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8900.1 CHG 555

VOLUME 3  GENERAL TECHNICAL ADMINISTRATION

CHAPTER 19  TRAINING PROGRAMS AND AIRMAN QUALIFICATIONS

Section 9  Safety Assurance System: Differences Training—All Training Categories

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Source Basis:

    Section 61.31, Type Rating Requirements, Additional Training, and Authorization Requirements.

    Section 121.400, Applicability and Terms Used.

    Section 121.401, Training Program: General.

    Section 121.403, Training Program: Curriculum.

    Section 121.415, Crewmember and Dispatcher Training Program Requirements.

    Section 121.418, Differences Training and Related Aircraft Differences Training.

    Section 121.419, Pilots and Flight Engineers: Initial, Transition, and Upgrade Ground Training.

    Section 121.424, Pilots: Initial, Transition, and Upgrade Flight Training.

    Section 121.425, Flight Engineers: Initial and Transition Flight Training.

    Section 121.427, Recurrent Training.

    Section 121.433, Training Required.

    Section 135.291, Applicability.

    Section 135.321, Applicability and Terms Used.

    Section 135.323, Training Program: General.

    Section 135.327, Training Program: Curriculum.

    Section 135.329, Crewmember Training Requirements.

    Section 135.341, Pilot and Flight Attendant Crewmember Training Programs.

    Section 135.345, Pilots: Initial, Transition, and Upgrade Ground Training.

    Section 135.347, Pilots: Initial, Transition, Upgrade, and Differences Flight Training.

    Section 135.351, Recurrent Training.

3-1311    GENERAL. This section contains information, direction, and guidance to be used by inspectors when evaluating an operator’s differences training in all categories of training. In accordance with Title 14 of the Code of Federal Regulations (14 CFR) part 121 subpart N and part 135 subpart H, differences training is required if a flightcrew member will serve on a variation(s) of a particular aircraft type that has pertinent differences from the base aircraft type. The base aircraft type and the variation(s) must have the same type certificate (TC). Related aircraft differences training applies to aircraft with different TCs that have been designated as related by the Administrator. Information, direction, and guidance regarding related aircraft designation, evaluation of an operator’s related aircraft differences training, and related aircraft deviations are located in Volume 3, Chapter 19, Section 12. Definitions of terms are located in Volume 3, Chapter 19, Section 1. This section is related to Safety Assurance System (SAS) Element 2.1.1 (OP) Training of Flight Crewmembers.

A.    Background. Due to differences in instrumentation and installed equipment, the skills and knowledge required to operate a variation(s) of an aircraft type can differ. The range of differences between variations of an aircraft type can be significant due to technological advancements. Flightcrew members trained on one variation of an aircraft type may require additional training to safely and efficiently operate another variation(s) of that aircraft type.

B.    Identification of Base Aircraft and Variation(s). To develop differences training, an operator must first identify a base aircraft and the variation(s) of the aircraft.

1)    Base Aircraft. The base aircraft is the aircraft or group of aircraft identified by the operator for use as a reference to compare differences with other aircraft within the operator’s fleet. This comparison of differences between aircraft is for items that affect, or could affect, flightcrew knowledge, skills, or abilities pertinent to flight safety. Operators identify base aircraft by the N-number (such as “N 611DL”); the operator tail number (such as “aircraft 801-820”); the make, model, and series (M/M/S) (such as “DC-9-31”); and/or other classifications that can uniquely distinguish between the operator’s different aircraft pertaining to the different configurations, handling characteristics, performance procedures, limitations, controls, instruments, indicators, systems, equipment, options, or modifications. A base aircraft may either be a single aircraft or a group of aircraft with the same features and may be changed at the discretion of the operator. Base aircraft are typically those aircraft within a fleet in which flightcrew members are first trained, of which the operator has the greatest number, or which represent a target configuration for the operator to eventually use as a standard.
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2)    Variation(s) of the Aircraft Type. A variation of the aircraft type is an aircraft or a group of aircraft with the same TC as the base aircraft. A variation of the aircraft type has the same features as the base aircraft. If the variation(s) of the aircraft type has pertinent differences from the base aircraft, differences training is required. Pertinent differences are those that could affect flight safety. Typical pertinent differences are those relating to configuration, handling qualities, performance, procedures, limitations, controls, instruments, indicators, systems, equipment, options, or modifications. For example, a Boeing 737-200 ADV with a performance data computer system, SP-177 autopilot, dual-cue flight director (FD), and autoland is a different variation than another Boeing 737-200 ADV with a single-cue FD, SP-77 autopilot, and basic very high frequency omni-directional range station/distance measuring equipment (VOR/DME) navigation equipment. An operator may have a number of variations in addition to a base aircraft within a fleet.

3-1312    SPECIFIC SITUATIONS REQUIRING DIFFERENCES TRAINING. Inspectors should be knowledgeable in the several situations in which differences training may be required, as follows:

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    When an operator generates a need for differences training by introducing a variation of an aircraft into an existing fleet that has pertinent differences from the base aircraft.

    When an operator generates a need for differences training by creating a variation with pertinent differences by modifying one or more aircraft in the fleet.

    When mergers and acquisitions generate the need for fleets to be merged in operations.

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3-1313    FLIGHT STANDARDIZATION BOARD (FSB) REPORTS. Differences training must be based on an accurate analysis of the differences in design and maneuvers of the aircraft involved. In 1989, the FSBs began analyzing differences in variations of existing aircraft during certification. The FSB formulates Master Differences Requirements (MDR) and Differences Tables to address differences between related aircraft. These MDRs and Differences Tables are presented in tabular format in the appropriate FSB report. FSB reports are generally available for large turbojet and turbopropeller aircraft, Special Federal Aviation Regulations (SFAR) 41 airplanes, and 14 CFR part 23 commuter category airplanes. FSB reports are posted on the Flight Standards Information Management System (FSIMS) under the “Publications” tab. Additional information about FSB reports is available in the current edition of Advisory Circular (AC) 120-53, Guidance for Conducting and Use of Flight Standardization Board Evaluations, and Volume 8, Chapter 2.

3-1314    DEGREES OF DIFFERENCES. Principal operations inspectors (POI) must ensure that the methods used to conduct differences training are appropriate to the degree of difference between the base aircraft and the variation(s). For the purposes of describing degrees of difference and for defining acceptable training and checking methods, five levels of differences have been defined (Levels A–E). These levels are compatible with those described in FSB reports, but are discussed here primarily for guiding POIs in approving differences training when an FSB report does not exist for the aircraft type.

A.    Level A Differences. Level A differences are those differences of which the flightcrew member needs to be aware, but which have little effect on systems operations. For example, an engine starter on one variation has different time limits but does not have differences in controls, indicators, function, or procedures. Self-instruction methods, such as highlighted pages of operating manuals or training bulletins, are acceptable for these differences. For Level A differences, checking is not required.

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B.    Level B Differences. Level B differences are those differences in systems, controls, and indicators that have only minor procedural differences. Level B differences are of great enough degree to require formal training in general operational subjects, aircraft systems, or both, but are not of great enough degree to require systems integration training. An example of a Level B difference is a fuel system with additional fuel tanks, pumps, and gauges. Procedural differences are limited to the operation of transfer valves and pumps while an aircraft is in cruise flight. Appropriate instructional methods for Level B differences include, but are not limited to, audiovisual presentations, lectures, and tutorial computer-based instruction (TCBI). A task or systems check for Level B differences must be conducted after training. Appropriate methods include an oral or written exam or TCBI self-test.

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C.    Level C Differences. Level C differences are part task differences of flightcrew member knowledge, skills, and/or abilities. Level C differences are those differences of great enough degree to require a systems integration training module but that are not of great enough degree to require actual flight training (see Volume 3, Chapter 19, Section 5 for a definition and description of systems integration training). An example of a Level C difference is the installation of a flight management system (FMS) computer. Appropriate training methods in the systems integration module are dedicated part task trainers, interactive computer-based instruction (ICBI), or Level 4 or higher flight simulation training devices (FSTD). Level C differences require a check following training. Appropriate devices are the same as for Level C training. Checking methods appropriate to Level C differences are demonstrations of skill in the procedures affected by the difference. In the case of the installation of an FMS computer, checking might consist of preflight programming of the computer and a demonstration of its use in navigation, climbs, and descents.

D.    Level D Differences. Level D differences are full task differences of flightcrew member knowledge, skills, and/or abilities. Level D differences are those differences for which there is a requirement for flight training modules in a Level 6 or higher FSTD. When Level D differences exist between two aircraft, general operational subject modules, aircraft systems modules, and systems integration modules may be required. An example of a Level D difference is the installation of an electronically integrated flight instrumentation display. Aircraft operations using such a display are required to contain flight training in most phases of flight. Level 6 or higher FSTDs are appropriate for conducting Level D differences training and qualification modules. Level D differences require a check following training. The check must be conducted using scenarios representing a real‑time flight environment.

E.    Level E Differences. Level E differences are such significant full task differences that a “high‑fidelity” environment is required to attain or maintain knowledge, skills, or abilities. Level E differences are those differences for which there is a requirement for flight training, including landing events. An example of a Level E difference is the installation of a Short Takeoff and Landing (STOL) kit on an aircraft, resulting in a very different flare and landing attitude. A Level C or D full flight simulator (FFS) or an aircraft is required for flight training in Level E differences. Checking for Level E differences requires a full part 121 proficiency check or part 135 competency check in a Level C or D FFS or an aircraft.

3-1315    METHODS FOR ACCOUNTING FOR DIFFERENCES. There are several acceptable methods operators may use to account for differences. Inspectors should be knowledgeable of the following acceptable methods:

A.    Standardized Configurations. The simplest and most traditional method for operators to use when dealing with differences is to avoid them by installing common instruments and equipment in each aircraft in the fleet.

B.    Separate Fleets. Some operators treat variations of an aircraft type as if they were different aircraft by developing separate curricula for each variation and by scheduling flightcrew members to operate only those variations of the aircraft types on which they have been trained.

C.    Integrated Training. An operator can conduct differences training as an integral part of each of the six defined categories of training. For example, an initial equipment Boeing 737 ground training curriculum segment may include a training module which includes training on the powerplant for the Boeing 737-200 and training on the powerplant for the Boeing 737-300.

D.    Separate Differences Curriculum Segments. The operator may choose to limit instruction throughout a curriculum to one specific base aircraft and then conduct training as to the differences present in variation(s) of the aircraft type as a separate and distinct curriculum segment. For example, an operator might designate the 100-series aircraft as the base aircraft in a transition Boeing 737 second-in-command (SIC) curriculum. Ground, flight, and qualification curriculum segments would be based on this aircraft. At an appropriate point in the instruction, a distinct curriculum segment would be presented to cover differences in the 200-, 300-, or 400-series aircraft. This method is advantageous when the operator operates numerous variations of an aircraft type.

3-1316    APPROVAL PROCESS. The approval process for differences training follows the five-step process described in Volume 3, Chapter 19, Section 2. The operator must submit a differences evaluation and an outline of the differences training curricula and/or segments.

A.    Differences Evaluation.

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1)    The FSB Report Contains MDRs for Variation(s) Involved. When an FSB report has been published that contains MDRs for the variation(s) involved, the operator’s proposed differences training must comply with the requirements in the FSB report. Operators typically use operator difference requirements (ODR) tables to show how the program addresses differences through descriptions of training and checking methods for each variation. ODR tables provide a uniform means for operators to comprehensively manage differences training and provide a basis for Federal Aviation Administration (FAA) approval. ODRs must comply with and be just as or more restrictive than MDRs and other FSB recommendations. The ODR tables must also comply with and be just as or more restrictive than the Differences Tables in the FSB report, as applicable to the variation(s) operated by the certificate holder. The POI should consult with the principal maintenance inspector (PMI) and principal avionics inspector (PAI) to identify aircraft modifications or optional equipment that is not addressed in the Differences Tables in the FSB report. If the modification or optional equipment requires additional pilot knowledge, skills, or abilities, the POI should consult with the Aircraft Evaluation Division (AFS-100) and the Air Transportation Division (AFS-200), as necessary, to determine the appropriate training.

NOTE:  If the FSB report does not contain Differences Tables for the additional variation(s) involved, the POI should consult with AFS-100 to identify the specific differences in design and maneuvers.

2)    The FSB Report Does Not Contain MDRs for Variation(s) Involved. An operator proposing differences training for which the FSB report does not contain MDRs for the variation(s) involved must submit a differences analysis conducted by the operator or other qualified party (such as a manufacturer or another operator). The analysis may take any form as long as it accurately identifies all differences in design and maneuvers that affect flight characteristics, flightcrew member skills, and/or procedures. One acceptable means of constructing a differences analysis is to construct a curriculum outline for the base aircraft and to identify each curriculum item in which there is a difference (see Table 3-72, Example of Differences Worksheet).
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a)    Part 121. The POI must obtain concurrence from AFS-200 before approving the differences training for the new variation. AFS-200 will collaborate with AFS-100 to determine if the analysis is acceptable, or if FSB action is necessary. The FSB may require that additional information or analysis be provided, or that the entire difference level test process or parts thereof be completed.
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EXAMPLE:  A certificate holder proposes to operate a new variation of a Boeing 737. The POI consults with AFS-100 and it is determined that the differences affect pilot knowledge, skills, and abilities pertinent to flight safety. Therefore, the POI would review the analysis and proposed training submitted by the certificate holder and seek concurrence from AFS-200 to approve the differences training for the new variation. AFS-200 would collaborate with AFS-100 to determine if the analysis is acceptable or if FSB action is necessary.

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b)    Part 135. Concurrence from AFS-200 is not required to approve differences training for the new variation. A POI may consult with AFS-100, if necessary, to determine if the differences affect pilot knowledge, skills, and abilities pertinent to flight safety.
3)    An FSB Report Does Not Exist for the Aircraft Type. An operator proposing differences training for which an FSB report has not been published must submit a differences analysis conducted by the operator or other qualified party (such as a manufacturer or another operator). The analysis may take any form as long as it accurately identifies all differences in design and maneuvers that affect flight characteristics, flightcrew member skills, and/or procedures. One acceptable means of constructing a differences analysis is to construct a curriculum outline for the base aircraft and to identify each curriculum item in which there is a difference (see Table 3-72).

B.    POI Evaluation of Curriculum and/or Curriculum Segments. Prior to granting initial approval, the POI must evaluate the curriculum and/or curriculum segments to ensure:

    The differences analysis is complete and accurate.

    The curriculum and/or curriculum segments contain the appropriate instructional elements to account for the differences identified in the analysis.

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    The appropriate methods of instruction and devices to conduct the training are used. The methods and devices must be consistent with the Differences Tables in the FSB report, as applicable to the variation(s) operated by the certificate holder. If the certificate holder proposes an alternative method or device than as specified in the Differences Tables, the POI must consult with AFS-100 and AFS-200 to determine if the alternative method meets an equivalent level of safety.

    If an FSB report has been published that contains MDRs that cover the variation(s) involved, the proposed differences training complies with all requirements in the FSB report, including methods of training and checking.

    AFS-200 has provided concurrence, if required (see subparagraph 3-1316A2)).

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3-1317    RECURRENT DIFFERENCES TRAINING AND CHECKING. When operators assign flightcrew members on multiple variations of an aircraft, recurrent differences training and checking is required at the same differences level as specified in the MDR and Differences Tables, unless otherwise specified in the FSB report.

3-1318    SEAT-DEPENDENT TRAINING. Pilots operating aircraft from the left and right pilot seats are frequently confronted with special skill and training requirements. The differences in flightcrew member duties and skill requirements vary from insignificant to highly significant in different makes and models of aircraft. For this reason, POIs must evaluate an operator’s seat-dependent training requirements on a case-by-case basis. POIs may require that operators use a differences evaluation (as described in this section) for making this determination. POIs should refer to the FSB report for the specific aircraft for the seat-dependent tasks identified during the FSB evaluation.

Table 3-72.  Example of Differences Worksheet

BASE AIRCRAFT

VARIATION OF THE AIRCRAFT

Aircraft Systems Subject Areas

Hydraulic System

 

    Pumps

Pneumatic pump deleted; electric pump added

    Supply

No change

    System A Components

Yaw damper added

    System B Components

Deleted

    Ram Air Turbine

Electrical pump time

    Limitations

Yaw damper off below 100 feet

Electrical System

No change

Air Conditioning System

No change

Systems Integration Subject Areas

Normal Procedures

 

    Inertial Navigation System

New procedures

Non-Normal Procedures

 

    Hydraulic Fluid Loss

No change

    Hydraulic Pump Failure

Different procedures

    Hydraulic Fluid Overheat

No change

    Electrical System

No change

Flight Training Maneuvers and Procedures

Normal Procedures

Different procedures

Preflight

Differences

No-Flap Approach

Different procedures

Loss of Pressurization

No change

One-Engine-Inoperative Approach

Different procedures

RESERVED. Paragraphs 3-1319 through 3-1335.