VOLUME 3 GENERAL TECHNICAL ADMINISTRATION
CHAPTER 19 TRAINING PROGRAMS AND AIRMAN QUALIFICATIONS
Section 9 Safety Assurance System: Differences TrainingAll Training Categories
Type Rating Requirements, Additional Training, and Authorization Requirements.
Applicability and Terms Used.
Training Program: General.
Training Program: Curriculum.
Crewmember and Dispatcher Training Program Requirements.
Differences Training and Related Aircraft Differences Training.
Pilots and Flight Engineers: Initial, Transition, and Upgrade Ground Training.
Pilots: Initial, Transition, and Upgrade Flight Training.
Flight Engineers: Initial and Transition Flight Training.
Applicability and Terms Used.
Training Program: General.
Training Program: Curriculum.
Crewmember Training Requirements.
Pilot and Flight Attendant Crewmember Training Programs.
Pilots: Initial, Transition, and Upgrade Ground Training.
Pilots: Initial, Transition, Upgrade, and Differences Flight 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
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.
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
3-1312 SPECIFIC SITUATIONS REQUIRING DIFFERENCES TRAINING. Inspectors
should be knowledgeable in the several situations in which differences training
may be required, as follows:
• 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.
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
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)
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 AE). 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.
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.
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
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
check or part
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.
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).
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.
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.
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.
• 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)).
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
Aircraft Systems Subject Areas
Pneumatic pump deleted; electric pump added
• System A Components
Yaw damper added
• System B Components
• Ram Air Turbine
Electrical pump time
Yaw damper off below 100 feet
Systems Integration Subject Areas
• Inertial Navigation System
• Hydraulic Fluid Loss
• Hydraulic Pump Failure
• Hydraulic Fluid Overheat
• Electrical System
Flight Training Maneuvers and Procedures
Loss of Pressurization
RESERVED. Paragraphs 3-1319 through 3-1335.