Volume 3 General Technical Administration
Section 5 Part
142 Training Centers: Outsource TrainingóAir 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).
A. References. In addition to adopting Title 14 of the Code of
(14 CFR) part
142, the Federal Aviation Administration (FAA) also revised
applicable sections of 14 CFR parts
63, part 91K,
141 to 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
142 enabled operators to pursue training alternatives not previously available
under the regulations. Part
142 has made the use of training centers by operators more widely accepted
as an alternative means of providing training to its employees.
NOTE: ďAlternative meansĒ as used in part
142 has in some cases been misunderstood and has been interpreted to mean
that compliance with a training centerís approved courses will meet the training
requirements required by the appropriate operating rules for an operator. This
is not the case. ďAlternative meansĒ 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 ďalternative meansĒ to meet the training approval requirements
governing its particular operation. Programs approved in accordance with part
142 may not be used as an alternative means of satisfying the requirements
of the appropriate operating rules as approved by the operatorís POI.
B. TCPMs and POIs. As the use of training centers continues to
increase, the interrelationship between a centerís TCPM and an operatorís 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 resolveóand
this section will addressóare outlined below:
1) Exactly what portion of the operatorís 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
135, ßß 135.338 and
3) How does the operator propose to qualify Training Center Evaluators
(TCE) or other personnel to become contract check airmen? (Refer to ßß
4) What documentation is required to ensure the training conducted
by the center complies with the operatorís approved curriculums, and how does
the operator propose to document this training?
3-4411 BASIC STRUCTURE.
A. Operating Rules. The operating rules of parts
91K permit 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 operatorís POI, an operator may use the training
providerís 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 operatorís training curriculum, the operator is responsible for its approval,
oversight, content, and currency. Regulations are very clear regarding an operatorís
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 operatorís POI. In similar fashion, training
centers certificated under part
142 are also required to have their curriculums approved by the Administrator.
For training centers, the approval authority is delegated to the centerís TCPM.
C. Arrangements. The following cases are the two most common
arrangements that are formed between air carriers and training centers.
1) Case OneóDry Lease.
a) The least complicated way in which an operator may use the facilities
and equipment of a training center is through a ďdry leaseĒ 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 operatorís 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 operatorís check airman activities. The operatorís POI approves the use
of the centerís flight training equipment; however, the operator is responsible
for ensuring that the centerís 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 operatorís 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 centerís physical location in relation to the POIís office,
the POI may request the centerís TCPM to provide information concerning the
training center facility and equipment as well as assistance in performing required
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) A031.
2) Case TwoóThe 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 operatorís 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 centerís curriculum. Regardless of the source, each
curriculum must be approved by the operatorís POI for their use. However, it
is not uncommon for operators to adopt one of the centerís 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 centerís curriculum,
courseware, procedures, equipment, and personnel to determine if the training
centerís curriculum will meet their operational needs. If the operator determines
that the centerís 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 operatorís approved program, and in effect
becomes the operatorís curriculum. This trend is particularly evident among
135 and new entrant part
121 operators 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 carrierís approved program to become eligible to conduct training
under the air carrierís approved curriculum (ßß
135.340; or ßß
91.1095, as 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 (ßß
135.339; or ßß
91.1093, as appropriate).
c) The center may maintain the operatorís 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 centerís
personnel to act as a contract check airman, and the operatorís 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
e) The POI must be assured that the centerís facilities and equipment
are adequate to conduct the training the operator is proposing. The centerís
TCPM is one of the POIís best sources of information to enable him/her to make
the determination that the centerís 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 operatorís 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 operatorís program and that the complete
program is accomplished. POIs should communicate regularly with the training
centerís TCPM and are encouraged to request assistance with surveillance of
the operatorís activities at the training center. The TCPMís assistance will
typically afford the POI greater flexibility and a higher level of surveillance
than would normally be possible without the TCPMís assistance. An operator should
develop and keep up to date a ďTraining Source DocumentĒ or similar statement
detailing what training will be provided in-house and what will be conducted
by the training center. See the FAAís 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.
142 APPROVED 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 centerís approved curriculum may not be used by an operator
without first being evaluated for appropriateness and secondly, being approved
for use by the operatorís 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
63. (Refer to ß
2) In order for a training course to be approved as a core curriculum
a) Meet the applicable requirements of part
142 subpart 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;
f) Include maneuver descriptions, standard operating procedures (SOP),
checklists, and other supporting courseware.
142 pilot training curriculums are designed to meet the certification requirements
61 and therefore do not include many of the operator-specific elements required
by the operating rules associated with an air carrier/operator. For example,
142 core curriculum does not require a training center to specify the training
that is normally found in an operatorís 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 centerís core curriculum. Although a training centerís part
142 approved core curriculum may meet the aircraft specific requirements
for an operator, these curriculums do not qualify operatorís pilots for line
operations and may not be used by an operator without the specific approval
of the operatorís POI.
B. Specialty Curriculums. This term refers to courses that are
designed to satisfy a particular requirement of 14 CFR chapter I (parts 1-199),
other 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 ß
142.3). Training 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 ß 142.81). The approval of specialty curriculums or courses by a training
centerís TCPM, however, does not enable those curriculums or course to be used
by an operator without the specific approval of the operatorís 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 3-4413A
through D 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 3‑4413A through D 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 operatorís training program remains current and continues to meet the
operatorís 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 operatorís
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 operatorís 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 partyís role.
3) Develop an implementation plan to perform oversight of center
facilities and personnel engaged in the conduct of the operatorís training and
associated evaluations. The operatorís 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 operatorís approved program. (Refer to ßß
121.414; and ßß
135.340, as appropriate.)
NOTE: Operators must complete a detailed comparison between their check airman curriculum and that of the training centerís TCE curriculum to
determine what, if any, additional training must be provided to qualify the
centerís personnel to act as a contract check airman. Elements of the centerís
instructor/TCE training curriculum that the operator finds equivalent to their
training program may, with the POIís approval, be credited toward the completion
of the operatorís instructor/check airmen curriculum. If the centerís curriculum
is approved as meeting the requirements of the operatorís curriculum, other
than the operator specific items, no additional training for the centerís 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 centerís personnel as contract check airman. This module that
includes the operator-specific subjects must be presented to the operatorís
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
4) Additionally, the following procedures must be followed when
requesting the use of center personnel to become qualified as contract check
NOTE: These procedures follow the guidance outlined in Volume 3, Chapter
20, and should be accomplished in the order shown.
a) Evaluate the instructorís/TCEís credentials to ensure he or she
meets company requirements to become a contract check airman;
b) Evaluate the individualís 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 centerís 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
individualís 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 centerís TCPM whenever they authorize one
of the centerís personnel to act as a contract check airman by forwarding the
TCPM a copy of the contract check airmanís letter of authorization (LOA).
5) Coordinate the approval of FSTD missing, malfunctioning, or
inoperative (MMI) equipment procedures that will be used in support of the operatorís
1) When an operator requests the use of a training centerís facilities,
FSTDs, curriculums (core and/or specialty), flight instructors, TCEs, and/or
other services, including recordkeeping, the POI is responsible for determining
the operatorís 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 operatorís POI, and must conform to the
training program approval process outlined in Volume 3, Chapter 19. If an operator
wishes to use a training centerís core and/or specialty curriculums to meet
a portion of their required training program, it is the operatorís responsibility
a) The centerís curriculums/courses meet the operatorís training
b) The curriculums are submitted to the operatorís 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 operatorís training program.
NOTE: If the curriculums are approved for the operatorís use, these
curriculums now become a portion of the operatorís 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 operatorís approved training curriculum (including
maneuvers, procedures, and checklists). Additionally, each center must be specifically
approved for use by the POI and listed in the operatorís OpSpec/MSpec 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 centerís TCPM whenever they authorize one
of the centerís personnel to act as a contract check airman. This may be accomplished
by forwarding the TCPM a copy of the contract check airmenís LOA. POIs are encouraged
to contact the centerís TCPM for assistance with the review and potential approval
of a contract check airman. TCPMs are often the POIís best source of information
relating to a centerís 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 providerís
personnel, to act as contract instructor and/or contract check airmen to conduct
a portion of their required training, it is the operatorís responsibility to
ensure those individuals are qualified to conduct the subject training. Prior
to authorizing a centerís flight instructors or TCE(s) to conduct any portion
of an operatorís 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
91.1095(a)(2) require an observation of each authorized flight instructor
to be accomplished at least once every 24 months. Additionally, ßß
91.1093(a)(2) require an observation of each simulator and aircraft check
airman to be accomplished at least once every 24 months.
142 has similar requirements for flight instructors and evaluators. However,
142 requires these observations to be conducted at least once every 12 months.
(Refer to ßß
a) The intent of these regulations is to ensure the continued standardization
and quality of each operatorís training program by performing periodic observations
of each flight instructor and check airman by focusing on the individualís 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 centerís part
142 observations of their flight instructors may meet the requirements for
the center under part
142, but not meet the requirements for an air carrier under part
121 or part
135. Such an observation might be acceptable for a portion of an operatorís
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 ďessentially the
sameĒ when they comprise identical checklists, operational procedures, and call-outs, and flight deck layouts and flight manuals (fm) which are compatible in the
judgment of the operatorís POI. Training program components, which relate to
like-aircraft types, are dissimilar when they do not meet the criterion for
ďessentially the same.Ē When differences are too pronounced or too numerous
in the judgment of the POI, flight deck layouts and fm must not be viewed as
2. When the observation is acceptable to the operatorís 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 operatorís approved program.
7) If the operator requests approval of two or more centers,
determine that all training, testing, and checking is conducted using the operatorís
approved curriculum. To ensure
standardized training for all of the operatorís 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
operatorís curriculum as approved by the operatorís 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 operatorís permission) to
interchange crewmembers during the flight training phase. This may only be accomplished
providing the individual operatorís 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 operatorís use, as well as each maneuver, procedure,
or crewmember function to be trained.
9) Each training facility must be authorized and listed in the
operatorís OpSpec/MSpec A031.
10) Each training curriculum/module approved to be conducted by a training
provider must be listed, by curriculum title, in the operatorís OpSpec/MSpec
11) Review the operatorís 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 operatorís training center audit program.
NOTE: Many of the training centers used by operators are located in
areas apart from the operatorís 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 operatorís 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 operatorís 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
operatorsí records does not relieve the POI of required check airman/APD tracking
requirements outlined elsewhere in this order or the POIís 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 TCPMís
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 centerís 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
4) Assist the POI with required surveillance activities including:
a) Potential contract check airmen;
b) Observing contract check airman during the evaluation of the operatorís
airman to ensure evaluations are objective, accurate, and consistent with the
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 operatorís activities
at the training center.
NOTE: In all cases, the TCPMís assistance is subject to their offices
D. Training Center(s). A training centerís roles, responsibilities,
and coordination activities include:
1) Participating in the operatorís 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 operatorís 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 centerís training specifications (TSpec).
Only the centerís TCPM-approved core or specialty curriculums/courses are required
to be listed in the centerís 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 operatorís approved curriculums to conduct
such activities. This training must include, at a minimum, training in all portions
of the operatorís 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 operatorís 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 centerís approved instructor training program,
b) Are currently qualified and actively participating in one or more
of the centerís core curriculums appropriate to the operatorís needs.
7) Maintaining the centerís 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 operatorís use.
8) Advising the operator whenever flight training equipment fails
to meet required qualification standards and/or when maintenance problems will
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 operatorís training and testing/checking.
NOTE: Crew pairing policies and procedures may be found in paragraph
11) Advising operators of any proposed revisions to the centerís 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 applicantís 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 providers curriculums, courseware, procedures, equipment, facilities,
and personnel that will be used in the conduct of the operatorís 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 operatorís training, the application must contain an appropriate training
module developed to qualify centers instructors/TCEs on the operators 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 centers instructors/TCEs as contract check airman for the operator.
(See paragraph 3-4415 for complete details.)
e) A copy of the operatorís instructor/check airman standardization
f) A copy of the operatorís 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 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 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 operatorís 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 holderís 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 operatorís
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 operatorís 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 operatorís 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 operatorís aircraft, the operatorís program must state how
any differences between the aircraft and the FSTDs will be addressed and develop
an appropriate differences training module.
2) A TCPMís approval of a centerís FSTDs for use within the centerís
approved curriculum does not authorize an operator to use the same FSTDs within
the operatorís curriculum. The TCPMís 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 centerís FSTDs in support of the
operatorís curriculum, the operator must include the FSTDs in its training program
and have the FSTDs approved by its POI. The operatorís POI will evaluate the
requirements of the operatorís program and make a determination concerning the
appropriateness of the centerís FSTDs and their qualification as it relates
to the operatorís curriculum. POIs may request verification of the flight training
equipment authorized for use by a training center by contacting the centerís
3) To receive training credit for a particular FSTD, the FSTD
must first be qualified by the National Simulator Program (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 FSTDís 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 Centerís 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
142 requirements and are either ďcoreĒ or ďspecialtyĒ as defined by part
142. Once a curriculum is approved by the TCPM, it is listed in the centerís
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 operatorís POI, it becomes part of the operatorís 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 operatorís
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 operatorís program
as a specialty curriculum. This naming convention is important to clarify oversight
and ownership responsibilities for the subject curriculum/course. An operatorís
programs are approved by its POI in accordance with the appropriate operating
a) Training center curriculums, both core and specialty, are approved
by a TCPM in accordance with part
142 and designed to meet the training, testing, and checking requirements
of airmen certification under part
b) The flightcrew member requirements of parts 91K,
135 differ in numerous respects to part
61 requirements. A TCPMís approval of a centerís curriculum does not enable
an operator to use such curriculum without the specific approval of the operatorís
3) In order for an operator to request a training centerís approved
curriculum to be incorporated into their program, the operator must first complete
a comparison between the proposed centerís 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 centerís instructors
and/or TCEs on the operatorís curriculum. It is the operatorís 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 centerís 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 centerís. If
the differences found are minor, the operatorís 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 centerís personnel. Major differences
between the curriculums will require specialized differences or formal retraining
of the centerís personnel. In all cases, the operatorís 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 SOPs 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 operatorís program must clearly define these
functions and their procedures to ensure adequate training is conducted and
b) SOPs, including but not limited to:
∑ Crew coordination and ďcall-outs,Ē
∑ Maneuvers descriptions and aircraft configuration,
∑ Flight deck ďflows,Ē
∑ 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
63 are not required to include operator-specific items required by part
135 training regulations. Part
curriculums are required to meet the certification requirements of parts 61
and/or 63 and the associated
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 operatorís OpSpecs/MSpecs.
7) If an operator is introducing a new aircraft and requesting
the adoption of a centerís 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
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 POIís 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
8) Table 3-122A, SampleóWeight 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
142 W&B training module. Column B represents a typical part
135 W&B training module. These differences are a result of the requirements
135.293(a)(3), which require operators to train and check their pilots on
their (the operatorís) method of determining compliance with W&B limitations.
142 requires the centerís curriculum to comply with part 61, ß
61.155(c)(9), which is typically modeled after the manufacturerís procedures.
When confronted with these differences, an operator must decide to either:
a) Train and qualify the centerís 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 manufacturerís weight, balance training, and then conduct a specialized
course designed to cover the differences between the centerís curriculum and
that of the operator. If the operator chooses to permit the center to conduct
the centerís W&B module, the operator would then be required to convene a separate
instructional period to train and test the differences between the centerís
curriculum and its (operatorís) 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 centerís instructors in those elements
of their curriculum that are different from the centerís curriculum. It would
then be possible for the qualified instructor to conduct the entire W&B module
for the operatorís crewmembers. However, without specified training in the operatorís
procedures, the center may only be authorized to provide training and testing
in those subjects that are part of the centerís curriculum (Table 3-122A, lines
1 through 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. SampleóWeight and Balance
Curriculum Module Comparison Chart
Aircraft Manufacturers Weight & Balance Procedures
(Airplane Flight Manual (AFM))
Aircraft Manufacturers Weight & Balance Procedures
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 determinationóaverage, 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 operatorís approved
curriculum. However, the use of company-developed flip charts, computers,
ďWIZ WheelsĒ, etc., may require specialized training. Differences evaluation
2 through 4: Topics may comply with the operatorís
approved curriculum. Differences evaluation required.
5 through 13: Topics do not conform to the operatorís
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 POIís
oversight responsibility is to ensure that the operatorís 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
135 operators must ensure the training required by ß
135.345 is conducted and all subjects required by ßß
135.299 are 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 carrierís 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
142. Training centers may develop curriculums designed to comply with the
operating rules of an air carrier; however, the curriculums cannot be approved
as ďmeetingĒ the requirements of those parts. Training center instructors and
evaluators are likewise qualified in accordance with a centerís approved curriculums
and therefore cannot conduct an air operatorís training without first being
qualified by an air operator before conducting any of the operatorís required training. (Refer to ßß
121.414, and ßß
135.340.) Depending on the content of a particular centerís 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
12) When a center revises one of their core or specialty training curriculums
that originally formed the basis of an operatorís approved curriculum, the center
should be encouraged to advise the operator of the revision. However, it is
important to understand that revisions to a centerís core or specialty curriculums,
which were used as the basis of an operatorís training curriculum, does not
automatically create a revision to the operatorís POI-approved course. The adoption
of such changes is subject to the operatorís evaluation and approval by its
POI. Center revisions that are considered appropriate for the operatorís program
may be incorporated by the operator if approved by the operatorís 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 centerís 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 centerís personnel to conduct an operatorís training
curriculums will require the operator to conduct an evaluation of the centerís
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 operatorís 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 operatorís 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 operatorís ability to adequately monitor and audit the training being provided,
the POI and the operator have the responsibility to limit the number of training
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 operatorís crewmember training as approved. These procedures
may be part of the operatorís manual used by the certificate holderís flight
personnel in conducting its operations and/or contained in the operatorís approved
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 operatorís program contains appropriate policies and procedures to ensure
the training conducted by the authorized training provider(s) is in accordance
with the operatorís 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 ďread fileĒ specific to the operator that is available to all contract
instructors, contract check airmen, and the operatorís 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 POIís approval to integrate the subject
curriculum into its training program. See subparagraph 3-4414C for policies
and procedures for the integration of a centerís curriculum into an operatorís
F. Crew Pairing.
1) Training centers often provide services to air operators which
must meet requirements of particular operating rules (i.e., parts
135). Under 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 operatorís
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 operatorís 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 operatorís 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 carrierís line qualified pilots,
2. One of the air carrierís pilots undergoing training for the same
3. A contract flight instructor (airplane or simulator) or a contract
check airman (airplane or simulator) who is authorized to serve in that air
carrierís training program.
b) The following conditions apply when a part
135 air carrier pilot is training in an FAA-approved training program for
135 air 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 carrierís 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
120-35, Line 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 operatorís 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
135 operations should not routinely be paired with pilots training for operations
91. These 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
91 pilot must conform to the training program of the part
135 pilot in every respect. Specifically, checklists, profiles, approach
procedures and callouts must be those used in the training program of the part
135 pilot (not vice versa), and the part
91 pilot must understand and apply Crew Resource Management (CRM) principles
in accordance with the air transport pilot
practical test standards.
b) Each certificated air operatorís crewmember must complete the
appropriate air operatorís evaluation module. Part
135 pilots may support the part
91 pilotís training activities as appropriate.
91 pilots paired with an air operator crewmember must use the operatorís
approved curriculum. In these cases, the TCPM must either concur with the part
91 pilotís use of the air operatorís 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, operatorís crew
pairing procedures (if provided) and these requirements.
d) The part
91 pilot must have received differences training in the features of the
135 training curriculum that distinguishes it from the part
91 training curriculum. That training should also include the operatorís
OpSpecs and operational control procedures.
NOTE: In crew pairings involving pilots of different part
135 operators or pilots operating under different operating rules (parts
91) POIs and TCPMs must be especially vigilant. The part
135 operatorís 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
operatorís crewmember training conducted by an outsourced training provider.
The operatorís 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
120-78, Acceptance 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 operatorís approved system. Center personnel acting as
contract instructors and/or contract check airman for the operator must also
be trained in the operatorís records system.
4) Training centers are not required under part
142 to maintain an air carrierís crewmember training records when the training
was accomplished in accordance with the operatorís approved program. Training
centers are only required to maintain the records required to support the training
accomplished under part
142 that leads to airman certification or proficiency required by part
63. An operatorís crewmembers are not trained and evaluated in accordance
142. They are trained and evaluated in accordance with the operatorís 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 operatorís training program. In that context, FAA policy permits the center
to be used as a suitable location for required records if approved by the operatorís
POI. Many training centers provide a large portion of an operatorís training
and in some cases are the sole providers of such training, which may make the
center a logical location for such records.
142 requires 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
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 operatorís 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 individualís
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
135.324(b)(4) require 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 ďsufficientĒ 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 operator;
∑ Geographic location of the operator with respect to available
∑ 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 operatorís 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 91K, part
121 subpart N, and/or part
135 subpart H, as appropriate). Training center instructors and evaluators
are trained and qualified under part
142, 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
142 may 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 centerís approved core curriculum for a particular
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 carrierís
curriculum that the instructor will be responsible for providing to the air
carrierís crewmembers. Current policy does not require center instructors to
complete the carrierís entire approved training program or curriculum provided:
a) The individuals are limited to conducting only the training elements
of the operatorís 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 centerís
core or specialty curriculum(s) and the POI approves these curriculums as part
of the air carrierís 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 centerís
instructor(s) would be limited to any differences that exist between the training
centerís curriculum(s) (as approved by the TCPM) and the air carrierís training
curriculum (as approved by the carrierís POI).
NOTE: In such cases, it is the air carrierís responsibility to identify
each difference between the carrierís approved training curriculum (including
curriculum content, checklists, and procedures) and the training centerís curriculum.
The air carrier must than develop and provide their POI a training module to
qualify the centerís personnel on all noted differences. This differences training
module must be approved by the POI prior to conducting the subject training.
3) The air carrierís POI has the responsibility to determine
if the manner and method proposed by the air carrier to train and qualify the
centerís personnel on curriculum differences, will meet the operatorís training
D. Review. To ensure the centerís personnel meet the operatorís
check airman standards, the operator will need to review the individualís training
history and qualifications. Elements of the centerís instructor/TCE training
curriculums that the operator finds equivalent to their training program may,
with the POIís approval, be credited toward the completion of the operatorís
instructor/check airmen curriculums. If the centerís curriculum has been submitted
to the POI for approval and is approved as meeting the requirements of the operatorís
curriculum, other than the operator-specific items, no additional training for
the centerís 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 centerís personnel as contract
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 instructorís/TCEís credentials to ensure he or she
meets the certificate holderís 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
centerís TCPM for assistance with the review and potential approval of contract
check airman. TCPMs are often the POIís best source of information relating
to a centerís operation and personnel.
b) Evaluate the centerís instructor and TCE training curriculum by
comparing it to the operatorís check airman curriculum to determine the differences
training required to qualify the centerís 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 centerís instructor/TCE as a contract check airman.
d) Submit the contract check airmen training module(s) to its POI
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
individualís name and rťsumť 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 centerís TCPM whenever they authorize one
of the centerís personnel to act as a contract check airman. This may be accomplished
by forwarding the TCPM a copy of the check airmanís 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 operatorís
check airman, qualified as a line captain may be authorized as a simulator only
check airman permitting them to administer both ß
135.293(a)(1 through 8) as well as ß
135.297 evaluations. A contract check airman who is only qualified in the
aircraft-specific modules of an operatorís 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 ß
135.293(a)(2) and (b) and ß
135.297 evaluations. 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 ß
135.293(a)(1) or (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
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 operatorís 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 ß
135.293(a)(1) and (a)(4)Ė(8), it follows that neither the trainees nor the
instructors and evaluators themselves receive training in those subjectsówhich
ignores the training requirements of ßß
135.338(b)(2). Therefore, a training center evaluator typically is not qualified
to evaluate subjects other than those contained in the centerís core curriculum
which equates to ß
135.293(a)(2) and potentially (3). Similarly, a trainee should not be evaluated
in those subjects by individuals not qualified in the operatorís procedures.
NOTE: To preclude any confusion concerning a contract check airmanís
authorization, the POI must specify in each contract check airmanís 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
carrierís initial new hire training curriculum. Knowledge of an air carrierís
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 crewmemberís 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 carrierís 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 operatorís 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 centerís TCEs receive
annual training on the conduct of part
61 certification functions in accordance with part
142 subpart C, relating to the curriculums approved for the training centerís
use. As outlined above, this training and checking does not qualify an individual
to act as an operatorís check airman. Operators must complete a detailed comparison
between its check airman curriculum and that of the training centerís TCE curriculum
to determine the extent of the additional training they must provide to qualify
the centerís personnel to act as a contract check airman on their behalf. If
this comparison indicates that the operatorís training programs are identical,
other than the operator specific items, no additional training for the centerís
personnel is required. Any differences noted between the curriculums will require
the operator to develop a training module to qualify the centerís personnel
as a check airman. This module must be presented to the operatorís 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
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 operatorís programs.
NOTE: In all cases, the acceptance of an instructor/check airmenís qualification
by another operator is subject to the approval of the requesting operatorís
I. Reports. The POI should arrange to have the operator provide
the POI with a periodic report of each check airmanís checking activities, including
a pass/fail rate, to coincide with the POIís periodic review (annual, semiannual,
or other). POIs may arrange for these reports to arrive at a time that meets
the POIís 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 operatorís need for
those check airmen whose records indicate low activity levels.
3-4416 OUTSOURCED TRAINING PROVIDER AUDITS AND ASSOCIATED OPSPEC/MSPEC
A. Self-Audit Program. The FAA requires a mandatory self-audit
program for operators certificated under the provisions of parts
91K who 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 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 carrierís 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
120-59, Air 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 A031, and should be conducted at any
time that a major change affects the operatorís 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 operatorís 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 ßß
121.414; or ßß
135.340, as 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
121 Flight Engineer (FE))
∑ Flight training in lieu of the proficiency check, including LOFT;
∑ Competency checks;
∑ Maneuver validation (Advanced Qualification Program (AQP)); and
∑ 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 operatorís 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 operatorís 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 A031. All affected operators are required to
be issued OpSpec/MSpec A031. Any training provider conducting contract training,
within the meaning of this section, must be approved by the POI and recorded
in OpSpec/MSpec 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 operatorís 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
2150.3, Compliance and Enforcement Program.
NOTE: For guidance in accomplishing an Internal Evaluation Program (IEP)
AC 120‑59, and
Volume 3, Chapter 28, Section 1.
F. New Outsourced Training Arrangements. When approving new outsourced
training arrangements use the regular Program Tracking and Reporting Subsystem
(PTRS) recording procedures for the appropriate job function and enter ďContractĒ
in the ďNational UseĒ field.
RESERVED. Paragraphs 3-4417 through 3-4432.