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Issue link: http://amt.epubxp.com/i/122613
STAYING LEGAL on this subject seems to be at odds with the previously announced "policy" statement of FAA in the Federal Register (where the above statements came from). It would appear to this writer that the Federal Register statements trump the nonregulatory ASI "guidance" handbook. The eight-hour seminar The focus on people who have submitted attendance at a eight-hour seminar for the basis of their renewal has been and will be the crux of the problem and the so-called "policy change" we are all familiar with. Many have suggested that since this policy has not been published in the past 30 years or so it is logical to assume that they have abandoned it. I would argue yes, they say no it is still in the regulation and they can enforce it. That is, require the "active engagement" of the applicant. Well, as we all also know, the IA is generally thought to be an "inspector" and not a "wrench" turner. The FAA not so, you must turn wrenches or supervise those that do. No one knows how much, however. This is left up to the ASI when you apply. One way to support the actively engaged requirement is to submit copies of maintenance records that describe your maintenance work performed and support your mechanic requirement. On the other hand if you submit an "activity report" showing the four annuals for each year, you get a pass on having to prove you turned a wrench … so if you don't want angst over annuals submit four for each year and you don't have to prove you turned a wrench. At least that is the requirement now. Logs and maintenance records My deceased friend Bill O'Brien always made a point of talking about annual signoffs during his presentations at IA renewal seminars while he was alive. The question always was asked … which logbook do you sign off in? Is it just in one log or the others? And yes he always made a point to say that "logbooks" are not mentioned in the FAR … you refer to all as "maintenance records" forget the term logbooks. There are many types of maintenance records … work orders, maintenance discrepancy sheets, 100-hour/annual inspection and work sheets that are required to be used for annual inspections, FBO invoices for work performed, parts identification records, etc., and many more computer-generated forms and data. All are evidence of work performed by someone, in support of your active engagement. In regard to where you sign off your annual it is the "aircraft" main- PROFILE SHEARS 2D-44 features unique scissorcutting action From ramp to back offce, FUEL MANAGEMENT MADE SEAMLESS Ops Managers Must Check This Out! Right- or lefthanded blades • Allow airlines/customer access to exclusive into-plane data and electronic ticket printing • Storage tank, refueler and inventory volumes on hand • Forecast fuel needs and time your deliveries • Instant gain/loss monitoring • Cuts a radius as small as three inches round • Light in weight and highly maneuverable • Durable, high-quality steel blades • Effortless fuel allocation & monitoring of inventories within joint-use systems • End of month reconciliation, adjustments and reporting TAUGHANNOCK AVIATION WWW.FLYTAC.COM 5055 Madison Road • Cincinnati, Ohio 45227 513-271-0333 • www.kett-tool.com AviationPros.com/company/10134514 1-800-875-1551 AviationPros.com/company/10135025 www.AMTSociety.org • www.AviationPros.com • Aircraft Maintenance Technology April 2013 33