VOLUME 3 GENERAL TECHNICAL ADMINISTRATION
Section 5 Safety Assurance System: Part
142 Training Centers: Outsource TrainingAir Operators and/or Fractional Ownership Program Managers Contracting With Training
91.1073, Training Program: General.
91.1075, Training Program: Special Rules.
91.1079, Training Program: Curriculum.
91.1081, Crewmember Training Requirements.
91.1083, Crewmember Emergency Training.
91.1087, Approval of Aircraft Simulators and Other Training Devices.
91.1089, Qualifications: Check Pilots (Aircraft) and Check Pilots (Simulator).
91.1091 Qualifications: Flight Instructors (Aircraft) and Flight Instructors (Simulator).
91.1093, Initial and Transition Training and Checking: Check Pilots (Aircraft), Check Pilots (Simulator).
91.1095, Initial and Transition Training and Checking: Flight Instructors (Aircraft), Flight
91.1097, Pilot and Flight Attendant Crewmember Training Programs.
91.1099, Crewmember Initial and Recurrent Training Requirements.
91.1101, Pilots: Initial, Transition, and Upgrade Ground Training.
91.1103, Pilots: Initial, Transition, Upgrade, Requalification, and Differences Flight Training.
91.1105, Flight Attendants: Initial and Transition Ground Training.
91.1107, Recurrent Training.
121.401, Training Program: General.
121.402, Training Program: Special Rules.
121.403, Training Program: Curriculum.
121.407, Training Program: Approval of Airplane Simulators and Other Training Devices.
121.411, Qualifications: Check Airmen (Airplane) and Check Airmen (Simulator).
121.412, Qualifications: Flight Instructors (Airplane) and Flight Instructors (Simulator).
121.413, Initial, Transition, and Recurrent Training and Checking Requirements: Check Airmen (Airplane),
Check Airmen (Simulator).
121.414, Initial, Transition, and Recurrent Training and Checking Requirements: Flight Instructors
(Airplane), Flight Instructors (Simulator).
121.415, Crewmember and Dispatcher Training Program Requirements.
121.417, Crewmember Emergency Training.
121.418, Differences Training and Related Aircraft Differences Training.
121.419, Pilots and Flight Engineers: Initial, Transition, and Upgrade Ground Training.
121.421, Flight Attendants: Initial and Transition Ground Training.
121.422, Aircraft Dispatchers: Initial and Transition Ground Training.
121.423, Pilot: Extended Envelope Training.
121.424, Pilots: Initial, Transition, and Upgrade Flight Training.
121.425, Flight Engineers: Initial and Transition Flight Training.
121.427, Recurrent Training.
121.683, Crewmember and Dispatcher Record.
125.401, Crewmember Record.
125.296, Training, Testing, and Checking Conducted by Training Centers: Special Rules.
125.297, Approval of Flight Simulators and Flight Training Devices.
135.63, Recordkeeping Requirements.
135.323, Training Program: General.
135.324, Training Program: Special Rules.
135.327, Training Program: Curriculum.
135.329, Crewmember Training Requirements.
135.330, Crew Resource Management Training.
135.331, Crewmember Emergency Training.
135.335, Approval of Aircraft Simulators and Other Training Devices.
135.337, Qualifications: Check Airmen (Aircraft) and Check Airmen (Simulator).
135.338, Qualifications: Flight Instructors (Aircraft) and Flight Instructors (Simulator).
135.339, Initial and Transition Training and Checking: Check Airmen (Aircraft), Check Airmen
135.340, Initial and Transition Training and Checking: Flight Instructors (Aircraft), Flight Instructors
135.341, Pilot and Flight Attendant Crewmember Training Programs.
135.343, Crewmember Initial and Recurrent Training Requirements.
135.345, Pilots: Initial, Transition, and Upgrade Ground Training.
135.347, Pilots: Initial, Transition, Upgrade, and Differences Flight Training.
135.349, Flight Attendants: Initial and Transition Ground Training.
135.351, Recurrent Training.
142.39, Training Program Curriculum Requirements.
142.47, Training Center Instructor Eligibility Requirements.
142.49, Training Center Instructor and Evaluator Privileges and Limitations.
142.53, Training Center Instructor Training and Testing Requirements.
142.55, Training Center Evaluator Requirements.
142.59, Flight Simulators and Flight Training Devices.
142.73, Recordkeeping Requirements.
142.81, Conduct of Other Approved Courses.
3-4409 GENERAL. This section provides policy guidance for principal
operations inspectors (POI) that have operators or receive requests from their
operators to outsource a portion of their required crewmember training. The
information in this section may also be useful for Training Center Program Managers
(TCPM), operators, and training center managers (TCM). This section is related
to Safety Assurance System (SAS) Element 2.1.4, Outsource Crewmember Training.
A. References. In addition to adopting Title 14 of the Code of Federal Regulations (14 CFR)
part 142, the Federal Aviation Administration (FAA) also
revised applicable sections of 14 CFR
91 subpart K
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: “Alternative means” as used in part
142 has in some cases been misunderstood and has been interpreted to mean
that compliance with a training center’s approved courses will meet the training
requirements required by the appropriate operating rules for an operator. This
is not the case. “Alternative means” permits an operator to outsource or arrange
to have its approved training conducted by a third party. It does not mean that
an operator has an “alternative means” to meet the training approval requirements
governing its particular operation. Programs approved in accordance with
part 142 may not be used as an alternative means of satisfying the requirements
of the appropriate operating rules as approved by the operator’s POI.
B. TCPMs and POIs. As the use of training centers continues to
increase, the interrelationship between a center’s TCPM and an operator’s POI
have become increasingly important. When an operator wishes to use the services of a
part 142 training center, the most common operational issues that POIs must
resolveand this section will addressare outlined below:
1) Exactly what portion of the operator’s required crewmember
training, checking, and/or testing will the center be authorized to conduct?
2) What qualification requirements are necessary to enable training
center flight instructors to conduct the requested training? (Refer to
§§ 91.1091 and
§§ 121.412 and
121.414; and part
§§ 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
4) What documentation is required to ensure the training conducted by the center complies with the operator’s approved curriculums, and how does the operator propose to document
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 operator’s POI, an operator may use the training
provider’s facilities, equipment, and personnel to varying degrees to accomplish
the training, checking, and testing required by their approved training program.
B. Training Curriculum. Regardless of who actually developed
an operator’s training curriculum, the operator is responsible for its approval,
oversight, content, and currency. Regulations are very clear regarding an operator’s
requirement to have appropriate crewmember training programs that support their
particular operation. The regulations are also clear concerning the requirement
to have these programs approved by the Administrator. In the case of the operator,
this approval is delegated to the operator’s POI. In similar fashion, training centers certificated under
part 142 are also required to have their curriculums approved by the
Administrator. For training centers, the approval authority is delegated to the center’s TCPM.
C. Arrangements. The following cases are the two most common arrangements that are formed between air carriers and training centers.
1) Case OneDry Lease.
a) The least complicated way in which an operator may use the facilities
and equipment of a training center is through a “dry lease” agreement. In this
case, the operator has developed and maintains its own approved training curriculum,
associated courseware, materials, checklists, procedures, and personnel to conduct
training and checking, but elects to dry lease flight training equipment and
facilities from a training center. Associated airman certification functions
and proficiency requirements are completed by check airmen employed by the carrier
(not the training center), the operator’s aircrew program designee (APD), or
the FAA. The operator accomplishes recordkeeping, although required training
records may be maintained at the training facility if approved by their POI.
POIs will make all enhanced Vital Information Database (eVID) entries concerning
the operator’s check airman activities. The operator’s POI approves the use
of the center’s flight training equipment; however, the operator is responsible
for ensuring that the center’s equipment and facilities continue to meet the
standards required to accomplish required training. The training center simply
acts as a host for the operator and center personnel are not involved in the
training or checking of the operator’s crewmembers.
b) POIs are responsible for providing required surveillance to determine
if contracted facilities and training equipment meet the requirements for continued
approval. Due to the center’s physical location in relation to the POI’s office,
the POI may request the center’s TCPM to provide information concerning the
training center facility and equipment, as well as assistance in performing
c) Operators who conduct training in this manner (dry lease) are not outsourcing
their training from another training provider and therefore do not require approval
for outsourced training in their Operations Specification (OpSpec)/Management
Specification (MSpec)/Letter of Authorization (LOA) A031, Outsourced Training.
2) Case TwoThe Training Center Provides Facilities, Instructors, and/or Evaluators Under Contract to the Operator.
a) The second most common way operators use the services of part
142 training centers is to enter into an agreement with the center to provide
instructors and/or evaluators to act on behalf of the operator in the conduct
of the operator’s training curriculum. In this situation, the operator may have
developed their own training curriculum, hired a consultant to develop the curriculum,
or adopted the training center’s curriculum. Regardless of the source, each
curriculum must be approved by the operator’s POI for their use. However, it
is not uncommon for operators to adopt one of the center’s core or specialty
curriculums and submit it without revision, to their POI for approval. Prior
to submitting a center-developed curriculum to their POI for approval, the operator
must conduct a detailed review and comparison and analysis of the center’s curriculum,
courseware, procedures, equipment, and personnel to determine if the training
center’s curriculum will meet their operational needs. If the operator determines
that the center’s curriculum will meet their needs, they may submit it to their
POI for approval. If the POI accepts the submitted curriculum and grants approval,
the curriculum becomes part of the operator’s approved program, and in effect
becomes the operator’s curriculum. This trend is particularly evident among
part 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 carrier’s approved program to become eligible to conduct training under the air carrier’s approved curriculum
(§§ 121.412 and
§§ 135.338 and
§§ 91.1091 and
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
(§§ 121.411 and
§§ 135.337 and
§§ 91.1089 and
91.1093, as appropriate).
c) The center may maintain the operator’s training records if approved by the POI. However, the responsibility for the adequacy of the records remains with the operator, not the
d) If the operator elects to nominate one or more of the center’s personnel
to act as a contract check airman, and the operator’s POI authorizes such check
airmen, the POI must maintain all check airman entries in the eVID. In other
words, whether an operator uses their own personnel as check airmen (as outlined
in Case One) or elects to use center employees as contract check airmen, all
required eVID entries relating to check airmen will be made by the POI. This
will help ensure that both the POI and the operator maintain proper operational
control over persons performing check airmen/contract check airmen functions.
e) The POI must be assured that the center’s facilities and equipment are
adequate to conduct the training the operator is proposing. The center’s TCPM
is one of the POI’s best sources of information to enable him/her to make the
determination that the center’s facilities and training equipment are adequate
for the proposed operation and to assist with required surveillance activities.
f) Operators who wish to engage a training center to accomplish the aircraft‑specific
training modules of their curriculum create special surveillance requirements.
The division of an operator’s required training between the operator and a training
center creates a unique recordkeeping situation, as well as specialized training
for the center instructors. POIs must be extremely vigilant in determining who
is accomplishing each element of the operator’s program and that the complete
program is accomplished. POIs should communicate regularly with the training
center’s TCPM and are encouraged to request assistance with surveillance of
the operator’s activities at the training center. The TCPM’s assistance will
typically afford the POI greater flexibility and a higher level of surveillance
than would normally be possible without the TCPM’s assistance. An operator should
develop and keep up to date a “Training Source Document” or similar statement
detailing what training will be provided in house and what will be conducted
by the training center. See the FAA’s Air Transportation Division (AFS‑200),
Air Carrier Training Systems and Voluntary Safety Programs Branch (AFS‑280) website 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 center’s approved curriculum may not be used by an operator
without first being evaluated for appropriateness and secondly, being approved for use by the operator’s POI.
A. Core Curriculum.
1) A core curriculum is a training center‑developed course that
is approved by the Administrator (through the TCPM) for the purpose of meeting
the training and certification requirements of airmen under
parts 61 and/or
63. (Refer to
2) In order for a training course to be approved as a core curriculum it must:
a) Meet the applicable requirements of
part 142 subpart B and part
b) Contain all the events and maneuvers required by the appropriate
practical test standards (PTS)
or Airmen Certification Standards (ACS) for the issuance of the particular Airman
Certificate for which the curriculum was designed;
c) Meet the requirements of the Flight Standardization Board (FSB) report for that specific aircraft;
d) Consist of training segments that identify training and testing requirements for the issuance of a particular certificate;
e) Follow the guidance in
Volume 3, Chapter 54, Section 6,
Part 142 Training Centers: Evaluate Training Programs, Curriculums, Flight Training Equipment, and Recordkeeping Requirements
Volume 3, Chapter 19, Section 5, Safety Assurance System: Flightcrew Aircraft Ground Training
Curriculum Segments concerning ground and flight training threshold hours; and
f) Include maneuver descriptions, standard operating procedures (SOP), checklists, and other supporting courseware.
142 pilot training curriculums are designed to meet the certification
requirements of part
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, a part
142 core curriculum does not require a training center to specify the
training that is normally found in an operator’s OpSpecs, such as authorized takeoff
or landing minimums, types of authorized approaches, and captain high minimum
requirements. Additionally, ground training in areas such as hazardous materials
(hazmat) handling, security, aircraft maintenance, logbook procedures, and flight
following is also not required to be part of a
part 142 training center’s core curriculum. Although a training
142 approved core curriculum may meet the aircraft‑specific
requirements for an operator, these curriculums do not qualify operator’s pilots for line operations and may not be used by an operator without the specific approval of the operator’s POI.
B. Specialty Curriculums. This term refers to courses that are designed to satisfy a particular requirement of 14 CFR chapter I (parts 1199), other than airman
parts 61 and
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
§ 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
§ 142.81). The approval of specialty curriculums or courses by a training
center’s TCPM, however, does not enable those curriculums or courses to be used by an operator without the specific approval of the operator’s POI.
3-4413 ROLES, RESPONSIBILITIES, AND COORDINATION. The safety, efficiency,
and quality of training provided by training centers, through the use of structured
programs and FSTDs, has proven to be an effective and economical means for some
operators to accomplish required training. Consequently, a number of operators have come to rely on
part 142 training centers as a source of technical expertise and as their primary
training provider. As the use of approved training centers continues to expand,
it becomes increasingly important to understand the roles, responsibilities,
and coordination activities required of each participant. Subparagraphs A through
D of this paragraph that emphasize the regulatory roles and responsibilities,
as well as the coordination required between operators and training centers
when an operator is using a training center to conduct a portion of their required
training program. Subparagraphs A through D of this paragraph do not focus on
day-to-day activities associated with the surveillance of training centers or
operators outside of the context and scope of this section. It is presumed that
these activities are being conducted in accordance with the guidance located
elsewhere in this chapter, associated regulations, orders, and policy guidance.
A. Air Operators. The regulatory responsibility for ensuring
that an operator’s training program remains current and continues to meet the
operator’s needs resides with the operator, not the training provider. When
an operator makes application to use the services of an authorized training provider they must:
1) Ensure that all training, testing, and/or checking to be conducted
by the training center has been approved by the POI before any training is accomplished.
2) Develop an instructor/check airman standardization program
including a checklist, which clearly identifies those elements of the operator’s
program that are to be completed by the training center and those that are to
be completed by the operator. This checklist must specifically identify each
training element that will be conducted by the center and include the regulatory
and/or the training program reference for each item.
NOTE: A sample air operator standardization review may be found on the
AFS‑280 website. The sample program is designed to be all‑inclusive and therefore
not every item covered in the sample may be applicable to all operators. The
sample is intended to be comprehensive and include sufficient detail to ensure
the training provider has an accurate understanding of the operator’s training
requirements. The FAA suggests that each subject in the sample standardization
program be reviewed with a potential training provider to ensure a complete
understanding of each party’s role.
3) Develop an implementation plan to perform oversight of center
facilities and personnel engaged in the conduct of the operator’s training and
associated evaluations. The operator’s implementation plan must:
a) Ensure that all training center personnel selected to act as contract
instructors (both ground and flight) and/or contract check airmen are appropriately
trained and qualified. Flight instructors and/or check airmen must be qualified
in accordance with the operator’s approved program. (Refer to
§§ 91.1089 through
§§ 121.411 through
§§ 135.337 through
135.340, as appropriate.)
NOTE: Operators must complete a detailed comparison between their check
airman curriculum and that of the training center’s TCE curriculum to determine
what, if any, additional training must be provided to qualify the center’s personnel
to act as a contract check airman. Elements of the center’s instructor/TCE training
curriculum that the operator finds equivalent to their training program may,
with the POI’s approval, be credited toward the completion of the operator’s
instructor/check airman curriculum. If the center’s curriculum is approved as
meeting the requirements of the operator’s curriculum, other than the operator‑specific
items, no additional training for the center’s personnel would be required.
Any differences or deficiencies noted will require the operator to develop a
training module to ensure all regulatory requirements are met and to qualify
the center’s personnel as contract check airman. This module that includes the
operator‑specific subjects must be presented to the operator’s POI for approval/acceptance.
b) Provide the center with appropriate administration procedures and instructions
to be used in the accomplishment of agreed training.
c) Provide for the oversight of all contract center personnel who are authorized
to conduct training, testing, and/or checking on behalf of the operator.
4) Additionally, the following procedures must be followed when
requesting the use of center personnel to become qualified as contract check airmen:
NOTE: These procedures follow the guidance outlined in Volume 3, Chapter 20, and should be accomplished in the order shown.
a) Evaluate the instructor/TCE’s credentials to ensure he or she meets company requirements to become a contract check airman;
b) Evaluate the individual’s training record to determine the differences training required to qualify the individual as a contract check airman;
c) Develop an appropriate training differences module(s) to qualify the center’s instructor/TCE as a contract check airman and submit the training module to the POI for
d) Conduct and record appropriate check airman training; submit the individual’s name, short résumé, and training records to the POI for review and approval in accordance with
Volume 3, Chapter 20.
NOTE: POIs should notify the center’s TCPM whenever they authorize one
of the center’s personnel to act as a contract check airman by forwarding the
TCPM a copy of the contract check airman’s LOA.
5) Coordinate the approval of FSTD missing, malfunctioning, or inoperative (MMI) equipment procedures that will be used in support of the operator’s curriculum.
1) When an operator requests the use of a training center’s facilities,
FSTDs, curriculums (core and/or specialty), flight instructors, TCEs, and/or
other services, including recordkeeping, the POI is responsible for determining
the operator’s request conforms to the appropriate regulations, policies, and procedures.
2) The approval authority for an operator to conduct training
at a training center resides with the operator’s POI, and must conform to the
training program approval process outlined in Volume 3, Chapter 19. If an operator
wishes to use a training center’s core and/or specialty curriculums to meet
a portion of their required training program, it is the operator’s responsibility to ensure:
a) The center’s curriculums/courses meet the operator’s training requirements.
b) The curriculums are submitted to the operator’s POI for review and approval in accordance with the procedures outlined in
Volume 3, Chapter 1, Section 1.
c) The curriculums are integrated into the operator’s training program.
NOTE: If the curriculums are approved for the operator’s use, these
curriculums now become a portion of the operator’s approved training program,
and the maintenance/currency of those curriculums becomes the responsibility
of the operator, not the training center.
3) If an operator applies to have the same training curriculum
conducted by two or more centers (either operated by the same or a different
training provider/company), the operator must develop an implementation plan
for each center and ensure that each of the approved centers conducts their
training curriculum using the operator’s approved training curriculum (including
maneuvers, procedures, and checklists). Additionally, each center must be specifically
approved for use by the POI and listed in the operator’s OpSpec/MSpec/LOA A031.
It is the responsibility of the operator to ensure that all required software
and hardware approved to support the subject curriculum is available and used
by each center during the delivery of their training curriculum. See subparagraph 3‑4414D below for additional guidance.
NOTE: POIs should notify the center’s TCPM whenever they authorize one
of the center’s personnel to act as a contract check airman. This may be accomplished
by forwarding the TCPM a copy of the contract check airman’s LOA. POIs are encouraged
to contact the center’s TCPM for assistance with the review and potential approval
of a contract check airman. TCPMs are often the POI’s best source of information
relating to a center’s operation and personnel. A sample contract check airman
LOA is located on the AFS‑280 website.
4) When an operator requests approval of a training provider’s
personnel, to act as contract instructor and/or contract check airman to conduct
a portion of their required training, it is the operator’s responsibility to
ensure those individuals are qualified to conduct the subject training. Prior
to authorizing a center’s flight instructors or TCE(s) to conduct any portion
of an operator’s training, the operator must qualify each individual in accordance
with the training and testing requirements of their operating rule and provide
sufficient evidence of such training and checking to the POI for review and approval.
91.1095(a)(2) require an observation of each authorized flight instructor
to be accomplished at least once every 24 months. Additionally,
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.
part 142 requires these observations to be conducted at least once
every 12 months. (Refer to
§§ 142.53(a)(1) and
a) The intent of these regulations is to ensure the continued standardization
and quality of each operator’s training program by performing periodic observations
of each flight instructor and check airman by focusing on the individual’s performance
in conducting a representative part of a curriculum or training program approved for that operator.
b) A qualified inspector or APD may be requested to observe contract flight
instructors and contract check airmen on behalf of the POI. Whether conducting
its own training or contracting for training with a training provider, each
operator must ensure that all required observations are accomplished and documented. A training center’s part
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
operator’s requirements under the following conditions:
1. When the training curriculum or curriculum segment conducted by the
training center is essentially the same as that of the operator.
NOTE: Training program components may be viewed as “essentially the
same” when they comprise identical checklists, operational procedures, and callouts,
and flight deck layouts and flight manuals (fm) which are compatible in the
judgment of the operator’s POI. Training program components, which relate to
like‑aircraft types, are dissimilar when they do not meet the criterion for
“essentially the same.” When differences are too pronounced or too numerous
in the judgment of the POI, flight deck layouts and fm must not be viewed as compatible.
2. When the observation is acceptable to the operator’s POI.
c) An observation conducted by the FAA is always permissible instead of
an observation conducted by an approved check airman or by a Designated Examiner
(DE) employed by the operator. An observation by an FAA inspector counts toward
the observation requirements of all operators contracting for training program
services provided by a training center. POIs and TCPMs may conduct an observation
at any time at their discretion. It is anticipated that operators and training
centers will exchange information regarding observations of their instructors.
However, it is the responsibility of the operator to ensure that all required
observations are kept current and are documented.
6) Conduct training center surveillance to determine continued
compliance with the operator’s approved program.
7) If the operator requests approval of two or more centers,
determine that all training, testing, and checking is conducted using the operator’s
approved curriculum. To ensure standardized training for all of the operator’s
crewmembers, it is essential that, before authorizing multiple sources of training,
the operator provides the POI with a surveillance plan to ensure continued compliance
with their approved curriculum by all centers. Each authorized training center
must conduct the operator’s curriculum as approved by the operator’s POI and
be alike in content, training times, maneuver descriptions, procedures, checklists,
and FSTDs. If a training center is providing the same training program to two
or more operators at the same center, it may be permissible (with the operator’s
permission) to interchange crewmembers during the flight training phase. This
may only be accomplished providing the individual operator’s training curriculums
are essentially similar, including aircraft checklist, flows, emergency procedures,
and profiles. In this example, two separate but identical programs are being
8) Determine that FSTDs are appropriate to, and representative
of, the aircraft being operated by the air carrier. Flight training equipment
must be specifically qualified and approved for the operator’s use, as well
as each maneuver, procedure, or crewmember function to be trained.
9) Each training facility must be authorized and listed in the operator’s OpSpec/MSpec/LOA A031.
10) Each training curriculum/module approved to be conducted by a training provider must be listed, by curriculum title, in the operator’s OpSpec/MSpec/LOA A031.
11) Review the operator’s instructor/check airman standardization program.
NOTE: A sample instructor/check airman standardization program can be found on the AFS‑280 website.
12) Review the operator’s training center audit program.
13) Ensure that required airman training records meet regulatory
requirements. If requested by the operator, the POI may permit the training
provider to maintain the operator’s crewmember training records. However, the
operator must be advised that they (the operator) remain responsible for the
security, accuracy, and availability of all required records. Permitting a training
center to maintain operators’ records does not relieve the POI of required check
airman/APD tracking requirements outlined elsewhere in this order or the POI’s
office Quality Management System (QMS) policies.
C. TCPMs. From time to time, TCPMs may be called upon to assist
a POI whose operator is using the services of a training center. The TCPM’s
firsthand knowledge of center personnel, facilities, equipment, and curriculums
is a valuable resource that POIs have come to rely on. This knowledge enables TCPMs to:
1) Provide the POI information regarding the status and approval
level of FSTDs and the installed equipment used by center instructors and TCEs;
2) Assist the POI by providing technical information regarding
the center’s curriculums, FSTDs, and facilities; and
NOTE: TCPMs should advise the POI of any status change involving an
instructor or TCE that is also approved as a contract check airman for an operator.
3) Assist the POI with the evaluation of TCEs or other training
center personnel nominated by the operator to become contract check airmen or
flight instructors. The procedures outlined in Volume 3, Chapter 20, will be
followed when evaluating center personnel as potential contract check airman
candidates. Aviation safety inspectors (ASI) (e.g., TCPMs) must use the following
Program Tracking and Reporting Subsystem (PTRS) codes to document surveillance of contract check airmen:
• Check Pilot ObservationProficiency Check Oral or §
135.293(a) Knowledge Test (or any portion thereof): 1641.
• Check Pilot ObservationProficiency or Competency Check (Simulator): 1642.
• Check Pilot ObservationProficiency or Competency Check §
135.293(b) or §
135.297 (Aircraft): 1643.
NOTE: If the TCPM is observing a TCE, then a PTRS activity using code 1673 (for a TCE observation) should also be completed whether a check pilot observation is being completed or
4) Assist the POI with required surveillance activities including:
a) Potential contract check airmen;
b) Observing contract check airman during the evaluation of the operator’s airman to ensure evaluations are objective, accurate, and consistent with the operator’s program;
c) Evaluation of required crewmember training records that were authorized
to be maintained by the training center; and
d) Other surveillance activities appropriate to the operator’s activities at the training center.
NOTE: In all cases, the TCPM’s assistance is subject to their office’s
D. Training Center(s). A training center’s roles, responsibilities,
and coordination activities include:
1) Participating in the operator’s instructor/check airman standardization
program to ensure there is a clear understanding between the center and the
operator of exactly what portions (by regulation) of the operator’s approved
curriculums the center will be conducting.
2) Ensuring the operator has received approval from their POI
to use center facilities and personnel in the conduct of their approved curriculums.
3) Establishing a naming convention that will enable operator-approved
curriculums/courses to be distinguished from center‑approved curriculums. Operator
programs are not to be referred to as core or specialty, as these terms are
only appropriate for TCPM‑approved center curriculums/courses.
NOTE: Training centers are not required to list operator names or the
operator curriculums/courses in the center’s training specifications (TSpec).
Only the center’s TCPM‑approved core or specialty curriculums/courses are required
to be listed in the center’s TSpecs.
4) Ensuring that all center personnel used to instruct and/or
check on behalf of the operator have been appropriately trained, evaluated,
and authorized in accordance with the operator’s approved curriculums to conduct
such activities. This training must include, at a minimum, training in all portions
of the operator’s curriculums for which the contract instructors/check airmen
are assigned to conduct on behalf of the operator.
5) Ensuring that sufficient contract instructors are qualified
to support the operator’s training agreement and requirements.
6) Recommending (not qualifying) center personnel as potential
contract check airmen. The center must ensure recommended individuals:
a) Have completed the center’s approved instructor training program, and
b) Are currently qualified and actively participating in one or more of
the center’s core curriculums appropriate to the operator’s needs.
7) Maintaining the center’s FSTDs in accordance with their qualification standards.
NOTE: If a Simulator Component Inoperative Guide (SCIG) has been developed
for a particular full flight simulator (FFS), and the training agreement with
an operator includes FFS training, make sure the SCIG has been approved for
the operator’s use.
8) Advising the operator whenever flight training equipment fails to meet required qualification standards and/or when maintenance problems will restrict training.
9) Ensuring required training records are appropriately maintained
and remain readily available to both the Administrator and operator.
10) Ensuring crew pairing policies and procedures are adhered
to as it relates to the operator’s training and testing/checking.
NOTE: Crew pairing policies and procedures may be found in paragraph 3‑4414 below.
11) Advising operators of any proposed revisions to the center’s
curriculums that are being used partially or in total by the operator.
3-4414 OUTSOURCED TRAINING PROVIDER APPROVAL PROCESS.
A. Application to Outsource Required Crewmember Training.
1) Operators requesting approval to outsource a portion of their
required flightcrew member training must submit an application in a form and
manner prescribed by the Administrator. The application must contain sufficient
detail to enable the Administrator to evaluate the applicant’s request. Applications
must be submitted a minimum of 60 days prior to the proposed training and contain
at least the following information:
a) A copy of the standardization review including an analysis of the training
provider’s curriculums, courseware, procedures, equipment, facilities, and personnel
that will be used in the conduct of the operator’s training.
b) A detailed outline, by regulatory reference, of the training elements
proposed to be outsourced.
c) If center personnel will be used as contract instructors to conduct the
operator’s training, the application must contain an appropriate training module
developed to qualify center’s instructors/TCEs on the operator’s curriculum.
d) If center personnel are being requested to act as contract check airmen,
the application must contain an appropriate training module developed to qualify
center’s instructors/TCEs as contract check airmen for the operator. (See paragraph 3‑4415 for complete details.)
e) A copy of the operator’s instructor/check airman standardization program.
f) A copy of the operator’s proposed surveillance plan to ensure the center
continues to provide the agreed training.
g) Proposed method to maintain required crewmember, contract instructors,
and contract check airmen training records, including the methodology proposed
to ensure curriculum revisions and an appropriate instructor/check airman read
file are maintained.
h) Other data that the POI may require to evaluate the application.
2) The approval for an operator to use a part
142 training center or other provider in the conduct of their required
training is authorized through the issuance of OpSpec/MSpec/LOA A031. An initial standardization
review must be conducted by the operator and submitted to the POI before any
contract training or checking may be conducted. OpSpec/MSpec/LOA A031 also requires
the operator to conduct ongoing audits of the training center/provider to ensure
the training center is continuing to provide training and checking in accordance
with the operator’s approved program. The initial audit must be completed within 60 days of the commencement of contract training or checking operations.
Each audit with evaluation must be presented to the certificate holder’s POI
for review and acceptance within 30 days after completion. Ongoing audits will
be conducted at least every 24 months in order for the operator to continue
to use the training center/provider. Guidelines for the scope and content of
the operator standardization and audit program are located on the AFS‑280 website.
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 above.
3) A sample outline of the modules and elements of an operator’s
curriculum that are typically contracted out to a training center can be found
on the AFS‑280 website. These curriculum checklists have been developed to provide
a guideline for the operator and center in determining which regulatory requirements
may be satisfied by the training provider and which will be completed by the operator.
B. Flight Training Equipment.
1) In order to receive training/checking/testing credit for the
use of a FSTD, the specific FSTD must be a part of the operator’s approved curriculum.
The subject curriculum and FSTD are a part of the outsourced training audit
and must include a comparison of the aircraft flown by the operator to the flight
training equipment available at the training center. The comparison should encompass
the make, model, and series (M/M/S) (and serial number, in some cases) of the
aircraft and FSTD and include a summary of the flight instrumentation, autopilot,
flight management system (FMS) equipment, aircraft modifications (electrical
system, hydraulic system, engines, propellers, thrust rev, heads‑up display,
etc.) applicable to each. Regulations require that the flight training equipment
fully meet the requirements of the operator’s training program and accurately
represent the M/M/S of aircraft flown by the operator, including installed equipment.
If the flight training equipment available at the training center does not match
the operator’s aircraft, the operator’s program must state how any differences
between the aircraft and the FSTDs will be addressed and develop an appropriate
differences training module.
2) A TCPM’s approval of a center’s FSTDs for use within the center’s
approved curriculum does not authorize an operator to use the same FSTDs within
the operator’s curriculum. The TCPM’s approval only ensures that the FSTDs are
approved to conduct the training, testing, and checking permitted under
part 142. In order for an operator to use a center’s FSTDs in
support of the operator’s curriculum, the operator must include the FSTDs in its training program
and have the FSTDs approved by its POI. The operator’s POI will evaluate the
requirements of the operator’s program and make a determination concerning the
appropriateness of the center’s FSTDs and their qualification as it relates
to the operator’s curriculum. POIs may request verification of the flight training
equipment authorized for use by a training center by contacting the center’s TCPM.
3) To receive training credit for a particular FSTD, the FSTD
must first be qualified by the National Simulator Program (NSP) (AFS‑205) and
be assigned a specific level of qualification. TCPMs and POIs may then approve
the FSTD for use by a center or operator respectively, by specific maneuver(s),
procedure(s), and crewmember function(s). Approval letters are generally issued
to operators and centers specifying the FSTD’s use within a specific curriculum.
Operators are authorized the use of FSTDs through the inclusion of the FSTDs in their training program.
C. Approving/Accepting a Center’s Core or Specialty Curriculums for Use by an Operator.
1) Training centers often submit programs to their TCPM for approval that are targeted for specific customers and/or operators. However, these curriculums must meet part
142 requirements and are either “core” or “specialty” as defined by part
142. Once a curriculum is approved by the TCPM, it is listed in the
center’s TSpecs as a core or a specialty curriculum/course. For an operator to use a
center‑developed curriculum it must submit the curriculum to its POI for approval.
The procedure for approving a center‑developed curriculum is the same as if
the operator had developed the curriculum or paid a consultant to develop the
curriculum. The important point to remember is that when the subject curriculum/course
is approved by the operator’s POI, it becomes part of the operator’s training
program and as it relates to the operator, it ceases to be either a core or a specialty curriculum.
2) Once the subject curriculum/course is approved by the operator’s
POI, the center, when conducting training for the operator, should refer to
the subject curriculum by the name given to it by the operator. It is important
to note that the training center should not refer to the operator’s program
as a specialty curriculum. This naming convention is important to clarify oversight
and ownership responsibilities for the subject curriculum/course. An operator’s
programs are approved by its POI in accordance with the appropriate operating rule.
a) Training center curriculums, both core and specialty, are approved by a TCPM in accordance with part
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 TCPM’s approval of a center’s curriculum does not
enable an operator to use such curriculum without the specific approval of the operator’s POI.
3) In order for an operator to request a training center’s approved
curriculum to be incorporated into their program, the operator must first complete
a comparison between the proposed center’s curriculum to their approved curriculum.
All differences must be noted and a training module developed to bridge the
differences. This training module will be used to qualify the center’s instructors
and/or TCEs on the operator’s curriculum. It is the operator’s responsibility
to ensure all center instructors and/or proposed contract check airmen receive
training on the differences module(s) developed as a result of the curriculum
comparison before they may be authorized as contract instructors or contract check airmen for the operator.
4) The operator may find that a center’s curriculum may be used
without change but that there may be minor differences in operating procedures
and/or checklists. As part of the standardization and audit process, the operator
must determine all differences between their curriculum and the center’s. If
the differences found are minor, the operator’s POI may authorize the operator
to develop a briefing guide outlining the differences as a suitable method to
provide the training necessary to qualify the center’s personnel. Major differences
between the curriculums will require specialized differences or formal retraining
of the center’s personnel. In all cases, the operator’s regulations require
contract instructors and check airmen 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 programs 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 operator’s program must clearly define these functions and their procedures to ensure adequate training is conducted and recorded.
b) SOPs, including but not limited to:
• Crew coordination and “callouts,”
• Maneuver descriptions and aircraft configuration,
• Flight deck “flows,”
• Checklist procedures,
• Autopilot use and crew coordination,
• Crew Resource Management (CRM), 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 and are not required to include operator‑specific items required by
135 training regulations. Part
142 training‑center‑developed curriculums are required to meet the certification requirements of parts
63 and the associated
PTS or ACS. Consequently,
part 142 training center curriculums will not
comply with the operating rules governing an air carrier and by default do not
contain or reference operator‑specific requirements or the limitations/authorizations
contained within an operator’s OpSpecs/MSpecs.
7) If an operator is introducing a new aircraft and requesting
the adoption of a center’s curriculum in support of the introduction, the operator
is responsible for ensuring the proposed curriculum meets their operational
requirements. Additionally, the operator must:
a) Evaluate the proposed curriculum and submit it to their POI for approval/acceptance.
b) Develop a module(s) outlining any operator‑specific training required
to qualify center personnel as contract instructors and or contract check airmen
based on the POI’s authorized curriculum.
c) If a contract check airman is being proposed, the operator must provide
the selected individual with any operator‑specific training identified during
the curriculum approval process.
d) Submit an appropriate contract check airman request to their POI a minimum
of 15 business‑days prior to the proposed use of the contract check airman.
8) Table 3‑122A, SampleWeight 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 of §
135.293(a)(3), which require operators to train and check their pilots on
their (the operator’s) method of determining compliance with W&B limitations.
Part 142 requires the center’s curriculum to comply with
part 61, §
61.155(c)(9), which is typically modeled after the manufacturer’s procedures.
When confronted with these differences, an operator must decide to either:
a) Train and qualify the center’s instructors to enable them to conduct
the operators approved W&B training module; or
b) Providing there is no negative training involved, permit the center to
conduct the manufacturer’s weight, balance training, and then conduct a specialized
course designed to cover the differences between the center’s curriculum and
that of the operator. If the operator chooses to permit the center to conduct
the center’s W&B module, the operator would then be required to convene
a separate instructional period to train and test the differences between the
center’s curriculum and its (operator’s) W&B curriculum. This differences
training would be required prior to releasing any crewmember for line operations.
c) As mentioned in subparagraph C9)a) above, the operator could elect to
provide W&B training to one of the center’s instructors in those elements
of their curriculum that are different from the center’s curriculum. It would
then be possible for the qualified instructor to conduct the entire W&B
module for the operator’s crewmembers. However, without specified training in
the operator’s procedures, the center may only be authorized to provide training
and testing in those subjects that are part of the center’s curriculum (Table 3‑122A, lines 14). 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 the AFS‑280 website has been designed
to provide assistance in this area.
Table 3-122A. SampleWeight and Balance Curriculum Module Comparison Chart
Aircraft Manufacturers Weight & Balance Procedures (Airplane Flight Manual (AFM))
Aircraft Manufacturers Weight & Balance Procedures (AFM)
Load Shift/Fuel Management and Use
Load Shift/Fuel Management and Use
Operations Specifications (Paragraph A096, A097, A098)
Carry-on Baggage identification and load and storage
Passenger Weight determinationaverage, surveyed, actual
Baggage/cargo weight determination
Cabin Configuration and loading
Baggage Compartment loading and security
Air Carrier Computation method (computer)
1: Topic may comply with the operator’s approved curriculum. However, the use of company‑developed flip charts, computers, “WIZ Wheels,” etc., may require specialized
training. Differences evaluation required.
2 through 4: Topics may comply with the operator’s approved curriculum. Differences evaluation required.
5 through 13: Topics do not conform to the operator’s curriculum.
14: Applicable to the particular curriculum. Differences evaluation required.
10) The curriculum an operator submits for approval to its POI
must contain sufficient detail to assure all required training is addressed.
The operator is responsible for submitting the subject curriculum to its POI
for review, approval/acceptance, and subsequent inclusion in its training program,
before any training is accomplished by the training provider.
11) This document will be jointly developed by the training provider
and the operator, and will specify the division of all tasks required for training/testing/checking
between the training provider and the operator. (Other equivalent methods that
specify the division of tasks may be acceptable.) The operator bears the primary
responsibility to ensure that all ground and flight training required by their
specific operating rule is conducted and appropriately evaluated. The POI’s
oversight responsibility is to ensure that the operator’s compliance efforts
are satisfactory. The POI should check signoffs (certifications) of ground training
and all testing for completeness, and should cross‑check those signoffs against
the source document showing the division of tasks. For example, part
135 operators must ensure the training required by §
135.345 is conducted and all subjects required by §§
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 website.
NOTE: Training centers are not certificated as air carriers or commercial
operators and are not issued OpSpecs/MSpecs. The operator‑specific requirements
of an air carrier’s operating regulations make it impossible for a part
142 training center to have a training curriculum approved under those
regulations. TCPMs may only approve training center curriculums that comply with part
142. Training centers may develop curriculums designed to comply with
the operating rules of an air carrier; however, the curriculums cannot be approved
as “meeting” the requirements of those parts. Training center instructors and
evaluators are likewise qualified in accordance with a center’s approved curriculums
and therefore cannot conduct an air operator’s training without first being
qualified by an air operator before conducting any of the operator’s required training. (Refer to §§
121.414, and §§
135.340.) Depending on the content of a particular center’s instructor/TCE
training curriculum, an operator may be able to credit a portion of the center‑provided training as meeting some of their required instructor/check airman training requirements.
12) When a center revises one of their core or specialty training
curriculums that originally formed the basis of an operator’s approved curriculum,
the center should be encouraged to advise the operator of the revision. However,
it is important to understand that revisions to a center’s core or specialty
curriculums, which were used as the basis of an operator’s training curriculum,
does not automatically create a revision to the operator’s POI‑approved course.
The adoption of such changes is subject to the operator’s evaluation and approval
by its POI. Center revisions that are considered appropriate for the operator’s
program may be incorporated by the operator if approved by the operator’s POI.
Likewise, the operator may make changes to its curriculum, in which case they
must notify the center and ensure that all contract instructors and contract
check airmen are trained in the new procedures (differences). Operators must
be especially vigilant to ensure that changes to the training center’s core
or specialty curriculums do not affect the training they receive.
D. Air Carrier Training at Multiple Training Centers.
1) Occasionally, an air carrier will request that training be
conducted at two or more training centers. These centers may be owned by the
same parent company, satellite centers of the same certificate holder, or may
be training centers operated by different companies. It is common practice for
training centers operated by different owners/companies to take varied approaches
to curriculum design and development for the same aircraft M/M/S. These differences
often include training equipment, training hours, maneuver 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 noncertificated operators. However,
because air operators are required to have their own approved programs, differing
curriculum between or among training providers is not authorized. Training conducted
by different centers will present a standardization problem if not properly
monitored and managed by the operator.
3) To qualify a center’s personnel to conduct an operator’s training
curriculums will require the operator to conduct an evaluation of the center’s
curriculums to determine what, if any, differences exist between the two and
provide center instructors and evaluators training in those differences. This
process must be repeated for each center authorized to conduct training for
the operator. If a contract check airman is requested, the additional training
appropriate to the operator’s check airmen training will also have to be completed.
4) If POIs have reason to believe that multiple centers can provide
the quality training required by the operator’s approved curriculum, they may
authorize two or more facilities or training companies to conduct the subject
training. However, if the POI suspects that an operator curriculum cannot be
adequately presented at multiple centers due to differing delivery methods,
FSTDs training hours, maneuver descriptions, qualified personnel, etc., and/or
the operator’s ability to adequately monitor and audit the training being provided,
the POI and the operator have the responsibility to limit the number of training providers.
E. Training Policy and Procedures.
1) Operators are required to develop and document, as part of
their approved program, adequate procedures and policies to ensure all training
providers conduct the operator’s crewmember training as approved. These procedures
may be part of the operator’s manual used by the certificate holder’s flight
personnel in conducting its operations and/or contained in the operator’s approved training program.
2) Operators must establish training policies and procedures
to ensure crewmembers are trained and evaluated in accordance with the policies
and procedures that represent the manner in which it conducts its aircraft operations.
It is unacceptable to have differences between training/checking and actual
aircraft operations or between individual crewmembers.
3) POIs are not to approve requests for outsourced training unless
the operator’s program contains appropriate policies and procedures to ensure
the training conducted by the authorized training provider(s) is in accordance with the operator’s approved program.
NOTE: Operators must ensure that approved training providers are provided
at least one copy of their operating manual(s), including the revision service
for such manuals, which cover the particular areas that the training provider
has been approved to conduct. The operator must also ensure the training provider
maintains a “read file” specific to the operator that is available to all contract
instructors, contract check airmen, and the operator’s crewmembers. This read
file must contain information pertinent to their flight operations and crewmember
operating procedures. Refer to the Instructor/Check Airman Standardization Program
on the AFS‑280 website for additional information.
4) An operator that determines a center‑developed curriculum
is suitable for its use must receive its POI’s approval to integrate the subject
curriculum into its training program. See subparagraph 3‑4414C for policies
and procedures for the integration of a center’s curriculum into an operator’s program.
F. Crew Pairing.
1) Training centers often provide services to air operators, which must meet requirements of particular operating rules (i.e., parts
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 outlined in the operator’s training program.
2) The FAA promotes the crew concept in air carrier training
and checking to ensure that crew coordination and other flight management issues
are adequately and appropriately addressed. Flight training must address the
performance of duties as Pilot Flying (PF) and pilot monitoring (PM) as described
in the air operator’s approved procedures. To meet both of these seat‑dependent
training needs, each required flight deck crew position must be occupied by a qualified crewmember.
3) It is desirable that each flight training session be scheduled
so that two pilots from the same company or air operator may be trained during
a single flight training session. The preferred crew pairing is a pilot in command
(PIC) and a second in command (SIC). Other acceptable crew pairings are two
PICs or two SICs employed by the same certificate holder. Each pilot receiving
training should have completed the appropriate aircraft ground training, including
basic indoctrination, prior to beginning the flight training segment.
4) Permissible crew pairings. Some air carriers often operate
with small pilot rosters or with pilots who are widely dispersed. Providing
the operator’s training program does not otherwise restrict crew pairings for
flight training/checking/testing in a FSTD at a training center, the center
may use the following guidelines when determining who may be considered an appropriate crewmember.
a) An appropriate crewmember must be one of the following:
1. One of the air carrier’s line qualified pilots,
2. One of the air carrier’s pilots undergoing training for the same aircraft, or
3. A contract flight instructor (airplane or simulator) or a contract check airman (airplane or simulator) who is authorized to serve in that air carrier’s
b) The following conditions apply when a part
135 air carrier pilot is training in an FAA‑approved training
program for another part
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 carrier’s operations must be addressed during flight training.
• When only one pilot is receiving flight training, the other pilot
seat must be occupied by a person who is line qualified or line familiar in
the specified duty position (refer to the current edition of Advisory Circular (AC)
120‑35, Flightcrew Member 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 operator’s applicable ground training
curriculum segments prior to starting the flight training curriculum segments.
5) Pairing pilots in flight training and evaluation for operations
under different parts. When pilots from different operators are paired in training
programs that are essentially similar, the operator‑specific features (such
as MELs and OpSpecs/MSpecs) of each operator must be addressed. Pilots in training for part
135 operations should not routinely be paired with pilots training for
operations under part
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 CRM principles in accordance with the
air transport pilot
PTS or ACS, as applicable.
b) Each certificated air operator’s crewmember must complete the appropriate air operator’s evaluation module. Part
135 pilots may support the part
91 pilot’s training activities as appropriate.
91 pilots paired with an air operator crewmember must use the operator’s
approved curriculum. In these cases, the TCPM must either concur with the part
91 pilot’s use of the air operator’s curriculum to complete required
training and currency, or approve a documented process submitted by the training center
that ensures all requirements described herein are met. The training center
should maintain records of such pairings in sufficient detail to allow FAA inspectors
to easily determine compliance with the applicable regulation, operator’s crew
pairing procedures (if provided), and these requirements.
d) The part
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 operator’s
OpSpecs and operational control procedures.
NOTE: In crew pairings involving pilots of different part
135 operators or pilots operating under different operating rules
(parts 135 and
91)), POIs and TCPMs must be especially vigilant. The
part 135 operator’s training program must not be distorted or diminished in
order to accommodate dissimilar training needs. If the integrity of the air carrier training program cannot be upheld, the crew pairing must not be permitted.
1) Regulations require an operator to maintain training and qualification
records for each crewmember, flight instructor, and check airman. This requirement
includes contract instructors and contract check airmen employed by training
providers that are authorized to provide training and checking for the operator.
The means and methodology of maintaining required crewmember records must include
an acceptable process to record training, checking, and qualifications of the
operator’s crewmember training conducted by an outsourced training provider.
The operator’s training program should contain a description of their recordkeeping
system, as well as describing what records are to be used to comply with each
regulatory requirement. If the operator wishes to use an electronic recordkeeping system, the current edition of AC
120‑78, Electronic Signatures, Electronic Recordkeeping, and Electronic
Manuals, provides guidance for the evaluation and approval of these systems.
2) Operators and training providers must establish and document
procedures to ensure they have a clear understanding of their individual responsibilities
for complying with required training and testing/checking recordkeeping requirements.
These procedures must include identification of responsible personnel and approved
location(s) where specific records will be maintained.
3) Training conducted by center personnel must be documented
in accordance with the operator’s approved system. Center personnel acting as
contract instructors and/or contract check airmen for the operator must also
be trained in the operator’s records system.
4) Training centers are not required under part
142 to maintain an air carrier’s crewmember training records when the
training was accomplished in accordance with the operator’s approved program. Training centers are only required to maintain the records required to support the training accomplished under part
142 that leads to airman certification or proficiency required by part
63. An operator’s crewmembers are not trained and evaluated in accordance
142. They are trained and evaluated in accordance with the operator’s
operating regulations and approved curriculums. Therefore, the responsibility for record
maintenance remains with the operator. Training centers that have been authorized
to provide training for an operator are considered to be an integral part of
that operator’s training program. In that context, FAA policy permits the center
to be used as a suitable location for required records if approved by the operator’s
POI. Many training centers provide a large portion of an operator’s training
and in some cases are the sole providers of such training, which may make the
center a logical location for such records.
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 airmen for an operator, it may also make sense for the
operator to have its instructors and/or check airmen records maintained by the
center. It is, however, the responsibility of the operator to ensure that all
crewmember records are readily available for inspection as required by applicable regulations.
6) Operators must ensure that training records developed and maintained by their
training providers are readily available to the operator. 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 airmen must also be made
readily available to the operator.
7) In many cases, the TCPM will be the best qualified individual
to assist the POI with required inspections, proficiency checks, and observations
of assigned operators. Properly maintained records will also enable the TCPM
and training centers to provide information on instructors and TCEs to other
operators that may need instructor and evaluator assistance.
8) A TCE who is authorized as a contract check airman may be
approved by one or more POIs to conduct checks for multiple operators that have
contracted with a training center. This may occur when multiple operators of
the same aircraft type have contracted for training at the same center and are
using essentially the same curriculum.
9) Although not required, training centers that maintain contract
check airman records for operators may be a good source of information for other
operators who are evaluating center personnel as potential contract check airman.
10) Training centers must have a process whereby they keep customers
apprised of all training or checking conducted on the operator’s behalf. Additionally,
the center must notify the operator within 24 hours if there is a job functions
status change with a TCE or instructor who is also a contract check airman or
contract flight instructor for the operator that may affect the individual’s
check airman or instructor status with the operator.
11) TCPMs are responsible for maintaining eVID information regarding
the training center, its instructors, and evaluators. POIs are responsible for
maintaining eVID files pertaining to each training center employee authorized
as a contract check airman.
3-4415 REQUIREMENTS TO AUTHORIZE CONTRACT FLIGHT INSTRUCTORS AND/OR CONTRACT CHECK AIRMEN FOR AN AIR OPERATOR.
A. Requirements. Sections
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 “sufficient” number of contract check airmen 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 FAA support;
• The operators understanding that they are required to provide
surveillance and supervision of their contract instructors/check airmen;
• Availability of FSTDs and location relative to the domiciles of the operators’ crewmembers; 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 airmen/instructors are appropriate. Maintaining
an equitable balance between the operator’s ability to provide required management
oversight and surveillance, while meeting their evaluation requirements without
compromising standardization or safety, is a primary concern.
B. Qualification and Training Requirements. The qualification
and training requirements for individuals to become contract flight instructors
and/or contract check airmen for an air carrier are outlined in the specific
regulations governing the type of operation (specifically part
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 airman
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 airman training
required by an air carrier, the two currently do not align. The differences
between these two regulatory requirements will generate additional training
requirements for training center instructors and evaluators selected to provide
training and checking services for operators.
C. Instructors. Consider the case of a part
142 training center flight instructor (simulator) who is qualified to
provide instruction under the training center’s approved core curriculum for a particular aircraft.
1) In order for a training center instructor to serve as a flight
instructor for an air carrier, the individual must be trained and qualified
to instruct in each training segment, module, or element of the air carrier’s
curriculum that the instructor will be responsible for providing to the air
carrier’s crewmembers. Current policy does not require center instructors to
complete the carrier’s entire approved training program or curriculum provided:
a) The individuals are limited to conducting only the training elements
of the operator’s curriculums that they have been specifically trained and qualified
to conduct and have been authorized by the operator; or
b) The individual has previously received the same training, proficiency/competency
checks, and observations in the same M/M/S aircraft for another air carrier
operating under the same part.
2) Situations where an air carrier adopts a training center’s
core or specialty curriculum(s) and the POI approves these curriculums as part
of the air carrier’s training program would also mitigate some of the training
required by the operator to qualify the subject instructor. In this situation
the only training the air carrier would be required to provide the center’s
instructor(s) would be limited to any differences that exist between the training
center’s curriculum(s) (as approved by the TCPM) and the air carrier’s training
curriculum (as approved by the carrier’s POI).
NOTE: In such cases, it is the air carrier’s responsibility to identify
each difference between the carrier’s approved training curriculum (including
curriculum content, checklists, and procedures) and the training center’s curriculum.
The air carrier must then develop and provide their POI a training module to
qualify the center’s personnel on all noted differences. This differences training
module must be approved by the POI prior to conducting the subject training.
3) The air carrier’s POI has the responsibility to determine
if the manner and method proposed by the air carrier to train and qualify the
center’s personnel on curriculum differences, will meet the operator’s training requirements.
D. Review. To ensure the center’s personnel meet the operator’s check airman standards, the operator will need to review the individual’s training
history and qualifications.
1) Elements of the center’s instructor/TCE training curriculums that the operator
finds equivalent to their training program may, with the POI’s approval, be
credited toward the completion of the operator’s instructor/check airman curriculums.
If the center’s curriculum has been submitted to the POI for approval and is
approved as meeting the requirements of the operator’s curriculum, other than
the operator‑specific items, no additional training for the center’s personnel
would be required. Any differences or deficiencies noted will require the operator
to develop a training module to ensure all regulatory requirements are met in
order to qualify the center’s personnel as contract check airmen.
2) In addition to the instructor qualification and testing requirements outlined in subparagraphs 3‑4415B and C, operators must accomplish the following to qualify
an individual as a contract check airman:
a) Evaluate the instructor/TCE’s credentials to ensure he or she meets the
certificate holder’s requirements to become a contract check airman.
NOTE: Individuals must have at least one year of experience as a center
instructor or TCE in the make and model (M/M) aircraft in order to be considered
as a contract check airman for an operator. POIs are encouraged to contact the
center’s TCPM for assistance with the review and potential approval of contract
check airmen. TCPMs are often the POI’s best source of information relating
to a center’s operation and personnel.
b) Evaluate the center’s instructor and TCE training curriculum by comparing
it to the operator’s check airman curriculum to determine the differences training
required to qualify the center’s personnel as a contract check airman.
c) Develop an appropriate differences training module(s) to include the
operator‑specific elements of the check airmen qualification and training/checking
regulations to qualify the center’s instructor/TCE as a contract check airman.
d) Submit the contract check airmen training module(s) to its POI for acceptance/approval.
e) If the training course is approved, ensure the course is provided to
all contract check airmen candidates.
f) Provide the POI with complete training records and submit the individual’s
name and résumé for review and approval in accordance with Volume 3, Chapter 20.
g) If the applicant is approved as a contract check airman, the POI will make the necessary eVID entries.
NOTE: POIs should notify the center’s TCPM whenever they authorize one
of the center’s personnel to act as a contract check airman. This may be accomplished
by forwarding the TCPM a copy of the check airman’s LOA. A sample contract check airman LOA is located on the AFS‑280 website.
E. Categories of Authorization. The standard categories of authorization
for check airmen currently shown in Volume 3, Chapter 20 do not provide the
level of specificity required for the approval of contract check airmen. For example, an operator’s check airman, qualified as a line captain may be authorized
as a simulator only check airman permitting him or her to administer both §
(9) as well as
§ 135.297 evaluations. A contract check airman who is only qualified in the
aircraft‑specific modules of an operator’s curriculum may be authorized to conduct simulator‑only evaluations; however, he or she would be limited, due to his or her training, to evaluations of
§ 135.293(a)(2) and
§ 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
§ 135.293(a)(1) or
(9). Other restrictions may also apply depending
on the training and qualification provided by the operator. A sample contract
check airman LOA is located on the AFS‑280 website.
F. Training of Instructors and Evaluators.
1) Because the typical training program offered by the training
center currently does not include all of the ground training subjects contained
in an operator’s curriculum, it follows that neither the trainees nor the instructors
and evaluators themselves receive training in those subjects. It is important
to ensure all training center instructors and evaluators are trained and evaluated
in all subjects that the center is contracted to conduct. For example, because
the typical training program offered by the training center currently does not include ground training in the subjects contained in
§ 135.293(a)(1) and
(9), it follows that neither the trainees
nor the instructors and evaluators themselves receive training in those subjects.
Therefore, a TCE typically is not qualified to evaluate subjects other than
those contained in the center’s core curriculum, which equates to
§ 135.293(a)(2) and potentially
(3). Similarly, a trainee should not be evaluated in those subjects by individuals not qualified in the operator’s procedures.
NOTE: To preclude any confusion concerning a contract check airman’s
authorization, the POI must specify in each contract check airman’s LOA what
specific subjects the check airman is authorized to test and check.
2) Particular caution must be exercised to ensure that individuals
being nominated by an air carrier to become contract instructors/check airmen
have a good understanding of the issues typically faced by crewmembers on a
daily basis, many of which are learned only through the completion of an air
carrier’s initial new‑hire training curriculum. Knowledge of an air carrier’s
operational environment becomes very important when instructors/check airmen
may be required to draw upon that knowledge to ensure that the quality of training
and evaluations demanded by the regulations is not compromised. Non‑aircraft‑specific
issues such as flight following/dispatch, MEL/Configuration Deviation Lists
(CDL), cabin crew/flightcrew interactions, hazmat, security, company SOPs, etc.,
play an important role in a crewmember’s training; especially during Line‑Oriented
Flight Training (LOFT) events. To effectively function as an air carrier instructor/evaluator,
individuals must have a good understanding of these issues.
3) Before an air carrier authorizes a contract instructor or
nominates an individual to become a contract check airman, the air carrier must
provide its POI with evidence that these individuals have completed at least
one air carrier’s initial training and qualification curriculum as a flightcrew
member for an operator certificated under the same 14 CFR part. Providing the
operator and the assigned POI find this training and qualification acceptable,
individuals may be considered to have met the non‑aircraft‑specific training
requirements to become a contract instructor/check airman. The completion of
an operator’s line check requirement(s) is not required. Following the completion
of an appropriate differences training curriculum, the subject individuals may
be authorized as contract instructors and nominated to become contract check
airmen. This process should preclude an individual from conducting training
and checking in an air carrier environment without ever having had the benefit
of, at a minimum, the training required to qualify an individual to act as required
crewmember for an air carrier.
G. Proficiency Evaluations. The proficiency evaluations required
by an air carrier to qualify and maintain the currency of its check airmen are
also applicable to center personnel that are being nominated as contract check
airmen for the operator.
NOTE: TCPMs are only required to verify that the center’s TCEs receive annual training on the conduct of part
61 certification functions in accordance with part
142 subpart C, relating to the curriculums approved for the training
center’s use. As outlined above, this training and checking does not qualify an individual
to act as an operator’s check airman. Operators must complete a detailed comparison
between its check airman curriculum and that of the training center’s TCE curriculum
to determine the extent of the additional training they must provide to qualify
the center’s personnel to act as a contract check airman on their behalf. If this comparison indicates that the operator’s training programs are identical,
other than the operator‑specific items, no additional training for the center’s
personnel is required. Any differences noted between the curriculums will require
the operator to develop a training module to qualify the center’s personnel
as a check airman. This module must be presented to the operator’s POI for approval/acceptance.
H. Contract Instructors/Check Airmen. Training center employees
that have been qualified by an operator to serve as a contract instructor/contract
check airman may be considered qualified to act in the same capacity for another operator provided that:
1) Both operators are certificated under the same 14 CFR part.
2) Both operators are operating the same M/M/S of aircraft with identical configurations.
3) Both operators are using identical training curriculums, including checklist and operating procedures.
4) The requesting operator finds the subject individual acceptable as a contract instructor/check airman.
5) The subject instructor/check airman has met the operating
or observation experience requirements for at least one operator for which they
are providing services. For example, if a training center instructor is qualified
to provide instruction in a particular aircraft for three different operators,
the instructor may be considered to have met the initial and recurrent line
operating or observation requirements for all three by remaining qualified in
one of the operator’s programs.
NOTE: In all cases, the acceptance of an instructor/check airman’s qualification by another operator is subject to the approval of the requesting operator’s POI.
I. Reports. The POI should arrange to have the operator provide
the POI with a periodic report of each check airman’s checking activities, including
a pass/fail rate, to coincide with the POI’s periodic review (annual, semiannual,
or other). POIs may arrange for these reports to arrive at a time that meets
the POI’s needs. A contract check airman should be active enough to retain the
required knowledge and skills. This activity level may vary depending on the
contract check airman functions and other operators for which he or she is authorized
check airman activities, the size of the operator, and the number of approved
check airmen. Usually a check airman should conduct at least eight authorized
check airman activities during a 12‑month period (including supervision of Operating
Experience (OE)). The POI should specifically reassess the operator’s need for
those check airmen whose records indicate low activity levels.
3-4416 OUTSOURCED TRAINING PROVIDER AUDITS AND ASSOCIATED OPSPEC/MSPEC PROCEDURES.
A. Self-Audit Program. The FAA requires a mandatory self‑audit program for operators certificated under the provisions of part
91K and 14 CFR part
119 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/LOA A031 to record
FAA approval of these contract training arrangements.
B. Operator Responsibility. The FAA is often limited in its ability
to oversee an air carrier’s training operations conducted under contract by
a training provider(s). This oversight is the primary responsibility not of
the FAA, but of the operator itself. The operator holds an air carrier certificate
as a privilege granted by the Administrator on the presumption that the operator
will continually maintain the highest safety standards, including flightcrew
training standards. The operator must ensure that its flightcrew training conducted
by a contractor continually meets the requirements set by regulations and the
standards contemplated at the time of initial certification.
NOTE: The current edition of AC
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/LOA A031, and should be conducted at any time that a major change affects the operator’s outsourced flightcrew training.
D. POI Verification. POIs must verify that their operators arranging
with training providers to conduct contract training for their crewmembers,
otherwise known as outsourced training, will accomplish the following activities.
a) Training Program Components: Adherence to Approved Program. The operator
must document that the training program delivered by the training provider is
identical to the training program approved for the operator’s use by the POI.
The documentation will address at least the following:
• The format and content of curriculums, curriculum segments, training
modules, and documents depicting flight maneuvers and procedures;
• Facilities; and
• Qualifications of instructors and check airmen.
b) Training Curriculums: Adherence to Approved Program. The operator must
audit curriculums and document that those curriculums presented by the training
provider adhere to the curriculums contained in its FAA‑approved training program.
The documentation must address at least the following, including ground training
and flight training curriculum segments:
• Initial new-hire training;
• Upgrade training;
• Transition training;
• Recurrent training;
• Refresher training (part
• Initial equipment training;
• Requalification training; and
• All other approved training such as differences, related aircraft differences
(part 121 only), hazmat, security, and CRM, as appropriate.
c) Flight Training and Testing/Checking: Adherence to Approved Program. The operator must observe all contract instructors and contract check airman
who are conducting required instruction and evaluations on their behalf by center personnel. The operator must document that regulations contained in
§§ 91.1089 through
§§ 121.411 through
121.414; or §§
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 91 and
• 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 operator’s crewmembers, including
pilots, FEs, and flight attendants (F/A) who have received outsourced training
since the last review cycle. The operator must document that each crewmember
has successfully completed all of the required components of training and checking
comprised by its approved training program.
2) Summary Report. The operator must prepare a report, summarizing
the findings of its self‑audit. A sample report is on the AFS‑280 website. This
sample report form may be used to compile self‑audit findings and to submit
findings to the POI as a summary report. Another form mutually acceptable to
the operator and the POI may be used instead. The summary report must be signed
by the operator’s director of operations. In all instances that discrepancies
are found between the training program delivered by the training provider and
that which is approved by the FAA, the operator must propose effective remedies.
Those remedies must be included in the summary report and must be addressed
under the following categories:
a) Immediate corrective action:
1. Action already taken, showing dates; and
2. Action planned, showing target dates.
b) Long-term corrective action, showing target dates; and
c) A strategy for ensuring continuing prevention of recurrence.
3) OpSpec/MSpec/LOA A031. All affected operators are required
to be issued OpSpec/MSpec/LOA A031. Any training provider conducting contract
training, within the meaning of this section, must be approved by the POI and
recorded in OpSpec/MSpec/LOA A031.
E. Program Discrepancies. An operator contracting for training
must address any training program discrepancy and undertake corrective action
as soon as the discrepancy becomes known. When the operator’s own remedies are
insufficient, the POI must take additional steps as deemed necessary and appropriate,
in accordance with applicable provisions of Title 49 of the Code of Federal
Regulations (49 CFR), 14 CFR, this order, and the current edition of FAA
Order 2150.3, FAA Compliance and Enforcement Program.
NOTE: For guidance in accomplishing an Internal Evaluation Program (IEP) evaluation, refer to
AC 120‑59 and Volume 3, Chapter 28, Section 1, Air Carrier
F. New Outsourced Training Arrangements. When approving new outsourced training arrangements for
part 91K use the regular PTRS recording procedures for the
appropriate job function and enter “Contract” in the “National Use” field.
RESERVED. Paragraphs 3-4417 through 3-4432.