FAA Order 8900.1, the Flight Standards Information Management System (affectionately referred to as “FSIMS,” pronounced “FIZZ-ims”) was recently revised to provide aviation safety inspectors guidance on certifying and evaluating part 147 certificated aviation maintenance technician schools (AMTS).
The changes to Vol. 2, Ch. 12, Section 1 and Section 3 include the addition of a “certification process flowchart” and instructions on issuing operations specifications. Most notable for current AMTS, the revision incorporates inspector guidance for approving distance education curriculum and ensuring the availability of missed material.
The inspector guidance seeks to limit distance learning instruction to 400 hours. The council maintains – as it did in its comments to draft Advisory Circular (AC) 147-3B – that distance learning instruction should not be limited to hours, rather by the subject matter and material and technology available to ensure the knowledge is properly conveyed.
Thanks to the efforts of Blue Ridge Community College instructor and ATEC director Fred Dyen, representatives at the FAA’s aircraft maintenance division have confirmed that the 400 hour “requirement” was inadvertently included and is scheduled for removal in the order’s next editorial update.
Also of concern is 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.” 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.
Orders are meant to provide direction to FAA employees, and not the public at large (see ATEC’s member alert on updates to Order 8900.2). However, when an inspector feels compelled to act in a particular way because of direction in “the handbook”, that decision has real practical effect to those subject to FAA regulation. ATEC maintains that additional regulatory requirements imposed through a non-legislative rule (such as an order) should be promulgated in accordance with the procedural requirements of the Administrative Procedures Act, which allow for public notice and opportunity to comment; otherwise it has no legal effect.
While many of the Order changes address initial certification, much of the criteria is applicable to currently-certificated entities. AMTS personnel should therefore ensure a proper and thorough review of the revised sections. Please send any additional comments or observations regarding the revision to firstname.lastname@example.org for inclusion in the council’s letter to the FAA addressing these concerns.
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