On November 30, 2010, the association submitted a letter to the Federal Aviation Administration (FAA) requesting that corrections be made to its guidance regarding persons performing final inspections. Specifically, Order 8900.1 has two locations that claim individuals performing final inspections must be certificated under part 65. That guidance is incorrect.
Section 145.213(d) states that only the individual authorized to approve the work for return to service must be certificated under part 65; that person must ensure that a final inspection has been performed before issuing the maintenance release.
The individual performing a final inspection, which must occur before the work is approved for return to service (see § 145.213(a)), needs to be qualified under section 145.155, but not part 65 (see § 145.213(c)).
ARSA noted in its letter that in most cases, the persons performing the final inspection are also qualified to issue the approval for return to service and therefore this issue never arises; the story is different for repair stations that separate the final inspection function from the approval for return to service – but the rule clearly provides for that separation.