FAA Publishes Draft Guidelines Allowing Part 147 Schools to Manage Oral and Practical Testing

The FAA lacks the resources to handle all certification activities needed to keep pace with an expanding aviation industry. Doing this without assistance is virtually impossible. For airman mechanic certification, the FAA relies on Designated Mechanic Examiners (DMEs) to conduct individual airman testing, allowing the FAA to focus its limited resources on critical safety issues.

DMEs come from private industry and are designated to test because they are experts in their field and familiar with the regulations and certification requirements necessary to evaluate the skill and knowledge required for a candidate to receive a mechanic certificate.

Despite the approximately 250 approved DMEs in the country, testing capacity falls short of what is needed to certify the number of individuals required to meet industry demand. Twenty percent of AMTS report that a shortage of DMEs is affecting their ability to certify graduates. ATEC estimates that the mechanic designee population needs to increase by 30 percent to accommodate the current flow of graduates—with even more needed to facilitate necessary growth (see the ATEC Pipeline Report). The FAA continually cites a lack of bandwidth to oversee designees as the reason for not approving additional DMEs.

For this reason, ATEC has long advocated for the FAA to expand testing capacity by incorporating airman certification into the Organization Designation Authorization (ODA) program. The ODA program, as outlined in the current FAA Order 8100.15, was officially established in 2005 to streamline the certification process and leverage the expertise of organizations to perform certain certifications functions on behalf of the FAA. It enables organizations to issue certifications for aircraft, aircraft engines, and related components (i.e., type certification, production certification, parts manufacturer approval, etc.).

A draft revision to Order 8100.15C published on July 22 introduces a systems-based approach to oversight, largely in response to increased scrutiny since the Boeing Max crashes. Importantly for mechanic schools and employers, the draft Order also creates an Airman Certification ODA (AC ODA), allowing organizations holding an AC ODA to manage and conduct oral and practical testing for airframe and/or powerplant ratings and better meet student demand. To be eligible to hold an AC ODA, the applicant must hold an air agency certificate under 14 CFR parts 121, 135, 141, 142, 145, or 147.

AC ODA holders will not replace individual DMEs. The benefit to the FAA is that managing organizations is more efficient than managing the activities of individual designees. The benefit to industry is that the AC ODA holder would manage its own testing capacity, overseeing the activities of its “Unit Members” who would perform mechanic testing according to the ODA holder’s approved quality system.

The qualification requirements and ongoing responsibilities for ODA holders are rigorous. Organizations are required to have facilities appropriate for the type of ODA sought, sufficient administrative and technical resources to satisfy the authorization requirements, and an internal quality assurance and quality control system (including an ODA procedures manual).

Organizations are not required to hold an ODA, and it may not be the best option for most schools, especially smaller programs or those that already have sufficient DME capacity. However, for programs located in “DME deserts” with the resources to apply for and maintain an ODA, or those seeking increased testing capacity to achieve 100 percent certification of their graduates, an ODA can be a valuable investment. And adding even just a few ODA holders to supplement the existing DME network will help alleviate the increasing pressure in the testing pipeline for the entire community, as ODA holders can make testing available to any mechanic applicant, not just their own students or employees.

Comments on Draft FAA Order 8100.15C are due Oct. 21, 2024. ATEC is still analyzing the Order and expects to submit comments in support of the proposal to expand ODA to mechanic testing.

Stakeholders are encouraged to submit formal comments at https://www.regulations.gov/commenton/FAA-2024-0491-0002.

FAA personnel managing the ODA program are expected to attend the ATEC Fly-in next month. For more information and to register, visit https://www.atec-amt.org/events/2024-flyin.