On July 10, ATEC sent a letter to FAA headquarters concerning recent changes to FAA Order 8900.1 (“FSIMS”), Vol. 2, Ch. 12, Section 1 and Section 3 and Advisory Circular (AC) 147-3B (see previous story http://www.atec-amt.org/member-alerts/-faa-updates-fsims-for-amts-certification-and-evaluation). In its letter the council requested revision to provisions regarding distance education and the availability of missed material.
Most of the language contained in FSIMS (directed at FAA inspectors), conflicts with the AC language (directed at industry). Most notably, the order contains guidance that would “limit” distance learning instruction to 400 hours of level one instruction, a provision that was removed in the final version of AC 147-3B (as recommended in ATEC’s comments to draft AC 147-3B).
Similarly, inspector guidance for implementation of § 147.31(e), which requires that the AMTS system “show hours of absence allowed and how missed material will be made available to the student,” is not consistent with AC 147-3B or part 147. The order’s language goes beyond the scope of the regulation, specifically “requiring” that all missed projects and assignments be “made up” and the manner in which that must be accomplished.
In its letter the Council also requested some edits to AC 147-3B to ensure consistency and to clarify ambiguities in that recently-revised document.
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