8900.1 CHG 300



Section 14  Safety Assurance System: Crewmember and Dispatcher Records Inspections for Parts 121 and 135

6-489    REPORTING SYSTEM(S). For Title 14 of the Code of Federal Regulations (14 CFR) parts 121 and 135, use Safety Assurance System (SAS) automation. This section is related to SAS Subsystems 2.1, Training and Qualification, and 3.1, Training and Qualification.

6-490    GENERAL. This section provides direction and guidance to operations inspectors for the inspection of crewmember and dispatcher qualification, training, and currency records of part 121 or 135 operators. The inspection shall establish whether or not the operator is keeping the required records and whether or not the required training and qualification events are being conducted. Before conducting a records inspection, inspectors must be thoroughly familiar with Volume 3, Chapter 31, Section 1; part 121, §§ 121.401(c) and 121.683 or part 135, § 135.63, as applicable; and this section.

6-491    PROCEDURES FOR CONDUCTING A RECORDS INSPECTION. This paragraph contains a general description of the procedures inspectors will use when conducting records inspections. Inspectors may modify these guidelines to meet local conditions.

A.    Location. Inspectors normally conduct a records inspection at the place where the operator maintains the records. The inspection process does not require that the operator surrender records, even temporarily, and records may not be removed from the operator’s premises without the operator’s permission. Should an agreement be reached for inspectors to remove records, the operator must be given an itemized receipt for all records.

B.    Preparation and Initial Briefing. Normally, advance notice to the operator of a planned records inspection is appropriate.

1)    An introduction and initial briefing should be given to the operator. The briefing should describe the purpose of the inspection, what records will be required, and that a debriefing will take place at the conclusion of the inspection.
2)    Prior to conducting any records inspections, inspectors must become familiar with the operator’s system of recordkeeping and become familiar with which specific records are available at the facility. This familiarization is particularly important when the operator is using a computer-based recordkeeping system, as detailed in Volume 3, Chapter 31, Section 4.
3)    Prior to their arrival, inspectors should prepare a list of records to be inspected, since a records inspection uses the operator’s work space and usually takes time away from an employee’s assigned duties. Preplanning and preparation for a records inspection reflect positively on the professionalism of the Federal Aviation Administration (FAA) and should result in as little disruption to the operator’s work routine as possible.

NOTE:  Information from previous records inspections that are contained in SAS or the Program Tracking and Reporting Subsystem (PTRS) should be accessed to aid the inspector in determining the strategy and scope of the inspection.

C.    Records Selection. Before conducting a records inspection, inspectors must determine the number of records to be examined, which categories of the records will be inspected, and to what depth records will be scrutinized.

1)    Volume 6, Chapter 2, Section 1, provides general guidance to inspectors for determining the actual number of records to examine.
2)    Inspectors may obtain information on crewmember and dispatcher population from the enhanced Vital Information Database (eVID).

D.    Records Handling. Care should be taken to keep records as intact as the operator presents them. The preferred procedure is for inspectors to take only a few records at a time, examine them, then return that batch to the operator before starting on another batch. If it is necessary or desirable to obtain a copy of a record, the operator may not be willing or able to provide it. In this case, inspectors must make arrangements for copies.

Indicates new/changed information.

E.    Errors or Omissions in Records. During a records inspection, an inspector could find errors or omissions in an operator’s records. Minor errors and omissions do not necessarily constitute a lack of compliance on the part of the operator. Some errors or omissions, though, may require further action. For example, a crewmember training record may be found that does not indicate that required recurrent training was accomplished.

Indicates new/changed information.
1)    Further review could produce evidence that the training actually was completed. This omission may easily be corrected on the spot by the operator and may preclude the need for further action by the inspector other than documenting what occurred. In this case, the inspector should refer to Volume 14, Chapter 1, Section 2, Flight Standards Service Compliance Action Decision Procedure, and Volume 10 for documentation and notification procedures. The inspector should discuss with the operator methods for preventing a repetition of the problem and should appropriately record the operator’s intended fix.
2)    If the operator cannot produce evidence that the training was conducted, the inspector shall refer to Volume 14, Chapter 1, Section 2 to determine what further action is warranted. The inspector who discovers the discrepancy is responsible for recording the finding in accordance with Volumes 10 and 14.

6-492    CATEGORIES OF RECORDS. This paragraph lists the crewmember and dispatcher records required by §§ 135.63 and 121.683. Some or all of the categories are required for pilots, Flight Engineers (FE), flight attendants (F/A), flight and ground instructors, check pilots, check FEs, aircrew program designees (APD), and aircraft dispatchers. Volume 3, Chapter 31, Section 3, gives guidance as to the retention period for each of these categories of records.

A.    Crewmember and Aircraft Dispatcher Training and Qualification Records. The operator’s recordkeeping procedures should be reviewed to ensure that the training and qualification required for the individual’s present duty assignment is documented. Individual records should be reviewed according to the sampling plan to verify that the operator is correctly managing the training and qualification program.

1)    The training and qualification requirements of parts 121 and 135 can be complex (see Volume 3, Chapter 19 for pilots and FEs; Chapter 20 for flight instructors, check pilots, and check FEs; Chapter 22 for aircraft dispatchers; and Chapter 23 for F/As).
2)    Sections 121.401(c) and 135.323(c) require that the documentation of ground, flight, or qualification segments contain a certification by the instructor, supervisor, check pilot, or check FE that the crewmember or dispatcher is knowledgeable and proficient. In an electronic recordkeeping system, the certification does not have to be made by means of a signature.

B.    Medical Qualification Records. Inspectors should observe that any required medical certificates are current and appropriate to the applicable flightcrew member duty position.

Indicates new/changed information.

C.    Route, Special Airport, Area Qualification Records. Inspectors must ensure that operators have documented that the pilot in command (PIC) has met the special currency requirements of § 121.443, § 121.445, or § 135.299. Inspectors must also ensure that operators with the authority to conduct flights requiring Class II navigation or to operate in special use airspace (such as North Atlantic High Level Airspace (NAT HLA), North Pacific (NOPAC), or Central East Pacific (CEPAC)) document the successful completion of required training and qualification for each flightcrew member.

D.    Operating Experience or Operating Familiarization Records. Documentation should verify that operating experience or operating familiarization has been accomplished.

1)    All part 121 crewmembers and part 135 PICs in commuter operations must have satisfactorily completed the required operating experience prior to being assigned unsupervised duty in revenue service.
2)    Part 121 PICs who have completed initial or upgrade training must have been observed by an FAA inspector during operating experience.
3)    Aircraft dispatchers must have completed operating familiarization.

E.    Recent Experience Records. This category refers to events, other than required checks, that flightcrew members must accomplish within a specified time period to remain qualified to serve in revenue operations.

1)    Pilots—Part 121. Unless a deviation has been authorized by the Air Transportation Division (AFS-200) in accordance with § 121.439(f), § 121.439(a) requires a pilot to complete at least three takeoffs and landings within the preceding 90 days in the same airplane type in which the pilot is to serve. (See Volume 3, Chapter 19, Section 12, for additional information regarding deviations based on designation of related aircraft.) A pilot who does not complete the three required takeoffs and landings within any consecutive 90-day period must reestablish recency of experience in accordance with § 121.439(b).
2)    Pilots—Part 135. Section 135.247(a)(1) requires a PIC of an aircraft carrying passengers to complete at least three takeoffs and landings within the preceding 90 days in an aircraft of the same category and class and, if a type rating is required, in the same type in which the PIC is to serve. For operations during the period 1 hour after sunset to 1 hour before sunrise, § 135.247(a)(2) requires the three takeoffs and landings to be completed within that period. If the aircraft is a tailwheel airplane, § 135.247(b) requires each takeoff to be made in a tailwheel airplane and each landing must be to a full stop in a tailwheel airplane.

NOTE:  In accordance with § 135.247(a)(3), the requirements of § 135.247(a)(2) do not apply to a PIC of a turbine-powered airplane type certificated for more than one pilot, provided the PIC meets the requirements specified in § 135.247(a)(3)(i) or § 135.247(a)(3)(ii).

3)    Flight Engineers—Part 121. Section 121.453 requires an FE to acquire at least 50 hours of flight time as an FE or to complete a flight check within the preceding 6 calendar-months in the same airplane type in which the FE is to serve.

F.    Check Pilot, Check FE, and APD Records. Operator records should verify that check pilots and check FEs have completed appropriate training, have maintained currency in the flightcrew member duty position they are evaluating, and that letters of approval or designation have been maintained. The inspector should observe that operators record the number of qualification functions being performed by check pilots and check FEs.

G.    Special Training and Testing Requirements. The inspector should observe that operators that conduct such operations as air ambulance operations keep records of specialized training.

H.    Employment History. Inspectors should ensure that the operator’s flightcrew member and aircraft dispatcher records document action taken concerning an individual’s release from employment for physical or professional disqualification as required by § 121.683(a)(2) or § 135.63(a)(4)(ix).

6-493    SAS INPUT. The inspector must record any inspection of crewmember or aircraft dispatcher records or any category of the records in the appropriate Data Collection Tool (DCT).

RESERVED. Paragraphs 6-494 through 6-507.