VOLUME 3 GENERAL TECHNICAL ADMINISTRATION
Section 5 Safety Assurance System: Part
142 Training Centers: Outsource
Training—Air Operators and/or Fractional Ownership Program Managers Contracting With Training Providers
3-4409 GENERAL. This section provides policy guidance for principal
operations inspectors (POI) that have operators or receive requests from their
operators to outsource a portion of their required crewmember training. The
information in this section may also be useful for Training Center Program Managers
(TCPM), operators, and training center managers (TCM). This section is related
to Safety Assurance System (SAS) Element 2.1.4, Outsource Crewmember Training.
A. References. In addition to adopting Title 14 of the Code of Federal Regulations (14 CFR) part
Federal Aviation Administration (FAA) also revised applicable sections of 14 CFR parts
91 subpart K (part
provide a means for crediting the training, testing, and checking accomplished in flight simulation training devices (FSTD) toward the flight
training requirements of those parts. The adoption of part
operators to pursue training alternatives not previously available under the regulations. Part
made the use of training centers by operators more widely accepted as an alternative means of providing training to its employees.
NOTE: “Alternative means” as used in part
in some cases been misunderstood and has been interpreted to mean that compliance with a training center’s approved courses will meet the training
requirements required by the appropriate operating rules for an operator. This
is not the case. “Alternative means” permits an operator to outsource or arrange
to have its approved training conducted by a third party. It does not mean that
an operator has an “alternative means” to meet the training approval requirements
governing its particular operation. Programs approved in accordance with part
not be used as an alternative means of satisfying the requirements of the appropriate operating rules as approved by the operator’s POI.
B. TCPMs and POIs. As the use of training centers continues to
increase, the interrelationship between a center’s TCPM and an operator’s POI
have become increasingly important. When an operator wishes to use the services of a part
142 training center, the
most common operational issues that POIs must resolve—and this section will address—are outlined below:
1) Exactly what portion of the operator’s required crewmember
training, checking, and/or testing will the center be authorized to conduct?
2) What qualification requirements are necessary to enable training
center flight instructors to conduct the requested training? (Refer to part
121.414; and part
3) How does the operator propose to qualify Training Center Evaluators
(TCE) or other personnel to become contract check airmen? (Refer to §§
4) What documentation is required to ensure the training conducted
by the center complies with the operator’s approved curriculums, and how does the operator propose to document this training?
3-4411 BASIC STRUCTURE.
A. Operating Rules. The operating rules of parts
operators to use the services of another operator certificated under the same part or a certificated part
142 training center to
conduct some or all of their required crewmember training. If approved by the operator’s POI, an operator may use the training
provider’s facilities, equipment, and personnel to varying degrees to accomplish
the training, checking, and testing required by their approved training program.
B. Training Curriculum. Regardless of who actually developed
an operator’s training curriculum, the operator is responsible for its approval,
oversight, content, and currency. Regulations are very clear regarding an operator’s
requirement to have appropriate crewmember training programs that support their
particular operation. The regulations are also clear concerning the requirement
to have these programs approved by the Administrator. In the case of the operator,
this approval is delegated to the operator’s POI. In similar fashion, training centers certificated under part
also required to have their curriculums approved by the Administrator.
For training centers, the approval authority is delegated to the center’s TCPM.
C. Arrangements. The following cases are the two most common
arrangements that are formed between air carriers and training centers.
1) Case One—Dry Lease.
a) The least complicated way in which an operator may use the facilities
and equipment of a training center is through a “dry lease” agreement. In this
case, the operator has developed and maintains its own approved training curriculum,
associated courseware, materials, checklists, procedures, and personnel to conduct
training and checking, but elects to dry lease flight training equipment and facilities from a training center. Associated airman certification functions
and proficiency requirements are completed by check airmen employed by the carrier
(not the training center), the operator’s aircrew program designee (APD), or
the FAA. The operator accomplishes recordkeeping, although required training records may be maintained at the training facility if approved by their POI.
POIs will make all enhanced Vital Information Database (eVID) entries concerning
the operator’s check airman activities. The operator’s POI approves the use
of the center’s flight training equipment; however, the operator is responsible
for ensuring that the center’s equipment and facilities continue to meet the
standards required to accomplish required training. The training center simply
acts as a host for the operator and center personnel are not involved in the training or checking of the operator’s crewmembers.
b) POIs are responsible for providing required surveillance to determine
if contracted facilities and training equipment meet the requirements for continued
approval. Due to the center’s physical location in relation to the POI’s office,
the POI may request the center’s TCPM to provide information concerning the
training center facility and equipment as well as assistance in performing required surveillance.
c) Operators who conduct training in this manner (dry lease) are
not outsourcing their training from another training provider and therefore
do not require approval for outsourced training in their Operations Specification
(OpSpec)/Management Specification (MSpec)/Letter of Authorization (LOA) A031, Outsourced Training.
2) Case Two—The Training Center Provides Facilities, Instructors, and/or Evaluators Under Contract to the Operator.
a) The second most common way operators use the services of part
142 training centers is to enter
into an agreement with the center to provide instructors and/or evaluators to act on behalf of the operator in the conduct
of the operator’s training curriculum. In this situation the operator may have
developed their own training curriculum, hired a consultant to develop the curriculum,
or adopted the training center’s curriculum. Regardless of the source, each
curriculum must be approved by the operator’s POI for their use. However, it
is not uncommon for operators to adopt one of the center’s core or specialty curriculums and submit it without revision, to their POI for approval. Prior
to submitting a center-developed curriculum to their POI for approval, the operator
must conduct a detailed review and comparison and analysis of the center’s curriculum,
courseware, procedures, equipment, and personnel to determine if the training
center’s curriculum will meet their operational needs. If the operator determines
that the center’s curriculum will meet their needs, they may submit it to their
POI for approval. If the POI accepts the submitted curriculum and grants approval,
the curriculum becomes part of the operator’s approved program, and in effect
becomes the operator’s curriculum. This trend is particularly evident among part
new entrant part
for whom the development of a complete in-house pilot qualification program using modern FSTDs often entails prohibitive costs and logistics.
b) Training center personnel (flight instructors) conducting flight
training activities for an operator must be trained and qualified in accordance
with the air carrier’s approved program to become eligible to conduct training under the air carrier’s approved curriculum (§§
135.340; or §§
appropriate). If an air carrier wishes to have the center provide flight checking or testing services, the air carrier must ensure nominated individuals
are trained and qualified as a check airman in accordance with their approved training program (§§
135.339; or §§
91.1093, as appropriate).
c) The center may maintain the operator’s training records if approved
by the POI. However, the responsibility for the adequacy of the records remains with the operator, not the training center.
d) If the operator elects to nominate one or more of the center’s
personnel to act as a contract check airman, and the operator’s POI authorizes
such check airmen, the POI must maintain all check airman entries in the eVID. In other words, whether an operator uses their own personnel as check airmen
(as outlined in Case One) or elects to use center employees as contract check airmen, all required eVID entries relating to check
airmen will be made by the POI. This will help ensure that both the POI and the operator maintain proper
operational control over persons performing check airmen/contract check airmen functions.
e) The POI must be assured that the center’s facilities and equipment
are adequate to conduct the training the operator is proposing. The center’s
TCPM is one of the POI’s best sources of information to enable him/her to make
the determination that the center’s facilities and training equipment are adequate
for the proposed operation and to assist with required surveillance activities.
f) Operators who wish to engage a training center to accomplish the
aircraft-specific training modules of their curriculum create special surveillance
requirements. The division of an operator’s required training between the operator
and a training center creates a unique recordkeeping situation as well as specialized
training for the center instructors. POIs must be extremely vigilant in determining
who is accomplishing each element of the operator’s program and that the complete
program is accomplished. POIs should communicate regularly with the training
center’s TCPM and are encouraged to request assistance with surveillance of
the operator’s activities at the training center. The TCPM’s assistance will
typically afford the POI greater flexibility and a higher level of surveillance
than would normally be possible without the TCPM’s assistance. An operator should
develop and keep up to date a “Training Source Document” or similar statement
detailing what training will be provided in-house and what will be conducted
by the training center. See the FAA’s Air Transportation Division (AFS-200),
Air Carrier Training Systems and Voluntary Safety Programs Branch (AFS-280) Web site for a sample of such a document.
CURRICULUMS. A short review of the various types of training center curriculums and their approval process will assist with our understanding
of the appropriateness of these curriculums for use by an operator. It is important
to emphasize that a center’s approved curriculum may not be used by an operator
without first being evaluated for appropriateness and secondly, being approved for use by the operator’s POI.
A. Core Curriculum.
1) A core curriculum is a training center-developed course that
is approved by the Administrator (through the TCPM) for the purpose of meeting the training and certification requirements of airman under
parts 61 and/or
63. (Refer to §
2) In order for a training course to be approved as a core curriculum it must:
a) Meet the applicable requirements of part
B and part
b) Contain all the events and maneuvers required by the appropriate
practical test standards for
the issuance of the particular Airman Certificate for which the curriculum was designed;
c) Meet the requirements of the Flight Standardization Board (FSB) report for that specific aircraft;
d) Consist of training segments that identify training and testing
requirements for the issuance of a particular certificate;
e) Follow the guidance in
Volume 3, Chapter 54, Section 6, Part
142 Training Centers: Evaluate
Training Programs, Curriculums, Flight Training Equipment, and Recordkeeping Requirements and
Volume 3, Chapter 19, Section 5, Flightcrew
Aircraft Ground Training Curriculum Segments concerning ground and flight training threshold hours; and
f) Include maneuver descriptions, standard operating procedures (SOP), checklists, and other supporting courseware.
training curriculums are designed to meet the certification requirements of part
therefore do not include many of the operator-specific elements required
by the operating rules associated with an air carrier/operator. For example, a part
curriculum does not require a training center to specify the training
that is normally found in an operator’s OpSpecs, such as authorized takeoff
or landing minimums, types of authorized approaches, and captain high minimum
requirements. Additionally, ground training in areas such as hazardous materials
(hazmat) handling, security, aircraft maintenance, logbook procedures, and flight following is also not required to be part of a part
142 training center’s core
curriculum. Although a training center’s part
core curriculum may meet the aircraft specific requirements for an operator, these curriculums do not qualify operator’s pilots for line
operations and may not be used by an operator without the specific approval of the operator’s POI.
B. Specialty Curriculums. This term refers to courses that are
designed to satisfy a particular requirement of 14 CFR chapter I (parts
than airman certification under parts
63. The Administrator
(through the TCPM) is authorized to approve specialty
curriculums for use by a training center and, if appropriate, associated satellite and/or remote sites (refer to §
centers often develop specialty curriculums to meet the specific needs of a particular customer. Some examples of specialty curriculums
include (but are not limited to) Category II/III authorization, equipment differences
training, night vision goggles (NVG) and so forth. Specialty curriculums can
vary widely in focus and subject matter and may be developed for personnel other than flightcrew members (refer to §
approval of specialty curriculums or courses by a training center’s TCPM, however, does not enable those curriculums or course to be used
by an operator without the specific approval of the operator’s POI.
3-4413 ROLES, RESPONSIBILITIES, AND COORDINATION. The safety, efficiency,
and quality of training provided by training centers, through the use of structured
programs and FSTDs, has proven to be an effective and economical means for some
operators to accomplish required training. Consequently, a number of operators have come to rely on part
142 training centers as
a source of technical expertise and as their primary training provider. As the use of approved training centers continues to expand,
it becomes increasingly important to understand the roles, responsibilities,
and coordination activities required of each participant. Subparagraphs A through
D of this paragraph that emphasize the regulatory roles and responsibilities
as well as the coordination required between operators and training centers
when an operator is using a training center to conduct a portion of their required
training program. Subparagraphs A through D of this paragraph do not focus on
day-to-day activities associated with the surveillance of training centers or
operators outside of the context and scope of this section. It is presumed that
these activities are being conducted in accordance with the guidance located
elsewhere in this chapter, associated regulations, orders, and policy guidance.
A. Air Operators. The regulatory responsibility for ensuring
that an operator’s training program remains current and continues to meet the
operator’s needs resides with the operator, not the training provider. When
an operator makes application to use the services of an authorized training provider they must:
1) Ensure that all training, testing, and/or checking to be conducted
by the training center has been approved by the POI before any training is accomplished.
2) Develop an instructor/check airman standardization program
including a checklist, which clearly identifies those elements of the operator’s
program that are to be completed by the training center and those that are to
be completed by the operator. This checklist must specifically identify each
training element that will be conducted by the center and include the regulatory and/or the training program reference for each item.
NOTE: A sample air operator standardization review may be found on the
AFS-280 Web site. The sample program is designed to be all-inclusive and therefore
not every item covered in the sample may be applicable to all operators. The
sample is intended to be comprehensive and include sufficient detail to ensure
the training provider has an accurate understanding of the operator’s training
requirements. The FAA suggests that each subject in the sample standardization
program be reviewed with a potential training provider to ensure a complete understanding of each party’s role.
3) Develop an implementation plan to perform oversight of center
facilities and personnel engaged in the conduct of the operator’s training and
associated evaluations. The operator’s implementation plan must:
a) Ensure that all training center personnel selected to act as contract
instructors (both ground and flight) and/or contract check airmen are appropriately
trained and qualified. Flight instructors and/or check airmen must be qualified in accordance with the operator’s approved program. (Refer to §§
121.414; and §§
135.340, as appropriate.)
NOTE: Operators must complete a detailed comparison between their check
airman curriculum and that of the training center’s TCE curriculum to determine
what, if any, additional training must be provided to qualify the center’s personnel
to act as a contract check airman. Elements of the center’s instructor/TCE training
curriculum that the operator finds equivalent to their training program may,
with the POI’s approval, be credited toward the completion of the operator’s
instructor/check airmen curriculum. If the center’s curriculum is approved as
meeting the requirements of the operator’s curriculum, other than the operator
specific items, no additional training for the center’s personnel would be required.
Any differences or deficiencies noted will require the operator to develop a
training module to ensure all regulatory requirements are met and to qualify
the center’s personnel as contract check airman. This module that includes the
operator-specific subjects must be presented to the operator’s POI for approval/acceptance.
b) Provide the center with appropriate administration procedures
and instructions to be used in the accomplishment of agreed training.
c) Provide for the oversight of all contract center personnel who
are authorized to conduct training, testing, and/or checking on behalf of the operator.
4) Additionally, the following procedures must be followed when
requesting the use of center personnel to become qualified as contract check airmen:
NOTE: These procedures follow the guidance outlined in Volume 3, Chapter 20, and should be accomplished in the order shown.
a) Evaluate the instructor’s/TCE’s credentials to ensure he or she
meets company requirements to become a contract check airman;
b) Evaluate the individual’s training record to determine the differences
training required to qualify the individual as a contract check airman;
c) Develop an appropriate training differences module(s) to qualify
the center’s instructor/TCE as a contract check airman and submit the training module to the POI for acceptance/approval; and
d) Conduct and record appropriate check airman training; submit the
individual’s name, short resume, and training records to the POI for review and approval in accordance with Volume 3, Chapter 20.
NOTE: POIs should notify the center’s TCPM whenever they authorize one
of the center’s personnel to act as a contract check airman by forwarding the TCPM a copy of the contract check airman’s LOA.
5) Coordinate the approval of FSTD missing, malfunctioning, or
inoperative (MMI) equipment procedures that will be used in support of the operator’s curriculum.
1) When an operator requests the use of a training center’s facilities,
FSTDs, curriculums (core and/or specialty), flight instructors, TCEs, and/or
other services, including recordkeeping, the POI is responsible for determining
the operator’s request conforms to the appropriate regulations, policies, and procedures.
2) The approval authority for an operator to conduct training
at a training center resides with the operator’s POI, and must conform to the
training program approval process outlined in Volume 3, Chapter 19. If an operator
wishes to use a training center’s core and/or specialty curriculums to meet
a portion of their required training program, it is the operator’s responsibility to ensure:
a) The center’s curriculums/courses meet the operator’s training requirements.
b) The curriculums are submitted to the operator’s POI for review
and approval in accordance with the procedures outlined in
Volume 3, Chapter 1, Section 1.
c) The curriculums are integrated into the operator’s training program.
NOTE: If the curriculums are approved for the operator’s use, these
curriculums now become a portion of the operator’s approved training program,
and the maintenance/currency of those curriculums becomes the responsibility of the operator, not the training center.
3) If an operator applies to have the same training curriculum
conducted by two or more centers (either operated by the same or a different
training provider/company), the operator must develop an implementation plan
for each center and ensure that each of the approved centers conducts their
training curriculum using the operator’s approved training curriculum (including
maneuvers, procedures, and checklists). Additionally, each center must be specifically
approved for use by the POI and listed in the operator’s OpSpec/MSpec/LOA A031.
It is the responsibility of the operator to ensure that all required software
and hardware approved to support the subject curriculum is available and used
by each center during the delivery of their training curriculum. See subparagraph 3-4414D for additional guidance.
NOTE: POIs should notify the center’s TCPM whenever they authorize one
of the center’s personnel to act as a contract check airman. This may be accomplished
by forwarding the TCPM a copy of the contract check airmen’s LOA. POIs are encouraged
to contact the center’s TCPM for assistance with the review and potential approval
of a contract check airman. TCPMs are often the POI’s best source of information
relating to a center’s operation and personnel. A sample contract check airman LOA is located on the AFS-280 Web site.
4) When an operator requests approval of a training provider’s
personnel, to act as contract instructor and/or contract check airmen to conduct
a portion of their required training, it is the operator’s responsibility to
ensure those individuals are qualified to conduct the subject training. Prior
to authorizing a center’s flight instructors or TCE(s) to conduct any portion
of an operator’s training, the operator must qualify each individual in accordance
with the training and testing requirements of their operating rule and provide
sufficient evidence of such training and checking to the POI for review and approval.
an observation of each authorized flight instructor to be accomplished at least once every 24 months. Additionally, §§
an observation of each simulator and aircraft check airman to be accomplished at least once every 24 months.
similar requirements for flight instructors and evaluators. However, part
these observations to be conducted at least once every 12 months. (Refer
to §§ 142.53(a)(1) and
a) The intent of these regulations is to ensure the continued standardization
and quality of each operator’s training program by performing periodic observations
of each flight instructor and check airman by focusing on the individual’s performance
in conducting a representative part of a curriculum or training program approved for that operator.
b) A qualified inspector or APD may be requested to observe contract
flight instructors and contract check airmen on behalf of the POI. Whether conducting
its own training or contracting for training with a training provider, each
operator must ensure that all required observations are accomplished and documented. A training center’s part
of their flight instructors may meet the requirements for the center under part
not meet the requirements for an air carrier under part
121 or part
an observation might be acceptable for a portion of an operator’s requirement under the following conditions:
1. When the training curriculum or curriculum segment conducted by the
training center is essentially the same as that of the operator.
NOTE: Training program components may be viewed as “essentially the
same” when they comprise identical checklists, operational procedures, and callouts,
and flight deck layouts and flight manuals (fm) which are compatible in the
judgment of the operator’s POI. Training program components, which relate to
like-aircraft types, are dissimilar when they do not meet the criterion for
“essentially the same.” When differences are too pronounced or too numerous
in the judgment of the POI, flight deck layouts and fm must not be viewed as compatible.
2. When the observation is acceptable to the operator’s POI.
c) An observation conducted by the FAA is always permissible instead
of an observation conducted by an approved check airman or by a designated examiner
employed by the operator. An observation by an FAA inspector counts toward the
observation requirements of all operators contracting for training program services
provided by a training center. POIs and TCPMs may conduct an observation at
any time at their discretion. It is anticipated that operators and training
centers will exchange information regarding observations of their instructors.
However, it is the responsibility of the operator to ensure that all required observations are kept current and are documented.
6) Conduct training center surveillance to determine continued compliance with the operator’s approved program.
7) If the operator requests approval of two or more centers,
determine that all training, testing, and checking is conducted using the operator’s
approved curriculum. To ensure standardized training for all of the operator’s
crewmembers, it is essential that, before authorizing multiple sources of training,
the operator provides the POI with a surveillance plan to ensure continued compliance
with their approved curriculum by all centers. Each authorized training center
must conduct the operator’s curriculum as approved by the operator’s POI and
be alike in content, training times, maneuvers descriptions, procedures, checklists,
and FSTDs. If a training center is providing the same training program to two
or more operators at the same center, it may be permissible (with the operator’s
permission) to interchange crewmembers during the flight training phase. This
may only be accomplished providing the individual operator’s training curriculums
are essentially similar, including aircraft checklist, flows, emergency procedures,
and profiles. In this example, two separate but identical programs are being accomplished simultaneously.
8) Determine that FSTDs are appropriate to, and representative
of, the aircraft being operated by the air carrier. Flight training equipment
must be specifically qualified and approved for the operator’s use, as well as each maneuver, procedure, or crewmember function to be trained.
9) Each training facility must be authorized and listed in the operator’s OpSpec/MSpec/LOA A031.
10) Each training curriculum/module approved to be conducted by
a training provider must be listed, by curriculum title, in the operator’s OpSpec/MSpec/LOA A031.
11) Review the operator’s instructor/check airman standardization program.
NOTE: A sample instructor/check airman standardization program can be found on the AFS-280 Web site.
12) Review the operator’s training center audit program.
NOTE: Many of the training centers used by operators are located in
areas apart from the operator’s primary operations base and are often outside
of the geographical area of its assigned certificate-holding district office
(CHDO). This makes routine surveillance of the training center difficult for
POIs and increases the coordination necessary between the CHDO and the FAA office
with geographical oversight responsibilities. Under these conditions, it is
very important that the POI and CHDO work closely to ensure adequate surveillance
of the operator’s approved training facilities, equipment, and curriculums.
13) Ensure that required airman training records meet regulatory
requirements. If requested by the operator, the POI may permit the training
provider to maintain the operator’s crewmember training records. However, the
operator must be advised that they (the operator) remain responsible for the
security, accuracy, and availability of all required records. Permitting a training
center to maintain operators’ records does not relieve the POI of required check
airman/APD tracking requirements outlined elsewhere in this order or the POI’s office Quality Management System (QMS) policies.
C. TCPMs. From time to time, TCPMs may be called upon to assist
a POI whose operator is using the services of a training center. The TCPM’s
firsthand knowledge of center personnel, facilities, equipment, and curriculums
is a valuable resource that POIs have come to rely on. This knowledge enables TCPMs to:
1) Provide the POI information regarding the status and approval
level of FSTDs and the installed equipment used by center instructors and TCEs;
2) Assist the POI by providing technical information regarding the center’s curriculums, FSTDs, and facilities; and
NOTE: TCPMs should advise the POI of any status change involving an
instructor or TCE that is also approved as a contract check airman for an operator.
3) Assist the POI with the evaluation of TCEs or other training center personnel
nominated by the operator to become contract check airmen or flight instructors.
The procedures outlined in Volume 3, Chapter 20, will be followed when evaluating
center personnel as potential contract check airman candidates. Aviation safety
inspectors (ASI) (e.g., TCPMs) must use the following Program Tracking and Reporting
Subsystem (PTRS) codes to document surveillance of contract check airmen:
· Check Pilot Observation—Proficiency Check Oral or §
Test (or any portion thereof): 1641.
· Check Pilot Observation—Proficiency or Competency Check
· Check Pilot Observation—Proficiency or Competency Check §
135.293(b) or §
135.297 (Aircraft): 1643.
NOTE: If the TCPM is observing a TCE, then a PTRS activity using code
1673 (for a TCE observation) should also be completed whether a check pilot observation is being completed or not.
4) Assist the POI with required surveillance activities including:
a) Potential contract check airmen;
b) Observing contract check airman during the evaluation of the operator’s
airman to ensure evaluations are objective, accurate, and consistent with the operator’s program;
c) Evaluation of required crewmember training records that were authorized to be maintained by the training center; and
d) Other surveillance activities appropriate to the operator’s activities at the training center.
NOTE: In all cases, the TCPM’s assistance is subject to their office’s workload requirements.
D. Training Center(s). A training center’s roles, responsibilities, and coordination activities include:
1) Participating in the operator’s instructor/check airman standardization
program to ensure there is a clear understanding between the center and the
operator of exactly what portions (by regulation) of the operator’s approved curriculums the center will be conducting.
2) Ensuring the operator has received approval from their POI
to use center facilities and personnel in the conduct of their approved curriculums.
3) Establishing a naming convention that will enable operator-approved
curriculums/courses to be distinguished from center-approved curriculums. Operator
programs are not to be referred to as core or specialty, as these terms are only appropriate for TCPM-approved center curriculums/courses.
NOTE: Training centers are not required to list operator names or the
operator curriculums/courses in the center’s training specifications (TSpec).
Only the center’s TCPM‑approved core or specialty curriculums/courses are required to be listed in the center’s TSpecs.
4) Ensuring that all center personnel used to instruct and/or
check on behalf of the operator have been appropriately trained, evaluated,
and authorized in accordance with the operator’s approved curriculums to conduct
such activities. This training must include, at a minimum, training in all portions
of the operator’s curriculums for which the contract instructors/check airman are assigned to conduct on behalf of the operator.
5) Ensuring that sufficient contract instructors are qualified
to support the operator’s training agreement and requirements.
6) Recommending (not qualifying) center personnel as potential
contract check airman. The center must ensure recommended individuals:
a) Have completed the center’s approved instructor training program, and
b) Are currently qualified and actively participating in one or more
of the center’s core curriculums appropriate to the operator’s needs.
7) Maintaining the center’s FSTDs in accordance with their qualification standards.
NOTE: If a Simulator Component Inoperative Guide (SCIG) has been developed
for a particular full flight simulator (FFS), and the training agreement with
an operator includes FFS training, make sure the SCIG has been approved for operator’s use.
8) Advising the operator whenever flight training equipment fails
to meet required qualification standards and/or when maintenance problems will restrict training.
9) Ensuring required training records are appropriately maintained
and remain readily available to both the Administrator and operator.
10) Ensuring crew pairing policies and procedures are adhered
to as it relates to the operator’s training and testing/checking.
NOTE: Crew pairing policies and procedures may be found in paragraph 3-4414.
11) Advising operators of any proposed revisions to the center’s
curriculums that are being used partially or in total by the operator.
3-4414 OUTSOURCED TRAINING PROVIDER APPROVAL PROCESS.
A. Application to Outsource Required Crewmember Training.
1) Operators requesting approval to outsource a portion of their
required flightcrew member training must submit an application in a form and
manner prescribed by the Administrator. The application must contain sufficient
detail to enable the Administrator to evaluate the applicant’s request. Applications
must be submitted a minimum of 60 days prior to the proposed training and contain at least the following information:
a) A copy of the standardization review including an analysis of
the training provider’s curriculums, courseware, procedures, equipment, facilities,
and personnel that will be used in the conduct of the operator’s training.
b) A detailed outline, by regulatory reference, of the training elements proposed to be outsourced.
c) If center personnel will be used as contract instructors to conduct
the operator’s training, the application must contain an appropriate training
module developed to qualify center’s instructors/TCEs on the operator’s curriculum.
d) If center personnel are being requested to act as contract check
airmen, the application must contain an appropriate training module developed
to qualify center’s instructors/TCEs as contract check airman for the operator. (See paragraph 3-4415 for complete details.)
e) A copy of the operator’s instructor/check airman standardization program.
f) A copy of the operator’s proposed surveillance plan to ensure the center continues to provide the agreed training.
g) Proposed method to maintain required crewmember, contract instructors,
and contract check airman training records including the methodology proposed
to ensure curriculum revisions and an appropriate instructor/check airman read file are maintained.
h) Other data that the POI may require to evaluate the application.
2) The approval for an operator to use a part
142 training center or
other provider in the conduct of their required training is authorized through the issuance of OpSpec/MSpec/LOA A031. An initial standardization
review must be conducted by the operator and submitted to the POI before any
contract training or checking may be conducted. OpSpec/MSpec/LOA A031 also requires
the operator to conduct ongoing audits of the training center/provider to ensure
the training center is continuing to provide training and checking in accordance
with the operator’s approved program. The initial audit must be completed within
60 days of the commencement of contract training or checking operations.
Each audit with evaluation must be presented to the certificate holder’s POI
for review and acceptance within 30 days after completion. Ongoing audits will
be conducted at least every 24 months in order for the operator to continue
to use the training center/provider. Guidelines for the scope and content of
the operator standardization and audit program are located on the AFS‑280 Web
site. Additional information is contained in paragraph 3-4416. If an operator
does not conduct the required 24-month audit, their authorization to use the
training center/provider will cease on the last day of the 24th month following
the date of their last audit. Operators may reapply to use the training center/provider
by completing the application process outlined in accordance with the provisions of subparagraph 3-4414A.
3) A sample outline of the modules and elements of an operator’s
curriculum that are typically contracted out to a training center can be found
on the AFS-280 Web site. These curriculum checklists have been developed to
provide a guideline for the operator and center in determining which regulatory
requirements may be satisfied by the training provider and which will be completed by the operator.
B. Flight Training Equipment.
1) In order to receive training/checking/testing credit for the
use of a FSTD, the specific FSTD must be a part of the operator’s approved curriculum.
The subject curriculum and FSTD are a part of the outsourced training audit
and must include a comparison of the aircraft flown by the operator to the flight
training equipment available at the training center. The comparison should encompass
the make, model, and series (M/M/S) (and serial number, in some cases) of the
aircraft and FSTD and include a summary of the flight instrumentation, autopilot,
flight management system (FMS) equipment, aircraft modifications (electrical
system, hydraulic system, engines, propellers, thrust rev, heads-up display,
etc.) applicable to each. Regulations require that the flight training equipment
fully meet the requirements of the operator’s training program and accurately
represent the M/M/S of aircraft flown by the operator including installed equipment.
If the flight training equipment available at the training center does not match
the operator’s aircraft, the operator’s program must state how any differences
between the aircraft and the FSTDs will be addressed and develop an appropriate differences training module.
2) A TCPM’s approval of a center’s FSTDs for use within the center’s
approved curriculum does not authorize an operator to use the same FSTDs within
the operator’s curriculum. The TCPM’s approval only ensures that the FSTDs are
approved to conduct the training, testing, and checking permitted under part
142. In order
for an operator to use a center’s FSTDs in support of the operator’s curriculum, the operator must include the FSTDs in its training program
and have the FSTDs approved by its POI. The operator’s POI will evaluate the
requirements of the operator’s program and make a determination concerning the
appropriateness of the center’s FSTDs and their qualification as it relates
to the operator’s curriculum. POIs may request verification of the flight training
equipment authorized for use by a training center by contacting the center’s TCPM.
3) To receive training credit for a particular FSTD, the FSTD
must first be qualified by the National Simulator Program (NSP) (AFS-205) and
be assigned a specific level of qualification. TCPMs and POIs may than approve
the FSTD for use by a center or operator respectively, by specific maneuver(s),
procedure(s), and crewmember function(s). Approval letters are generally issued
to operators and centers specifying the FSTD’s use within a specific curriculum.
Operators are authorized the use of FSTDs through the inclusion of the FSTD in their training program.
C. Approving/Accepting a Center’s Core or Specialty Curriculums for Use by an Operator.
1) Training centers often submit programs to their TCPM for approval
that are targeted for specific customers and/or operators. However, these curriculums must meet part
and are either “core” or “specialty” as defined by part
a curriculum is approved by the TCPM, it is listed in the center’s
TSpecs as a core or a specialty curriculum/course. For an operator to use a
center-developed curriculum it must submit the curriculum to its POI for approval.
The procedure for approving a center-developed curriculum is the same as if
the operator had developed the curriculum or paid a consultant to develop the
curriculum. The important point to remember is that when the subject curriculum/course
is approved by the operator’s POI, it becomes part of the operator’s training
program and as it relates to the operator, it ceases to be either a core or a specialty curriculum.
2) Once the subject curriculum/course is approved by the operator’s
POI, the center, when conducting training for the operator, should refer to
the subject curriculum by the name given to it by the operator. It is important
to note that the training center should not refer to the operator’s program
as a specialty curriculum. This naming convention is important to clarify oversight
and ownership responsibilities for the subject curriculum/course. An operator’s
programs are approved by its POI in accordance with the appropriate operating rule.
a) Training center curriculums, both core and specialty, are approved by a TCPM in accordance with part
designed to meet the training, testing, and checking requirements of airmen certification under part
b) The flightcrew member requirements of parts
in numerous respects to part
A TCPM’s approval of a center’s curriculum does not enable
an operator to use such curriculum without the specific approval of the operator’s POI.
3) In order for an operator to request a training center’s approved
curriculum to be incorporated into their program, the operator must first complete
a comparison between the proposed center’s curriculum to their approved curriculum.
All differences must be noted and a training module developed to bridge the
differences. This training module will be used to qualify the center’s instructors
and/or TCEs on the operator’s curriculum. It is the operator’s responsibility
to ensure all center instructors and/or proposed contract check airmen receive
training on the differences module(s) developed as a result of the curriculum
comparison before they may be authorized as contract instructors or contract check airman for the operator.
4) The operator may find that a center’s curriculum may be used
without change but that there may be minor differences in operating procedures
and/or checklists. As part of the standardization and audit process, the operator
must determine all differences between their curriculum and the center’s. If
the differences found are minor, the operator’s POI may authorize the operator
to develop a briefing guide outlining the differences as a suitable method to
provide the training necessary to qualify the center’s personnel. Major differences
between the curriculums will require specialized differences or formal retraining
of the center’s personnel. In all cases, the operator’s regulations require
contract instructors and check airman to be trained in the approved methods,
procedures, and limitations for performing required normal, abnormal, and emergency procedures appropriate to the curriculum segment.
5) Operators must have training policies and procedures in their
operations manuals or training program that describe their standard operating
procedures and type of operation(s). At a minimum, operators that apply to contract
a portion of their required crewmember training to an authorized provider must
have policies and procedures in place that clearly identify the following:
a) This portion of the operator’s program must clearly define these
functions and their procedures to ensure adequate training is conducted and recorded.
b) SOPs, including but not limited to:
· Crew coordination and “callouts,”
· Maneuvers descriptions and aircraft configuration,
· Flight deck “flows,”
· Checklist procedures,
· Autopilot use and crew coordination,
· Crew resource management, and
· Approach procedures (including approach charts, crew briefing,
Electronic Flight Bag (EFB) use, etc.).
6) POIs and operators must be aware that training center-approved
curriculum are designed to meet the certification requirements of parts
not required to include operator-specific items required by part
curriculums are required to meet the certification requirements of parts
practical test standards. Consequently, part
142 training center curriculums
will not comply with the operating rules governing an air carrier and by default
do not contain or reference operator-specific requirements or the limitations/authorizations contained within an operator’s OpSpecs/MSpecs.
7) If an operator is introducing a new aircraft and requesting
the adoption of a center’s curriculum in support of the introduction, the operator
is responsible for ensuring the proposed curriculum meets their operational requirements. Additionally the operator must:
a) Evaluate the proposed curriculum and submit it to their POI for approval/acceptance.
b) Develop a module(s) outlining any operator-specific training required
to qualify center personnel as contract instructors and or contract check airman based on the POI’s authorized curriculum.
c) If a contract check airman is being proposed, the operator must
provide the selected individual with any operator specific training identified during the curriculum approval process.
d) Submit an appropriate contract check airman request to their POI
a minimum of 15 working days prior to the proposed use of the contract check airman.
8) Table 3-122A, Sample—Weight and Balance Curriculum Module
Comparison Chart, provides an illustration of the differences that normally
occur when an operator completes a comparison and evaluation of a Weight and Balance (W&B) training module that was designed for a part
142 training center against
one designed for an air carrier. The table also illustrates the complexities typically encountered by an operator when conducting
a curriculum comparison between their approved training program and that of a training center.
9) Column A in Table 3-122A lists the elements normally associated with an approved part
training module. Column B represents a typical part
training module. These differences are a result of the requirements of §
require operators to train and check their pilots on their (the operator’s) method of determining compliance with W&B limitations. Part
the center’s curriculum to comply with part
is typically modeled after the manufacturer’s procedures. When confronted with these differences, an operator must decide to either:
a) Train and qualify the center’s instructors to enable them to conduct the operators approved W&B training module; or
b) Providing there is no negative training involved, permit the center
to conduct the manufacturer’s weight, balance training, and then conduct a specialized
course designed to cover the differences between the center’s curriculum and
that of the operator. If the operator chooses to permit the center to conduct
the center’s W&B module, the operator would then be required to convene
a separate instructional period to train and test the differences between the
center’s curriculum and its (operator’s) W&B curriculum. This differences
training would be required prior to releasing any crewmember for line operations.
c) As mentioned in subparagraph 3-4414C9)a), the operator could elect
to provide W&B training to one of the center’s instructors in those elements
of their curriculum that are different from the center’s curriculum. It would
then be possible for the qualified instructor to conduct the entire W&B
module for the operator’s crewmembers. However, without specified training in
the operator’s procedures, the center may only be authorized to provide training
and testing in those subjects that are part of the center’s curriculum (Table 3-122A,
lines 1–4). In either case, operators must develop a quality control program that will ensure their entire
curriculum is conducted in accordance with their approved procedures and conducted
by qualified individuals. The Instructor/Check Airman Standardization Program
located on AFS-280 Web site has been designed to provide assistance in this area.
Table 3-122A. Sample—Weight and Balance Curriculum Module Comparison Chart
Aircraft Manufacturers Weight & Balance Procedures (Airplane Flight Manual (AFM))
Aircraft Manufacturers Weight & Balance Procedures (AFM)
Load Shift/Fuel Management and Use
Load Shift/Fuel Management and Use
Operations Specifications (Paragraph A096, A097,
Carry-on Baggage identification and load and storage
Passenger Weight determination—average, surveyed,
Baggage/cargo weight determination
Cabin Configuration and loading
Baggage Compartment loading and security
Air Carrier Computation method (computer)
1: Topic may comply with the operator’s approved
curriculum. However, the use of company-developed flip charts, computers,
“WIZ Wheels”, etc., may require specialized training. Differences evaluation
2 through 4: Topics may comply with the operator’s
approved curriculum. Differences evaluation required.
5 through 13: Topics do not conform to the operator’s
14: Applicable to the particular curriculum. Differences
10) The curriculum an operator submits for approval to its POI
must contain sufficient detail to assure all required training is addressed.
The operator is responsible for submitting the subject curriculum to its POI
for review, approval/acceptance, and subsequent inclusion in its training program, before any training is accomplished by the training provider.
11) This document will be jointly developed by the training provider
and the operator, and will specify the division of all tasks required for training/testing/checking
between the training provider and the operator. (Other equivalent methods that
specify the division of tasks may be acceptable.) The operator bears the primary
responsibility to ensure that all ground and flight training required by their
specific operating rule is conducted and appropriately evaluated. The POI’s
oversight responsibility is to ensure that the operator’s compliance efforts
are satisfactory. The POI should check sign-offs (certifications) of ground
training and all testing for completeness, and should cross-check those sign-offs
against the source document showing the division of tasks. For example, part
must ensure the training required by §
conducted and all subjects required by §§
evaluated. A properly executed standardization document between the operator and the training provider will provide guidance to both parties
concerning the training and testing/checking obligations for each party. A sample
Instructor/Check Airman Standardization Program is located on the AFS-280 Web site.
NOTE: Training centers are not certificated as air carriers or commercial
operators and are not issued OpSpecs/MSpecs. The operator-specific requirements
of an air carrier’s operating regulations make it impossible for a part
142 training center to
have a training curriculum approved under those regulations. TCPMs may only approve training center curriculums that comply with part
centers may develop curriculums designed to comply with the operating rules of an air carrier; however, the curriculums cannot be approved
as “meeting” the requirements of those parts. Training center instructors and
evaluators are likewise qualified in accordance with a center’s approved curriculums
and therefore cannot conduct an air operator’s training without first being
qualified by an air operator before conducting any of the operator’s required training. (Refer to §§
§§ 135.337 through
on the content of a particular center’s instructor/TCE training curriculum, an operator may be able to credit a portion of the center-provided
training as meeting some of their required instructor/check airman training requirements.
12) When a center revises one of their core or specialty training
curriculums that originally formed the basis of an operator’s approved curriculum,
the center should be encouraged to advise the operator of the revision. However,
it is important to understand that revisions to a center’s core or specialty
curriculums, which were used as the basis of an operator’s training curriculum,
does not automatically create a revision to the operator’s POI-approved course.
The adoption of such changes is subject to the operator’s evaluation and approval
by its POI. Center revisions that are considered appropriate for the operator’s
program may be incorporated by the operator if approved by the operator’s POI.
Likewise, the operator may make changes to its curriculum, in which case they
must notify the center and ensure that all contract instructors and contract
check airman are trained in the new procedures (differences). Operators must
be especially vigilant to ensure that changes to the training center’s core or specialty curriculums do not affect the training they receive.
D. Air Carrier Training at Multiple Training Centers.
1) Occasionally, an air carrier will request that training be
conducted at two or more training centers. These centers may be owned by the
same parent company, satellite centers of the same certificate holder, or may
be training centers operated by different companies. It is common practice for
training centers operated by different owners/companies to take varied approaches
to curriculum design and development for the same aircraft M/M/S. These differences
often include training equipment, training hours, maneuvers description, operating
procedures, and checklists. When evaluated individually, each variant may be
perfectly acceptable for the specific aircraft; however, as training products
for an air carrier these differences, although subtle, are not consistent with
the standardization requirements demanded by air carrier regulations. To ensure
standardized training is provided, it is essential that before authorizing the
use of multiple sources of training, the air carrier and subsequently the POI
determine that the same curriculum and syllabus, including courseware, flight
training equipment, maneuver descriptions, procedures, checklists, etc., will be conducted by each provider.
2) Subtle differences between or among training providers may
not create standardization difficulties for non-certificated operators. However,
because air operators are required to have their own approved programs, differing
curriculum between or among training providers is not authorized. Training conducted
by different centers will present a standardization problem if not properly monitored and managed by the operator.
3) To qualify a center’s personnel to conduct an operator’s training
curriculums will require the operator to conduct an evaluation of the center’s
curriculums to determine what, if any, differences exist between the two and
provide center instructors and evaluators training in those differences. This
process must be repeated for each center authorized to conduct training for
the operator. If a contract check airman is requested, the additional training
appropriate to the operator’s check airmen training will also have to be completed.
4) If POIs have reason to believe that multiple centers can provide
the quality training required by the operator’s approved curriculum, they may
authorize two or more facilities or training companies to conduct the subject
training. However, if the POI suspects that an operator curriculum cannot be
adequately presented at multiple centers due to differing delivery methods,
FSTDs training hours, maneuver descriptions, qualified personnel, etc., and/or
the operator’s ability to adequately monitor and audit the training being provided,
the POI and the operator have the responsibility to limit the number of training providers.
E. Training Policy and Procedures.
1) Operators are required to develop and document, as part of
their approved program, adequate procedures and policies to ensure all training
providers conduct the operator’s crewmember training as approved. These procedures
may be part of the operator’s manual used by the certificate holder’s flight
personnel in conducting its operations and/or contained in the operator’s approved training program.
2) Operators must establish training policies and procedures
to ensure crewmembers are trained and evaluated in accordance with the policies
and procedures that represent the manner in which it conducts its aircraft operations.
It is unacceptable to have differences between training/checking and actual aircraft operations or between individual crewmembers.
3) POIs are not to approve requests for outsourced training unless
the operator’s program contains appropriate policies and procedures to ensure
the training conducted by the authorized training provider(s) is in accordance with the operator’s approved program.
NOTE: Operators must ensure that approved training providers are provided
at least one copy of their operating manual(s), including the revision service
for such manuals, which cover the particular areas that the training provider
has been approved to conduct. The operator must also ensure the training provider
maintains a “read file” specific to the operator that is available to all contract
instructors, contract check airmen, and the operator’s crewmembers. This read
file must contain information pertinent to their flight operations and crewmember
operating procedures. See the Instructor/Check Airman Standardization Program on the AFS-280 Web site for additional information.
4) An operator that determines a center-developed curriculum
is suitable for its use must receive its POI’s approval to integrate the subject
curriculum into its training program. See subparagraph 3-4414C for policies
and procedures for the integration of a center’s curriculum into an operator’s program.
F. Crew Pairing.
1) Training centers often provide services to air operators which
must meet requirements of particular operating rules (i.e., parts
these rules, training programs include checklists, callouts, profiles, approach procedures, and other features that are approved for the
specific air operator by its assigned POI. Occasionally an operator may not
be able to assign a complete crew for its training/checking/testing activities at part
142 training centers. When
this situation occurs, the training center may provide a qualified crewmember that meets the requirements outlines in the operator’s
2) The FAA promotes the crew concept in air carrier training
and checking to ensure that crew coordination and other flight management issues
are adequately and appropriately addressed. Flight training must address the
performance of duties as Pilot Flying (PF) and pilot monitoring (PM) as described
in the air operator’s approved procedures. To meet both of these seat-dependent
training needs, each required flight deck crew position must be occupied by a qualified crewmember.
3) It is desirable that each flight training session be scheduled
so that two pilots from the same company or air operator may be trained during
a single flight training session. The preferred crew pairing is a pilot in command
(PIC) and a second in command (SIC). Other acceptable crew pairings are two
PICs or two SICs employed by the same certificate holder. Each pilot receiving
training should have completed the appropriate aircraft ground training, including basic indoctrination, prior to beginning the flight training segment.
4) Permissible crew pairings. Some air carriers often operate
with small pilot rosters or with pilots who are widely dispersed. Providing
the operator’s training program does not otherwise restrict crew pairings for
flight training/checking/testing in a FSTD at a training center, the center
may use the following guidelines when determining who may be considered an appropriate crewmember.
a) An appropriate crewmember must be one of the following:
1. One of the air carrier’s line qualified pilots,
2. One of the air carrier’s pilots undergoing training for the same aircraft, or
3. A contract flight instructor (airplane or simulator) or a contract
check airman (airplane or simulator) who is authorized to serve in that air carrier’s training program.
b) The following conditions apply when a part
carrier pilot is training in an FAA‑approved training program for another part
carrier, whose training program is essentially similar.
· When the training curriculums are not essentially similar,
pilots may not be paired; similarly, when operational differences between carriers
are too pronounced or too numerous, at the discretion of the appropriate POI, pilots may not be paired.
· Each air carrier pilot must be trained in accordance with the
training program approved by the POI of his or her own air carrier.
· Minimum equipment lists (MEL), OpSpec/MSpecs, and other features
specific to each air carrier’s operations must be addressed during flight training.
· When only one pilot is receiving flight training, the other pilot
seat must be occupied by a person who is line qualified or line familiar in the specified duty position (see the current edition of Advisory Circular (AC)
Operational Simulations: Line Oriented Flight Training, Special Purpose Operational Training, Line Operational Evaluation, for definition
of terms), unless the flight training is being conducted for single pilot operations.
NOTE: Training programs may be viewed as essentially similar when they
include the same curriculum, the same checklists, and the same callouts and
include flight deck configurations, operational procedures, and fms that are compatible in the judgment of the appropriate POI.
c) Pilots must have completed the operator’s applicable ground training
curriculum segments prior to starting the flight training curriculum segments.
5) Pairing pilots in flight training and evaluation for operations
under different parts. When pilots from different operators are paired in training
programs that are essentially similar, the operator-specific features (such
as MELs and OpSpecs/MSpecs) of each operator must be addressed. Pilots in training for part
should not routinely be paired with pilots training for operations under part
crew pairings should be avoided in favor of the pairings outlined in subparagraph 3-4414F4). However, such crew pairings are permissible provided
the following conditions are met:
a) The part
must conform to the training program of the part
in every respect. Specifically, checklists, profiles, approach procedures and callouts must be those used in the training program of the part
(not vice versa), and the part
must understand and apply Crew Resource Management (CRM) principles in accordance with the air transport pilot
practical test standards.
b) Each certificated air operator’s crewmember must complete the appropriate air operator’s evaluation module. Part
may support the part
training activities as appropriate.
paired with an air operator crewmember must use the operator’s approved curriculum. In these cases, the TCPM must either concur with the part
use of the air operator’s curriculum to complete required training
and currency, or approve a documented process submitted by the training center
that ensures all requirements described herein are met. The training center
should maintain records of such pairings in sufficient detail to allow FAA inspectors
to easily determine compliance with the applicable regulation, operator’s crew pairing procedures (if provided) and these requirements.
d) The part
must have received differences training in the features of the part
curriculum that distinguishes it from the part
curriculum. That training should also include the operator’s OpSpecs and operational control procedures.
NOTE: In crew pairings involving pilots of different part
or pilots operating under different operating rules (parts
and TCPMs must be especially vigilant.
The part 135 operator’s
training program must not be distorted or diminished in order to accommodate dissimilar training needs. If the integrity of the air carrier
training program cannot be upheld the crew pairing must not be permitted.
1) Regulations require an operator to maintain training and qualification
records for each crewmember, flight instructor, and check airman. This requirement
includes contract instructors and contract check airmen employed by training
providers that are authorized to provide training and checking for the operator.
The means and methodology of maintaining required crewmember records must include
an acceptable process to record training, checking, and qualifications of the
operator’s crewmember training conducted by an outsourced training provider.
The operator’s training program should contain a description of their recordkeeping
system as well as describing what records are to be used to comply with each
regulatory requirement. If the operator wishes to use an electronic recordkeeping system, the current edition of AC
and Use of Electronic Signatures, Electronic Recordkeeping
Systems, and Electronic Manuals, provides guidance for the evaluation and approval of these systems.
2) Operators and training providers must establish and document
procedures to ensure they have a clear understanding of their individual responsibilities
for complying with required training and testing/checking recordkeeping requirements.
These procedures must include identification of responsible personnel and approved location(s) where specific records will be maintained.
3) Training conducted by center personnel must be documented
in accordance with the operator’s approved system. Center personnel acting as
contract instructors and/or contract check airman for the operator must also be trained in the operator’s records system.
4) Training centers are not required under part
maintain an air carrier’s crewmember training records when the training
was accomplished in accordance with the operator’s approved program. Training
centers are only required to maintain the records required to support the training accomplished under part
leads to airman certification or proficiency required by part
operator’s crewmembers are not trained and evaluated in accordance with part
are trained and evaluated in accordance with the operator’s operating
regulations and approved curriculums. Therefore, the responsibility for record
maintenance remains with the operator. Training centers that have been authorized
to provide training for an operator are considered to be an integral part of
that operator’s training program. In that context, FAA policy permits the center
to be used as a suitable location for required records if approved by the operator’s
POI. Many training centers provide a large portion of an operator’s training
and in some cases are the sole providers of such training, which may make the center a logical location for such records.
training centers to maintain the training records of their instructors and TCEs. When these individuals are also approved as contract instructors
and/or contract check airman for an operator, it may also make sense for the
operator to have its instructor and/or check airmen records maintained by the
center. It is, however, the responsibility of the operator to ensure that all
crewmember records are readily available for inspection as required by applicable regulations.
6) Operators must ensure that training records developed and
maintained by their training providers are available in a timely manner. Records
of crewmember training and checking are required to be furnished to the operator
upon completion (within 24 hours) of any training and/or checking in order to
enable the operator to determine qualifications for crew assignment(s). Training
and qualification records for contract instructors and contract check airman must also be made readily available to the operator.
7) In many cases, the TCPM will be the best qualified individual
to assist the POI with required inspections, proficiency checks, and observations
of assigned operators. Properly maintained records will also enable the TCPM
and training centers to provide information on instructors and TCEs to other operators that may need instructor and evaluator assistance.
8) A TCE who is authorized as a contract check airman may be
approved by one or more POIs to conduct checks for multiple operators that have
contracted with a training center. This may occur when multiple operators of
the same aircraft type have contracted for training at the same center and are using essentially the same curriculum.
9) Although not required, training centers that maintain contract
check airman records for operators may be a good source of information for other
operators who are evaluating center personnel as potential contract check airman.
10) Training centers must have a process whereby they keep customers
apprised of all training or checking conducted on the operator’s behalf. Additionally,
the center must notify the operator within 24 hours if there is a job functions
status change with a TCE or instructor who is also a contract check airman or
contract flight instructor for the operator that may affect the individual’s check airman or instructor status with the operator.
11) TCPMs are responsible for maintaining eVID information regarding
the training center, its instructors, and evaluators. POIs are responsible for
maintaining eVID files pertaining to each training center employee authorized as a contract check airman.
3-4415 REQUIREMENTS TO AUTHORIZE CONTRACT FLIGHT INSTRUCTORS AND/OR CONTRACT CHECK AIRMEN FOR AN AIR OPERATOR.
A. Requirements. Sections
operators to provide enough flight instructors and
check airmen to conduct the flight training and flight checks required by the applicable operating rules.
1) The determination of a “sufficient” number of contract check
airman and/or contract instructors for a particular operator will require a careful evaluation of the following:
· Number of APDs authorized by the FAA and employed by the
· Geographic location of the operator with respect to
available FAA support;
· The operators understanding that they are required to
provide surveillance and supervision of their contract instructors/check airman;
· Availability of FSTDs and location relative to the operators
crewmember domiciles; and
· Operators required crewmember training and evaluation workload.
2) There is no fixed formula that will definitively answer the
question of how many contract check airman/instructors are appropriate. Maintaining
an equitable balance between the operator’s ability to provide required management
oversight and surveillance, while meeting their evaluation requirements without compromising standardization or safety, is a primary concern.
B. Qualification and Training Requirements. The qualification
and training requirements for individuals to become contract flight instructors
and/or contract check airmen for an air carrier are outlined in the specific regulations governing the type of operation (specifically part
N, and/or part
H, as appropriate). Training center instructors and evaluators are trained and qualified under part
which does not mirror the instructor and/or check airmen qualification
requirements of an air carrier. Although some of the instructor/evaluator training required by part
be considered equivalent to the instructor/check airmen training required by an air carrier, the two currently do not align. The differences
between these two regulatory requirements will generate additional training
requirements for training center instructors and evaluators selected to provide training and checking services for operators.
C. Instructors. Consider the case of a part
142 training center flight
instructor (simulator) who is qualified to provide
instruction under the training center’s approved core curriculum for a particular aircraft.
1) In order for a training center instructor to serve as a flight
instructor for an air carrier, the individual must be trained and qualified
to instruct in each training segment, module, or element of the air carrier’s
curriculum that the instructor will be responsible for providing to the air
carrier’s crewmembers. Current policy does not require center instructors to
complete the carrier’s entire approved training program or curriculum provided:
a) The individuals are limited to conducting only the training elements
of the operator’s curriculums that they have been specifically trained and qualified to conduct and have been authorized by the operator; or
b) The individual has had previously received the same training,
proficiency/competency checks, and observations in the same M/M/S aircraft for another air carrier operating under the same part.
2) Situations where an air carrier adopts a training center’s
core or specialty curriculum(s) and the POI approves these curriculums as part
of the air carrier’s training program would also mitigate some of the training
required by the operator to qualify the subject instructor. In this situation
the only training the air carrier would be required to provide the center’s
instructor(s) would be limited to any differences that exist between the training
center’s curriculum(s) (as approved by the TCPM) and the air carrier’s training curriculum (as approved by the carrier’s POI).
NOTE: In such cases, it is the air carrier’s responsibility to identify
each difference between the carrier’s approved training curriculum (including
curriculum content, checklists, and procedures) and the training center’s curriculum.
The air carrier must than develop and provide their POI a training module to
qualify the center’s personnel on all noted differences. This differences training
module must be approved by the POI prior to conducting the subject training.
3) The air carrier’s POI has the responsibility to determine
if the manner and method proposed by the air carrier to train and qualify the
center’s personnel on curriculum differences, will meet the operator’s training requirements.
D. Review. To ensure the center’s personnel meet the operator’s
check airman standards, the operator will need to review the individual’s training
history and qualifications. Elements of the center’s instructor/TCE training
curriculums that the operator finds equivalent to their training program may,
with the POI’s approval, be credited toward the completion of the operator’s
instructor/check airmen curriculums. If the center’s curriculum has been submitted
to the POI for approval and is approved as meeting the requirements of the operator’s
curriculum, other than the operator-specific items, no additional training for
the center’s personnel would be required. Any differences or deficiencies noted
will require the operator to develop a training module to ensure all regulatory
requirements are met in order to qualify the center’s personnel as contract check airmen.
1) In addition to the instructor qualification and testing requirements
outlined in subparagraphs 3-4415B and C, operators must accomplish the following to qualify an individual as a contract check airman:
a) Evaluate the instructor’s/TCE’s credentials to ensure he or she
meets the certificate holder’s requirements to become a contract check airmen.
NOTE: Individuals must have at least one year of experience as a center
instructor or TCE in the make and model aircraft in order to be considered as
a contract check airman for an operator. POIs are encouraged to contact the
center’s TCPM for assistance with the review and potential approval of contract
check airman. TCPMs are often the POI’s best source of information relating to a center’s operation and personnel.
b) Evaluate the center’s instructor and TCE training curriculum by
comparing it to the operator’s check airman curriculum to determine the differences
training required to qualify the center’s personnel as a contract check airman.
c) Develop an appropriate differences training module(s) to include
the operator-specific elements of the check airmen qualification and training/checking
regulations to qualify the center’s instructor/TCE as a contract check airman.
d) Submit the contract check airmen training module(s) to its POI for acceptance/approval.
e) If the training course is approved, ensure the course is provided to all contract check airmen candidates.
f) Provide the POI with complete training records and submit the
individual’s name and résumé for review and approval in accordance with Volume 3, Chapter 20.
g) If the applicant is approved as a contract check airman the POI will make the necessary eVID entries.
NOTE: POIs should notify the center’s TCPM whenever they authorize one
of the center’s personnel to act as a contract check airman. This may be accomplished
by forwarding the TCPM a copy of the check airman’s LOA. A sample contract check airman LOA is located on the AFS‑280 Web site.
E. Categories of Authorization. The standard categories of authorization
for check airmen currently shown in Volume 3, Chapter 20 do not provide the
level of specificity required for the approval of contract check airmen. For
example, an operator’s check airman, qualified as a line captain may be authorized as a simulator only check airman permitting them to administer both §
135.293(a)(1) through 8) as well
as § 135.297 evaluations.
A contract check airman who is only qualified in the aircraft-specific modules of an operator’s curriculum may be authorized to conduct
simulator-only evaluations; however, he or she would be limited, due to his or her training, to evaluations of §
135.293(a)(2) and (b) and §
Unless the contract airman is qualified in the operators complete curriculum for the specific aircraft, he or she may not be authorized
to conduct the elements required by §
(a)(3) through (8). Other restrictions may also apply depending on the training and qualification provided by the operator. A sample contract
check airmen LOA is located on the AFS-280 Web site.
F. Training of Instructors and Evaluators.
1) Because the typical training program offered by the training
center currently does not include all of the ground training subjects contained
in an operator’s curriculum, it follows that neither the trainees nor the instructors
and evaluators themselves receive training in those subjects. It is important
to ensure all training center instructors and evaluators are trained and evaluated
in all subjects that the center is contracted to conduct. For example, because
the typical training program offered by the training center currently does not include ground training in the subjects contained in §
(a)(4)–(8), it follows that neither the trainees nor the instructors and evaluators themselves receive training in those subjects—which
ignores the training requirements of §§
a training center evaluator typically is not qualified to evaluate subjects other than those contained in the center’s core curriculum which equates
to § 135.293(a)(2) and
potentially (3). Similarly, a trainee should not be evaluated in those subjects by individuals not qualified in the operator’s procedures.
NOTE: To preclude any confusion concerning a contract check airman’s
authorization, the POI must specify in each contract check airman’s LOA what specific subjects the check airman is authorized to test and check.
2) Particular caution must be exercised to ensure that individuals
being nominated by an air carrier to become contract instructors/check airmen
have a good understanding of the issues typically faced by crewmembers on a
daily basis, many of which are learned only through the completion of an air
carrier’s initial new hire training curriculum. Knowledge of an air carrier’s
operational environment becomes very important when instructors/check airmen
may be required to draw upon that knowledge to ensure that the quality of training
and evaluations demanded by the regulations is not compromised. Non-aircraft-specific
issues such as flight following/dispatch, MEL/Configuration Deviation Lists
(CDL), cabin crew/flightcrew interactions, hazmat, security, company SOPs, etc.,
play an important role in a crewmember’s training; especially during Line-Oriented
Flight Training (LOFT) events. To effectively function as an air carrier instructor/evaluator, individuals must have a good understanding of these issues.
3) Before an air carrier authorizes a contract instructor or
nominates an individual to become a contract check airman, the air carrier must
provide its POI with evidence that these individuals have completed at least
one air carrier’s initial training and qualification curriculum as a flightcrew
member for an operator certificated under the same 14 CFR part. Providing the
operator and the assigned POI find this training and qualification acceptable,
individuals may be considered to have met the non-aircraft-specific training
requirements to become a contract instructor/check airman. The completion of
an operator’s line check requirement(s) is not required. Following the completion
of an appropriate differences training curriculum, the subject individuals may
be authorized as contract instructors and nominated to become contract check
airman. This process should preclude an individual from conducting training
and checking in an air carrier environment without ever having had the benefit
of, at a minimum, the training required to qualify an individual to act as required crewmember for an air carrier.
G. Proficiency Evaluations. The proficiency evaluations required
by an air carrier to qualify and maintain the currency of its check airmen are
also applicable to center personnel that are being nominated as contract check airmen for the operator.
NOTE: TCPMs are only required to verify that the center’s TCEs receive annual training on the conduct of part
functions in accordance with part
C, relating to the curriculums approved for the training center’s
use. As outlined above, this training and checking does not qualify an individual
to act as an operator’s check airman. Operators must complete a detailed comparison
between its check airman curriculum and that of the training center’s TCE curriculum
to determine the extent of the additional training they must provide to qualify
the center’s personnel to act as a contract check airman on their behalf. If
this comparison indicates that the operator’s training programs are identical,
other than the operator specific items, no additional training for the center’s
personnel is required. Any differences noted between the curriculums will require
the operator to develop a training module to qualify the center’s personnel
as a check airman. This module must be presented to the operator’s POI for approval/acceptance.
H. Contract Instructors/Check Airmen. Training center employees
that have been qualified by an operator to serve as a contract instructor/contract
check airman may be considered qualified to act in the same capacity for another operator provided that:
1) Both operators are certificated under the same 14 CFR part.
2) Both operators are operating the same M/M/S of aircraft with identical configurations.
3) Both operators are using identical training curriculums, including checklist and operating procedures.
4) The requesting operator finds the subject individual acceptable as a contract instructor/check airmen.
5) The subject instructor/check airman has met the operating
or observation experience requirements for at least one operator for which they
are providing services. For example, if a training center instructor is qualified
to provide instruction in a particular aircraft for three different operators,
the instructor may be considered to have met the initial and recurrent line
operating or observation requirements for all three by remaining qualified in one of the operator’s programs.
NOTE: In all cases, the acceptance of an instructor/check airmen’s qualification
by another operator is subject to the approval of the requesting operator’s POI.
I. Reports. The POI should arrange to have the operator provide
the POI with a periodic report of each check airman’s checking activities, including
a pass/fail rate, to coincide with the POI’s periodic review (annual, semiannual,
or other). POIs may arrange for these reports to arrive at a time that meets
the POI’s needs. A contract check airman should be active enough to retain the
required knowledge and skills. This activity level may vary depending on the
contract check airman functions and other operators for which he or she is authorized
check airmen activities, the size of the operator, and the number of approved
check airmen. Usually a check airman should conduct at least eight authorized
check airman activities during a 12-month period (including supervision of Operating
Experience (OE)). The POI should specifically reassess the operator’s need for those check airmen whose records indicate low activity levels.
3-4416 OUTSOURCED TRAINING PROVIDER AUDITS AND ASSOCIATED OPSPEC/MSPEC PROCEDURES.
A. Self-Audit Program. The FAA requires a mandatory self-audit
program for operators certificated under the provisions of parts
contract with a training provider to conduct a portion of their required crewmember training. Such training arrangements are informally known
as outsourced training. POIs will use OpSpec/MSpec/LOA A031 to record FAA approval of these contract training arrangements.
B. Operator Responsibility. The FAA is often limited in its ability
to oversee an air carrier’s training operations conducted under contract by
a training provider(s). This oversight is the primary responsibility not of the
FAA, but of the operator itself. The operator holds an air carrier certificate
as a privilege granted by the Administrator on the presumption that the operator
will continually maintain the highest safety standards, including flightcrew
training standards. The operator must ensure that its flightcrew training conducted
by a contractor continually meets the requirements set by regulations and the standards contemplated at the time of initial certification.
NOTE: The current edition of AC
Carrier Internal Evaluation Programs, recommends a voluntary self-audit strategy for air carriers that may be readily adapted to continuing
analysis and surveillance of outsourced flightcrew training.
C. Self-Audit and Summary Report. The self-audit and summary
report cycle outlined in this section may be used as the first phase of a plan
to implement more effective operator-driven quality assurance (QA) where outsourced
flightcrew training is concerned. The cycle must be conducted at least every
24 months in accordance with OpSpec/MSpec/LOA A031, and should be conducted
at any time that a major change affects the operator’s outsourced flightcrew training.
D. POI Verification. POIs must verify that their operators arranging
with training providers to conduct contract training for their crewmembers,
otherwise known as outsourced training, will accomplish the following activities.
a) Training Program Components: Adherence to Approved Program. The
operator must document that the training program delivered by the training provider
is identical to the training program approved for the operator’s use by the POI. The documentation will address at least the following:
· The format and content of curriculums, curriculum segments,
training modules, and documents depicting flight maneuvers and procedures;
· Facilities; and
· Qualifications of instructors and check airmen.
b) Training Curriculums: Adherence to Approved Program. The operator
must audit curriculums and document that those curriculums presented by the
training provider adhere to the curriculums contained in its FAA-approved training
program. The documentation must address at least the following, including ground training and flight training curriculum segments:
· Initial new-hire training;
· Upgrade training;
· Transition training;
· Recurrent training;
· Refresher training (121 only);
· Initial equipment training;
· Requalification training; and
· All other approved training such as differences, related aircraft
differences (121 only),
hazmat, security, and crew resource management, as appropriate.
c) Flight Training and Testing/Checking: Adherence to Approved Program.
The operator must observe all contract instructors and contract check airman
who are conducting required instruction and evaluations on their behalf by center personnel. The operator must document that regulations contained
in §§ 91.1089 through
121.414; or §§
appropriate, are being met and that approved standards are being maintained. Documentation must address at least the following, as applicable:
· Certification flight checks;
· Proficiency checks, and instrument proficiency checks (parts
· Flight checks (part
· Flight training in lieu of the proficiency check, including
· Competency checks;
· Maneuver validation (Advanced Qualification Program (AQP));
· Line operational evaluations.
d) Training Records: Completion of All Approved Training. The operator
must review required training and testing records to ensure compliance with
their operating rule. This review must cover all of the operator’s crewmembers,
including pilots, FEs, and flight attendants (F/A) who have received outsourced
training since the last review cycle. The operator must document that each crewmember
has successfully completed all of the required components of training and checking comprised by its approved training program.
2) Summary Report. The operator must prepare a report, summarizing
the findings of its self‑audit. A sample report is on the AFS-280 Web site.
This sample report form may be used to compile self‑audit findings and to submit
findings to the POI as a summary report. Another form mutually acceptable to the
operator and the POI may be used instead. The summary report must be signed
by the operator’s director of operations. In all instances that discrepancies
are found between the training program delivered by the training provider and
that which is approved by the FAA, the operator must propose effective remedies.
Those remedies must be included in the summary report and must be addressed under the following categories:
a) Immediate corrective action:
1. Action already taken, showing dates, and
2. Action planned, showing target dates.
b) Long-term corrective action, showing target dates; and
c) A strategy for ensuring continuing prevention of recurrence.
3) OpSpec/MSpec/LOA A031. All affected operators are required
to be issued OpSpec/MSpec/LOA A031. Any training provider conducting contract
training, within the meaning of this section, must be approved by the POI and recorded in OpSpec/MSpec/LOA A031.
E. Program Discrepancies. An operator contracting for training
must address any training program discrepancy and undertake corrective action
as soon as the discrepancy becomes known. When the operator’s own remedies are
insufficient, the POI must take additional steps as deemed necessary and appropriate,
in accordance with applicable provisions of Title 49 of the Code of Federal
Regulations (49 CFR), 14 CFR, FAA Order 8900.1, and the current edition of Order
Compliance and Enforcement Program.
NOTE: For guidance in accomplishing an Internal Evaluation Program (IEP) evaluation, refer
to AC 120-59 and
Volume 3, Chapter 28, Section 1, Air
Carrier Management Effectiveness.
F. New Outsourced Training Arrangements. When approving new outsourced training arrangements for part
the regular PTRS recording procedures for the appropriate job function and enter “Contract” in the “National Use” field.
RESERVED. Paragraphs 3-4417 through 3-4432.