Jose Delacruz Salazar

Document ID: FAA-2010-1060-0004
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: November 08 2010, at 12:00 AM Eastern Standard Time
Date Posted: November 8 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: November 5 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: December 6 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b84e06
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I agree that some type of definition is required that would better clarify and standardize this actively engaged meaning. However, training is another issue that some IA's do not have when working on different types of General Aircraft. Going to an IA Seminar or taking on-line courses is just meeting the minimum requirement for people who just want their IA certificate to continue. Yes, they are deemed as qualified and are renewed on this basis as required by the regulation but, it's not considering the safety aspects of aviation unless specialized training is somewhat emphasized. This would hopefully eliminiate IA's that apply a signature for annuals when they are not really qualified or trained to do so. This situation unfortunately creates the difficulty of ASI's in determining actively engaged when IA's rarely work for a living. There needs to be some type of method or way that specialized training coincides with the IA's who are not familiar with various aircraft maintenance tasks and have this training be accountable towards their IA renewal. With the Safety Management System concepts coming down the pipe, this IA arena will be a factor to consider in General Aviation in the future. Maybe we should consider revising our regulations to reflect these issues and safety concerns. It could minimize General Aviation accidents by having more accountability for IAs.

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