Renew Title 14 CFR Part 65, Inspection Authorization Holder




N 8900.67


National Policy

Effective Date: 03/05/09



Cancellation Date: 03/05/10



Renew Title 14 CFR Part 65, Inspection Authorization Holder

1. Purpose of This Notice. This notice provides policy and guidance to supplement Flight Standards Information Management System Order 8900.1, Volume 5, Chapter 5, Section 8, Renew Title 14 CFR Part 65 Inspection Authorization, and 2-year Inspection Authorization (IA) cycle procedures.

2. Audience. The primary audience for this notice is Flight Standards District Office (FSDO) aviation safety inspectors. The secondary audience includes Flight Standards branches and divisions in the regions and in headquarters.

3. Where You Can Find This Notice. Inspectors can access this notice through the Flight Standards Information Management System (FSIMS) at Operators may find this information at:

4. Background.
a. With the issuance of Title 14 of the Code of Federal Regulations (14 CFR) part 65, § 65.93, holders of a Federal Aviation Administration (FAA) IA will not be required to renew their certificates until March 2009. Each IA holder, however, must maintain their eligibility to hold the certificate throughout the 2-year renewal cycle. IA holders must have written documentation to support their continued eligibility through March 2008 and 2009, and include it with the renewal application package (FAA Form 8610‑1, Mechanic’s Application for Inspection Authorization) submitted to the assigned Flight Standards District office (FSDO) in March 2009, and each subsequent odd year renewal cycle.
b. For the purposes of IA activity, the year begins on April 1 and extends through March 31. During this 12‑month period, IA holders must meet one of the renewal requirements set forth in § 65.93(a). An IA holder must continue to meet the yearly requirements of § 65.93 in order to retain the authorization.

5. Policy Action. Applicants for IA renewal must meet one of the following:
a. Title 14 CFR § 65.93(a)(1) Requirements. Has performed at least one annual inspection for each 90 days that the applicant held the current authority. These four annual inspections could be performed at any time during the year. Some individuals incorrectly assume that at least one annual inspection must be completed during each 90‑day period.
b. Title 14 CFR § 65.93(a)(2) Requirements. Has performed inspections of at least two major repairs or major alterations for each 90 days that the applicant has held the current authority. Likewise, the completion of these activities need not occur during each 90‑day period. You may renew on either annual inspections or major repairs/alterations, not a combination of the two.
c. Title 14 CFR § 65.93(a)(3) Requirements. Has performed or supervised and approved at least one progressive inspection in accordance with the standards prescribed by the Administrator.
d. Title 14 § 65.93(a)(4) Requirements. Has attended and successfully completed a refresher course acceptable to the Administrator of not less than 8 hours of instruction during the 12 months preceding the application for renewal. Many renew an IA through attending the classes provided at an annual approved IA symposium. Many of the manufacturer’s training courses have also been approved as a basis for IA renewal. Generally, these courses will display an FAA‑approved course number on the certificate of completion. There are also a number of approved computer-based instruction courses available on the Internet.
e. Title 14 CFR § 65.93(a)(5) Requirements. Has passed an oral test by an FAA inspector to determine whether the applicant’s knowledge of the applicable regulations and standards are current. This method of renewal may not be your first choice, but it is a viable option that allows positive interaction with FAA personnel during the renewal process. Oral tests may be based on the current revision of the FAA Inspection Authorization Knowledge Test Guide, FAA‑G‑8082‑11B, and IA privileges and limitations per part 65.

6. Guidelines for Question Development. The FSDO or International Field Office (IFO) should develop the oral test questions, which should meet the following criteria:
a. Clear. Content should establish the conditions or circumstances so the inspector and IA applicant will have the same mental picture with regard to the question’s intent and expected answer.
b. Concise. Questions should not be too complex, ambiguous, or have multiple answers.
c. Focused. Questions should have one specific answer and be referenced to a specific, FAA‑accepted guidance document or regulation; questions should not be manufacturer‑specific.

7. Sources for Test Development and Questions.
a. FAA Inspection Authorization Knowledge Test Guide, FAA‑G‑8082‑11B, current edition, is an example source for question development of oral questions along with the Practical Test Standards, Aviation Mechanic General Test Standards (FAA‑S‑8081‑26), specific to maintenance form and records. Reference
b. IA privileges and limitations per part 65 would be additional sources for test development, as there should be enough variance in the test to prevent the applicant from having prior knowledge of the specific questions. It is recommended that a minimum of 10 oral questions be asked to each IA affected, with a passing grade of 70 percent.

8. Administration and Use of the Oral Test as Evidence of Authorization. Aviation safety inspectors assigned to a FSDO or IFO administering oral tests must issue the IA with evidence of the applicant having passed or failed the test in the form of written documentation. The IA should instruct IA holders to retain the oral test results and be prepared to present the results to the FAA upon renewal or by request. Upon renewal during the odd‑year renewal month, IA holders may use FAA Form 8610‑1 as evidence of having passed the oral test if the completion is noted in the Remarks section of the form. Failing the oral test will result in nonrenewal of the IA.

Note: Oral tests administered at any other time will require written evidence of completion signed by the inspector conducting the test, and a copy placed in the IA office file.

9. Disposition. We will permanently incorporate this information into FSIMS before this notice expires. Direct questions concerning this notice to the General Aviation and Avionics Branch, AFS‑350, Attn: Kim Barnette at (202) 385‑6403 or Ed Hall at (804) 222‑7494, extension 240.

John W. McGraw for
John M. Allen
Director, Flight Standards Service

Appendix A. Question and Answers
1. Renewal of IA, and Exercising IA Privileges.
a. Question. If an IA holder does not complete one of the five activity requirements, as stated in Title 14 of the Code of Federal Regulations (14 CFR) part 65, § 65.93, after the first year, he or she is not allowed to exercise inspection privileges after March 31 of the first year. If this is only determined during the renewal (after the second year), what happens to all the work that is signed off during the second year? Does this mean all items “signed off” by the IA holder during the second year are not airworthy? Is the owner required to have all the work done again? Is enforcement action warranted on these IA holders?
b. Answer. An IA holder must show on FAA Form 8610‑1, Mechanic’s Application for Inspection Authorization, that he or she meets 14 CFR § 65.91(c) during the second year renewal period; there is no change from previous requirements for completion of Form 8610‑1, actively engaged per 14 CFR § 65.93(a). An IA holder who does not meet one of 14 CFR § 65.93(1) to (5) during the first year may not exercise IA privileges after March 31 of the first year. (14 CFR § 65.93(c)) An IA holder may resume privileges after passing an oral test per 14 CFR § 65.93(c). The IA holder’s activity must show during the odd year (month of March), that he or she meets the 2‑year renewal requirements, as the statement indicates.
(1) In the event that an IA holder becomes ineligible due to insufficient activity or failure to meet first-year requirements, the IA holder would then receive a warning letter addressing the activity performed, stating the activity was performed while the IA was not currently effective and in violation of § 65.93(c). The IA holder would then take an oral test to resume IA privileges, and no further action is required if the IA holder successfully completes the oral test.
(2) There has been no change to previous policy on IA renewals or failure to meet the renewal requirements. If the IA holder fails the oral test, the IA will not be renewed.
(3) The IA holder’s nonrenewal status does not affect the airworthiness of the aircraft, major repair, or major alteration he or she inspected, performed, and recorded in accordance with 14 CFR part 43, §§ 43.9 or 43.11. Therefore, no additional action should be taken against the affected aircraft or owners.

2. FAA Pursuit of Enforcement Action.
a. Question. Will the FAA be required to pursue enforcement action against the IA certificate holder for approving the aircraft for “return to service”, not having met his/her odd year renewal requirements?
b. Answer. Yes. There is no change from previous years, the IA has now expired.

3. Authorization Expiration.
a. Question. Will an IA holder that does not meet his/her first year of renewal activity requirements be required to retake the IA test?
b. Answer. No. Remember, the IA only expires in March of the odd year. (part 65, § 65.92(a)). The IA holder can take the oral test to resume activity, or renew in the second year.

4. Oral Exam for IA Renewal.
a. Question. If an IA holder comes to the office for an oral exam during the month of March 2009 (or any other time from now until then), to fulfill the requirement of performing one of the five activities required for the first year, could that person take another oral exam to fulfill the requirements for the second year, and then renew? While it appears that there is not a regulatory basis to deny a person the opportunity to take an oral test twice to renew, it creates a situation where a person could renew every 2 years by simply taking two oral examinations, theoretically on the same day.
b. Answer. Per the 2‑year current rule requirements, you are correct on the oral test issue, assuming the IA indeed still meets part 65, § 65.91(c)(1) through (4) and is not in violation of 14 CFR § 65.93(c). As an example, the IA holder performed an annual progressive, major repair/alteration while not meeting the first year activity/training/or oral test requirements to continue or resume said activity. The violation investigation/ action should preempt the oral testing process, but not prevent a subsequent oral test from being given to an otherwise eligible IA holder.

5. Requirements for IA Renewal Applicants.
a. Question. What if I am no longer actively engaged in the maintenance or repair of aircraft but I attend an FAA‑approved refresher course?
b. Answer. Part 65, § 65.93(a) requires that an applicant for renewal must continue to meet the requirements of part 65, § 65.91(c)(1) through (4). This means that an applicant must remain active in maintaining aircraft and have the equipment, facility, and inspection data available to properly inspect airframes, powerplants, propellers, or any related part or appliance.

6. Failure to Meet Eligibility Requirements for Renewal.
a. Question. What if I failed to meet the renewal requirements by March 31 of the first year of the two‑year renewal cycle?
b. Answer. If you failed to maintain eligibility for renewal in March of the first year, you may not exercise the privileges of the IA beyond March 31 of the first year. If an IA holder does not meet the renewal requirements of § 65.93(a)(1) through (5) at the end of the first year, the holder must successfully pass an oral examination administered by an FAA inspector before exercising the privileges of their certificate in the second year.

Note: The inspector should seek to determine if the IA holder has performed any activity referenced in § 65.93(1) through (3) before administering the oral test in the second year. If activity has been accomplished and that individual has not met the requirements of § 65.93(a)(1) through (5) by March of the first year, enforcement investigation action per FAA Order 2150.3, Compliance and Enforcement Program, current edition, should be initiated and the oral test not be given pending issuance of a warning notice or letter.
(1) Oral tests should be reserved for individuals, which through unusual circumstances, have been unable to meet the activity or training requirements for renewal, as specified in § 65.93
(2) The test should not be made more difficult or untimely as to intentionally prevent renewal or resumption of IA activity.
(3) Be aware that FAA inspectors may wish to verify your continued compliance with § 65.93(a)(1) through (5) as they perform routine inspections throughout the year.