1.2 IA Privileges, Limitations & Operational Authority

1.2 IA Privileges, Limitations & Operational Authority

[!IMPORTANT] The Return-to-Service Mandate: The Inspection Authorization is strictly an inspection, conformity verification, and airworthiness determination privilege, not a maintenance performance credential. When an IA approves a major repair or major alteration, they certify that the completed work conforms in all respects to FAA-approved technical data and is in a condition for safe operation. An IA cannot approve any major repair or alteration that lacks approved data, nor can they delegate their inspection responsibilities to anyone else.

Holding an Inspection Authorization confers substantial legal authority under the Federal Aviation Regulations, placing the holder in a position of direct public trust. The primary statutory framework establishing what an IA holder may and may not do is codified in 14 CFR § 65.95 (Inspection authorization: Privileges and limitations). Understanding the precise boundary between an A&P mechanic's general privileges under Part 65 Subpart D and an IA holder's specialized inspection authority under § 65.95 is one of the most heavily tested areas on the FAA IA examination.

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Statutory Scope of IA Privileges: 14 CFR § 65.95(a)

Section 65.95(a) enumerates the affirmative authorities granted to an Inspection Authorization holder. These privileges center on two major operational domains: approving major repairs and alterations, and conducting annual or progressive inspections.

Major Repairs and Major Alterations Approvals (§ 65.95(a)(1))

Under 14 CFR § 65.95(a)(1), an IA may:

• Broad Scope of Products: Inspect and approve for return to service any aircraft, airframe, engine, propeller, appliance, or component part after a major repair or major alteration performed in accordance with 14 CFR Part 43.
• The Approved Data Prerequisite: This authority is strictly conditional: the work must have been executed in accordance with technical data approved by the Administrator. If the data used to execute the repair or alteration is merely "acceptable" rather than "approved," the IA has no legal authority to sign the approval.
• FAA Form 337 Execution: When approving a major repair or major alteration, the IA executes Block 7 (Approval for Return to Service) of FAA Form 337 (Major Repair and Alteration). By signing Block 7, the IA legally certifies that they have personally inspected the repair or alteration and found it to conform to the approved technical data listed in Block 8.

Annual and Progressive Inspection Authority (§ 65.95(a)(2))

Under 14 CFR § 65.95(a)(2), an IA possesses the exclusive privilege to:

• Conduct Annual Inspections: Perform an annual inspection in accordance with 14 CFR §§ 43.13 and 43.15. An annual inspection is a comprehensive, complete-aircraft airworthiness review required by 14 CFR § 91.409(a). While an A&P mechanic may perform a 100-hour inspection, only an IA, a certificated repair station appropriately rated, or the manufacturer may perform and approve an annual inspection.
• Perform or Supervise Progressive Inspections: Perform or supervise a progressive inspection program conducted under 14 CFR § 91.409(d) and § 43.15(d). Unlike annual inspections, which cannot be delegated, § 65.95(a)(2) explicitly allows an IA to supervise a progressive inspection. Under this supervision, qualified A&P mechanics may execute routine inspection tasks while the IA maintains overall administrative and airworthiness oversight.

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Critical Limitations and Operational Prohibitions

The privileges granted by § 65.95 are matched by rigorous regulatory restrictions designed to safeguard aviation safety and prevent conflicts of interest.

The Strict Non-Delegation Principle

Inspection Authorization authority is personal and non-delegable. An IA cannot:

• Authorize another mechanic, apprentice, or helper to conduct an annual inspection and sign the aircraft maintenance records based on their findings.
• Assign their return-to-service sign-off authority to an employer, business partner, or repair station manager.
• Sign a maintenance record entry or Form 337 without having personally inspected the aircraft, system, or article. Personal inspection requires direct visual and physical examination of the work performed, verification of dimensions and tolerances, review of conformity records, and assessment of operating condition.

The Approved Data Imperative vs. Acceptable Data

A frequent area of regulatory confusion—and exam questions—is the difference between acceptable data and approved data:

• Acceptable Data: Guidance publications such as FAA Advisory Circular AC 43.13-1B contain methods, techniques, and practices acceptable to the Administrator. While an A&P mechanic may use AC 43.13-1B as acceptable data to perform minor repairs, it is not automatically approved data for major repairs or major alterations (unless explicitly authorized by the FAA or cited as an approved source in a specific directive).
• Approved Data: Technical data explicitly approved by the FAA, including:
  1. Airworthiness Directives (ADs)
  2. Type Certificate Data Sheets (TCDS) and Aircraft Specifications
  3. Supplemental Type Certificates (STCs)
  4. FAA Designated Engineering Representative (DER) Approved Data (documented on FAA Form 8110-3)
  5. FAA Aviation Safety Inspector Field Approvals (documented in Block 3 of FAA Form 337)
  6. Manufacturer Maintenance Manuals or Service Bulletins specifically designated as FAA-approved.
• The IA's Legal Boundary: An IA cannot generate approved data or approve a major alteration performed without approved data. If an alteration lacks approved data, the IA must ensure the data is submitted to the FAA for field approval or engineering review before approving the aircraft for return to service.

The One Statutory Exclusion: Part 121 Continuous Airworthiness Programs

Read § 65.95(a)(1) literally. The parenthetical exclusion is narrow and names exactly one program:

"Inspect and approve for return to service any aircraft or related part or appliance (except any aircraft maintained in accordance with a continuous airworthiness program under part 121 of this chapter) after a major repair or major alteration to it in accordance with part 43 of this chapter, if the work was done in accordance with technical data approved by the Administrator."

• What the rule excludes: aircraft maintained under a Part 121 continuous airworthiness program. That is the only aircraft class carved out of the IA's major repair/major alteration return-to-service privilege by § 65.95(a)(1).
• What the rule does not say: it does not name Part 135. A Part 135 operator that maintains an aircraft under a continuous airworthiness maintenance program per § 135.411(a)(2) will, as a practical matter, release work through its own approved program and authorized personnel under § 43.7(e), and the operator's manual controls how that aircraft is maintained. But the § 65.95(a)(1) exception itself reaches only Part 121 — do not read Part 135 into the regulatory text on the test.
• Practical effect for the IAR test: a question asking which aircraft an IA may approve after a major alteration accomplished with approved data (for example, a commuter-category multiengine turboprop and a transport-category turbojet both operated under Part 91) is answered "either one." Category, weight, and engine type are irrelevant to § 65.95(a)(1); only the Part 121 continuous airworthiness program exclusion matters.

Separation of Functions: Performing vs. Inspecting

Under 14 CFR Part 43 and Part 65:

• When a major repair or major alteration is performed, the installing mechanic executes Block 6 (Conformity Statement) of FAA Form 337 using their A&P certificate number.
• The approving IA executes Block 7 (Approval for Return to Service) using their Inspection Authorization number (or mechanic certificate number with "IA" designation).
• While a single dual-rated technician holding an IA may perform the work as an A&P and then inspect and approve it as an IA, the two legal capacities are distinct. An IA authorization conveys no performance authority—the right to perform maintenance flows entirely from the underlying A&P certificate.

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Administrative Responsibilities: Display and Relocation

Under 14 CFR § 65.95(b) and (c), an IA must comply with specific operational rules:

• Presentation of Authorization (§ 65.95(b)): The IA must keep their authorization available for inspection. They must present it upon request to:
  1. The aircraft owner or operator.
  2. The mechanic submitting the aircraft, repair, or alteration for approval.
  3. The FAA Administrator or an authorized representative.
  4. An authorized representative of the National Transportation Safety Board (NTSB).
  5. Any Federal, State, or local law enforcement officer.
• Change of Fixed Base of Operations (§ 65.95(c)): If an IA relocates their fixed base of operations, they may not exercise the privileges of the authorization until they have notified the responsible Flight Standards office (or International Field Office) for the new area in writing of the change. This restriction takes effect immediately upon the move.

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Comparison Matrix: IA Privileges vs. Limitations

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Common Exam Traps & Regulatory Distinctions

• Delegation of Annuals: An IA cannot delegate any part of an annual inspection to an apprentice or an A&P. The word "supervise" in § 65.95(a)(2) attaches only to progressive inspections — read the sentence carefully, because the exam builds distractors on exactly this asymmetry.
• AC 43.13-1B as Approved Data: AC 43.13-1B is acceptable data, not approved data. An IA cannot approve a major alteration based solely on AC 43.13-1B without an approved field approval or engineering substantiation.
• Change of Base Notice: Written notice to the FSDO must precede the exercise of privileges; verbal notice or post-inspection notification is a regulatory violation under § 65.95(c).
• 100-Hour vs. Annual Sign-Off: An A&P can sign off a 100-hour inspection, but signing an annual inspection requires an IA (or repair station/manufacturer).