Q: Are part 147 instructors considered "actively engaged" for purposes of meeting part 65 inspector authorization (IA) renewal requirements?
A: Part 65 provides IA eligibility and renewal requirements. Specifically, § 65.93(a) bases renewal on an individual’s ability to show that he or she still meets the original eligibility requirements, namely, § 65.91(c)(2) which requires that an applicant be “actively engaged, for at least the 2-year period before the date he applies, in maintaining aircraft certificated and maintained in accordance with this chapter…” The term “actively engaged”, and its applicability to part 147 instructors, is specifically addressed in:
Therefore, if an instructor at a part 147 institution can show that their duties and responsibilities include supervising or performing maintenance (meaning inspection, overhaul, repair, preservation, and the replacement of parts, but excluding preventive maintenance, see § 1.1), or supervising maintenance, they should be considered "actively engaged" for purposes of IA eligibility and renewal.
Q: Does an AMTS need to keep every test issued to every student of every class offered for the two year record limit?
A: No. As provided for in § 147.33(a)(1), each AMTS "shall keep a current record of each student enrolled, showing attendance, tests, and grades..." On its face, the language does not require filing each and every test for every student, only that it is recorded. Filing every test would require lots of physical or data storage space. Plus, now in our technological world many schools provide computerized knowledge testing, just like the FAA through commercial testing centers where only the "grade earned" is the record. Of course, if an FAA Inspector doing surveillance over a particular grade issued to a student for a specific test given, the AMTS should be able to provide a sample of that test.
This position is supported in the language of AC 147-3B, paragraph 3-4 entitled Records, Transcripts, and Graduation Certificates, which states that "records must clearly show attendance, tests, quizzes,http://fsims.faa.gov/PICDetail.aspx?docId=8900.1,Vol.6,Ch10,Sec1 and practical projects grades received on subjects required" (emphasis added) and in 8900.1, Vol. 6, Ch. 10, Sec. 1, paragraph (c), which also speaks to the recording of grades, not filing or storing individual student's tests.
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