one. Not maintenance related, but every(?) pilot's dream! http://www.oig.dot.gov/item.jsp?id=2081
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The student pilot was also an employee of the company. She did a great job landing, except she didn't put down the gear. In that particular case, the incapacitated pilot allegedly had a history of unexplained blackouts and allegedly had shopped AMEs until he found one who would sign him off.
 
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