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:

• FSIMS Volume 5, Chapter 5, Section 7, subparagraphs 5-1279. The inspector guidance states that actively engaged means “having an active role in exercising the privileges of an A&P Mechanic Certificate in the maintenance of civil aircraft. Applicants who inspect, overhaul, repair, preserve, or replace parts on aircraft, or who supervise (i.e., direct and inspect) those activities, are actively engaged…. Individuals employed teaching or instructing solely in an academic environment are generally not considered actively engaged. Individuals teaching and/or instructing in a 14 CFR part 147-approved Aviation Maintenance Technician School (AMTS), when also engaging in the maintenance of certificated aircraft and/or aircraft-related instruction equipment, certificated or maintained in accordance with 14 CFR, can be considered actively engaged.” (emphasis added)
• The preamble to the notice (Docket No. FAA–2010–1060). This document accompanied the change in FSIMS language that occurred in 2011, and states “Some commenters also requested actively engaged includes full-time instruction under part 147… The FAA agrees that supervision of maintenance activities provides the same sort of experience the actively engaged requirement was intended to require… The FAA previously determined involvement solely in an academic environment is not actively engaged. However, a technical instructor or part 147 school instructor may maintain aircraft or supervise the maintenance of aircraft in addition to instruction, in which case the instructor could be considered actively engaged.” (emphasis added)

Thus, while the agency has excluded purely academic instruction from the definition of “actively engaged”, it specifically included part 147 instructors, when their teaching duties include exercising the privileges of their mechanic certificate.

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.