An Incentive for Maintenance Training

If you're one of the nearly 20,000 A&P mechanics in the U.S. who holds the Inspection Authorization, it's that time of year again; you need to renew your IA with the FAA by March 31. To renew, you must either attend eight hours of training or have signed off a minimum number of annual inspections and/or major repairs or alterations.

In most cases, IAs renew by sending the old certificate and an application form to the local FAA Flight Standards District Office. Some FSDOs like to get some face time with their IA community and ask the IAs to come to an annual meeting to renew their acquaintance with FAA regulations and get to know their regulators better. This is not a bad idea because most FAA inspectors are so busy with airlines and repair stations that they don't have much time to spend knocking on the door of your average IA.

What's strange about this process is the annual March 31 deadline. The IA is the only renewable FAA certificate that expires on the same date each year. The reason for the March 31 expiration? Simple, it's in the FAA regulations, Part 65, sec. 65.92: "(a) Each inspection authorization expires on March 31 of each year."

But why March 31? Why do the regulations allow flight instructors to wait two years from the month that they obtain their certificate to renew? Why doesn't the FAA do the same with the IA?

The reason for asking this is because of the mad scramble that takes place every year from January through March 31. Apparently there are many IAs who don't qualify to renew based on the annual inspection or major alteration/repair signoff method, so they attend an eight-hour training session. These are held all over the U.S. and in other countries.

There are many opportunities for training that meet the IA-renewal requirements, from online courses to technical training by aviation vendors to IA-specific renewal sessions, many of which can be done at any time during the year. But, it's human nature to put things off till the last minute and many IAs wait until after January 1 to prepare for the March 31 deadline. And thus the crowded schedule of IA classes that really heats up in March.

Maintenance training is important; I'm sure everyone agrees with that. And maintenance training is about to get some serious attention, with the implementation of the Part 145 repair station training program rule on April 6 (is your shop ready?). The problem is that the annual focus on IA renewal is misguided. Why? Recurrent training is important and should be mandatory for all mechanics, not just IAs. And the current system of IA renewal training doesn't produce a high-quality training product geared towards the needs of the aviation industry. Much of the training is just filling in the blanks to satisfy the FAA regulations.

To fix this, I'd like to suggest a simple rule change, actually, two rule changes.

First, Part 65, sec. 65.92 should change to: "Each inspection authorization expires at the end of the month two years from the date of issue."

Second, Part 65, sec. 65.83 (recent experience requirements for mechanics) should add a subparagraph (c) after this sentence: "A certificated mechanic may not exercise the privileges of his certificate and rating unless, within the preceding 24 months..." --and subparagraph 9c) would offer this option: "He has attended at least 16 hours of aircraft maintenance training."

These rule changes would help the industry, by spreading out the time that IAs could attend training sessions and ending the mad March scramble. Plus, in this scenario, both IAs and A&P mechanics could recertify (IAs) or stay current (A&Ps) by obtaining 16 hours of training every two years. This would greatly expand the available pool of training class attendees and lead not only to more training opportunities for mechanics but also higher quality classes.

Recurrent maintenance training is required almost everywhere in the world except the U.S. This would be a simple way to provide an incentive for all FAA-certificated mechanics to attend recurrent training.