We are trying to hire a non-A&P as an instructor. Do we need FAA approval?

Q: We are trying to hire a non-A&P as an instructor. Do we need FAA approval?

A: The regulation does not require FAA approval for non-A&P instructor hires. The AMTS is responsible for ensuring the instructor is qualified to teach the assigned content so that positive educational outcomes are achieved.
 
Here are the regulatory requirements with regard to instructor qualifications:
 
§ 147.5 Application requirements.
(a) To be issued a certificate or rating under this part, an applicant must demonstrate compliance with the requirements of this part.
(b) An application for a certificate and rating to operate an aviation maintenance technician school must include the following:
* * *
(3) A description of the manner in which the school will ensure it provides the necessary qualified instructors to meet the requirements of § 147.19; and
* * *
 
§ 147.19 Instructor requirements.
Each certificated aviation maintenance technician school must:
(a) Provide qualified instructors to teach in a manner that ensures positive educational outcomes are achieved;
(b) Ensure instructors either -
(1) Hold a mechanic certificate with one or more appropriate ratings; or
(2) If they do not hold a mechanic certificate, are otherwise specifically qualified to teach their assigned content; and
(c) Ensure the student-to-instructor ratio does not exceed 25:1 for any shop class.
 
In short, the AMTS must follow the process as set forth in its operations specifications, paragraph A013, describing how it will ensure instructors are qualified.
 
For accredited institutions, your instructor qualifications are likely driven by state and/or accreditation requirements, those policies can and should be used as the basis of your operations specifications description. In other words, the program should either cut and paste the school’s policies surrounding hiring of qualified instructors, or reference the document where those policies reside (keeping in mind that if you reference a policy and its revision number, the operations specifications must be revised as new revisions are adopted).
 
While FAA mechanic certification is very likely a required qualification for many A&P faculty positions, FAA certification is not required. If an instructor does not hold an FAA certificate, the school must ensure they are otherwise specifically qualified to teach the assigned content. And that judgment should be made by the school, not the local inspector. Of course, the FAA’s “quality check” will ultimately be the FAA mechanic test passing rate of your students.
 
AMTS can choose to but are not required to maintain an FAA operations manual. Whether you have an operations manual or not, it is recommended (but not required) that the AMTS maintain a list of current instructors and make it available to the FAA upon request. The list of current instructors should include--

• The instructor’s name;
• The instructor’s certificate number and ratings held, or, if the instructor does not hold an A&P certificate, what makes the instructor qualified; and
• Courses the instructor is qualified to teach.