Industry Insights

If you were a child of the seventies you’ll remember a 1976 movie called "Logan’s Run." The story line was all about some people living in a utopian society who gathered on their 30th birthday to recycle their "life force." Amidst the spectator’s cries of "Renew! Renew!," these birthday celebrants would defy gravity, execute a lazy counter-clockwise climbing turn above the spectators and explode.

The purpose of this trivial pursuit is so we can focus on the cries that the spectators made: "Renew! Renew!" One of my jobs in the FAA is to renew some of the Designated Airworthiness Representative (DAR), Designated Engineering Representative (DER), Designated Maintenance Inspection Representative (DMIR), and Organizational Designated Airworthiness Representative (ODAR) designees for the New England region. The ODAR is soon to be replaced by the ODA, and, no, ODA isn’t caveman Alley-oop’s sister. It’s an acronym for Organization Designation Authorization (ODA).

Now you designee folks (you know who you are), your professionalism and talent have earned you a good job representing the FAA in industry. Your attention to detail has won you respect at your craft. But, it never fails; some of you guys still forget to renew your appointments on time! I mean, come on people, this is your livelihood we’re talking about!

The renewal time limits do vary from region to region, but not by much. Order 8100.8C (the latest version) says that an appointment can range from one to three years and is at the discretion of the appointing office, however, very rarely does the renewal period exceed a year. The designee’s advisor should make certain the designees know the renewal period and all understand the requirements with regard to renewal paperwork submission schedules.

Now sure, the renewal package is time-consuming and tedious, kind of like your tax forms. After all, you write a one-page letter to your FAA advisor, followed by a dash to your file cabinet (or computer) to make copies of the training you accomplished in the past two years. You then mail a copy of the letter, proof of training and a list of accomplished tasks (record of activity) performed during the past year to your FAA advisor.

That being said, I want you to understand that the FAA advisors aren’t required to remind anyone to renew; the key word being required. They do it to stay one step ahead of the deadlines and two steps ahead of the paper blob at renewal time. But sometimes we get busy and forget to send out the reminder alerts. So we really need you folks to stay on top of your expiration dates and manage your own career. Once the deadline has past for your renewal and you missed it, we can’t help you.

Oh, and you IA folks, don’t you go laughing just yet. I also deal with the renewals of Inspection Authorizations (IA). You would expect that a set calendar date of March 31 would be hard to forget. But somehow, on April 4 or so, there is always someone who says (and I quote), "You can get my IA renewal through, right?"

Um, that would be a "no." And you might want to bone up on the IA test again, because we all know how much fun taking that is.

Now the FAA has increased the renewal requirement for IA to two years. For those who missed it, March 1, 2007, the Direct Final Rule 72 FR 4933 was published which amended the renewal period for IA, which is by March 31 on odd number years.

Although the renewal period was extended, one must still complete one of the five activities listed in Sec. 65.93 (a) (1) – (5) every year. If not, the IA forfeits his/her right to exercise IA privileges. And it is very important to maintain communication with the FAA advisor(s) to assure that the activity documentation is kept up. If there are any questions, the local FAA representative can answer them. Just don’t wait two years to ask!

Now I would be remiss if I didn’t offer tips to how one can stay on top of the renewals. Suggestions to help the reader to NOT FORGET TO RENEW vary from tying a string around your finger, walk around with an elephant, eat fish for dinner (it is brain food), or eat a big dish of Gingko Biloba ice cream with large chunks of real Gingko Biloba. Maybe you can try putting subliminal reminders in all your DVDs or (my personal favorite) start on the renewal paperwork at the same time you change out the batteries in your smoke detectors. Do whatever it takes to stay on top of your deadlines; too much depends on it.

Now it’s safe to say that you won’t explode if you don’t renew. But perhaps you will endure a worse fate: the loss of your privilege. The advisors and I like working with professionals, so remember, be a professional and don’t let us down.