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8900.1 CHG 215

VOLUME 6 SURVEILLANCE

CHAPTER 8 PART 142 SURVEILLANCE

Section 1 Part 142 Inspections: Surveillance and Inspection Activities for Part 142 Training Centers, Satellites, and Remote Sites

6-1601    BACKGROUND.

A.    The Federal Aviation Administration (FAA) is empowered, by statutory requirement, ď...to carry out the functions, powers, and duties of the Secretary relating to aviation safety.Ē One of the most significant duties of the FAA is to conduct surveillance in all areas of air transportation safety. Surveillance is a continuing duty and responsibility of all aviation safety inspectors in the flight standards organization. The term ďsurveillance,Ē as used in this handbook, relates to this ongoing duty and responsibility and related programs. Surveillance programs provide the FAA with a method for the continual evaluation of operator compliance with Title 14 of the Code of Federal Regulations (14 CFR) and safe operating practices. Information generated from the surveillance programs permits the FAA to act upon deficiencies, which affect or have a potential effect on aviation safety. For surveillance programs to be effective, they must be carefully planned and executed during the conduct of specific inspection activity. Inspections provide specific data, which can be further evaluated; therefore, they support and maintain ongoing surveillance programs. Inspections are specific work activities that have the following characteristics:

    A specific work activity title and PTRS code;

    A definite beginning and a definite end;

    Defined procedures;

    Specific objectives; and

    A requirement for a report of findings (either positive, negative, or both)

B.    Training center program managers (TCPM) have regulatory oversight responsibility for certificated 14 CFR, part 142 training centers and the task of determining if a certificated training center continues to meet the requirements of their initial certification as defined during the certification process. A comprehensive surveillance plan will enable the TCPM to:

    Determine each operatorís compliance with regulatory requirements and safe operating practices;

    Detect changes as they occur in the operational environment;

    Detect the need for regulatory, managerial, and operational changes; and

    Measure the effectiveness of previous corrective actions and focus on the certificate holdersí ability to continue to offer the training, testing, and checking authorized by its certificate and training specifications

6-1602    GENERAL.

A.    FAA polices and procedures for surveillance activities are detailed in Volume 6. TCPMs and their assistants should review volume 6 for guidance on the development of a surveillance plan for assigned training centers. Volume 6, Chapter 1, Sections 1 and 2 provides policies and procedures for the planning and execution of surveillance programs. Volume 6, Chapter 2 contains specific surveillance guidance on various types of inspections that will also aid with the development of an appropriate surveillance plan. Volume 6, Sections 2 through 10 and 17 through 19 pertain to centers that conduct actual aircraft training. Volume 6, Section 11 deals with base inspections, which contains information applicable to all centers, associated satellites, and remote sites.

B.    The information in this section is meant to supplement the surveillance guidelines in FAA Order 8900.1 , Volume 6 and will concentrate on specific areas relating to the inspection of part 142 training centers, their satellites, and or remote sets.

6-1603    SURVEILLANCE PLAN.

A.    Four-Phase Surveillance Programs. When developing a surveillance plan, be sure to follow the four phases for planning and executing surveillance programs located in Volume 6, Chapter 1 of this order. Specific guidance for each phase is also located in volume 6, chapter 1.

B.    Frequency and Timing. Although unannounced inspections may be appropriate under some conditions, inspectors should consider conducting inspections at a time agreed and coordinated with the training centers management. Whenever practicable, the more encompassing formal inspections should be conducted during normal working hours (0800-1700). Routine daily or weekly inspections and/or observations should be conducted randomly and at times and places to ensure compliance with the certificate-holding district officeís (CHDO) surveillance plan. Surveillance plans for centers that operate around or nearly around the clock should include inspections throughout the centerís operating hours.

C.    CHDO, Flight Standards District Office (FSDO), International Field Office (IFO) Responsibilities. Surveillance and inspection of satellite training centers and remote training sites will normally be conducted by the FSDO/IFO holding geographic responsibility for the particular center or site after coordination with the CHDO. Consult FAA Notice 8000.363, Flight Standards Geographic Program, for guidance on geographic responsibility. (PTRS code 1559.)

NOTE: The surveillance coordination between a certificate-holding district office (CHDO) and related FSDO/IFO satellite district office(s) (SDO) for the surveillance of satellite center(s) or remote sites is outlined in subparagraph 6-1603H of this section.

D.    Developing a Surveillance Plan. The basis for a good surveillance plan begins with an evaluation of the centers; original certification documentation, training specifications, and the centers compliance statement (if available). Secondly, inspectors should evaluate the requirements for initial certification, outlined in section 6 of this chapter, on a recurring basis as part of any comprehensive inspection process.

E.    Job Aids. Inspectors can find job aids to assist with their inspection functions on AFS-210ís Part 142 Web site. Inspection areas that do not have a job aid available should use the detailed guidance for that subject located within this chapter. (PTRS codes 1603, 1607, 1612, 1621, 1626, 1629, 1630, 1640, 1641, 1642, 1643, 1644, 1645, 1646, 1647, 1649, 1650, 1652, 1653, 1654, 1662 1668, 1672, and 1673.)

F.    Policies and Procedures. Volume 6 outlines the agencies policies and procedures for the development of surveillance plans and remains the primary guidance. The following subparagraphs are provided as a supplement to the guidance provided in volume 6 and not meant to replace or supersede that guidance.

1)    Aircraft and Ramp Checks. Ramp checks may include foreign aircraft, aircraft not yet registered, and aircraft furnished by clients or applicants.
2)    Observation of Training Programs. TCPMs will schedule periodic observations of approved curricula and/or courses to ensure that each curriculum is being conducted in accordance with its current approval and to ensure the courseware originally or subsequently approved for the specific curriculum is being appropriately utilized.
3)    Advertising. Training center certificate holders that conduct public advertising must adhere to the following:
a)    Distinguishing Types of Training. A training center certificate holder may not advertise to conduct any training that is not approved by the FAA if that training is designed to satisfy any requirement of 14 CFR, chapter 1. However, training that is not related to, or designed to satisfy a 14 CFR, chapter 1 requirement may be advertised by a training center providing such advertising is clearly distinguished as not being FAA-approved or part of the training centerís approved curricula.
b)    Accuracy of Statements. A training center may not make any statement relating to its certification that are false or designed to mislead any person contemplating enrollment. The training center must clearly differentiate between courses that have been approved and those that have not.
c)    Curricula or course naming conventions.

1.    Part 142 training centers may not advertise or hold out to the public that they have an approved curriculum that meets a certificated air operatorís requirementís, such as 14 CFR parts 121, 125, or 135 . For example, centers may not advertise that they have an approved part 121/125/135 pilot training curriculum, course, or program.

2.    Part 142 training centers do not hold a certificate authorizing part 121, 125, or part 135 operations, and may not have its training programs approved in accordance with those parts. Training center curricula are approved under part 142 and as such, the approved curricula must meet the requirements of that part.

3.    The fact that a part 121, 125, or 135 operator adopts the training centerís curriculum as its own, does not give the training center the authority to advertise or promote itself as having a part 121, 125, or 135 training program. Rather, the training center is limited to the authority granted in part 142, and may only describe its training programs as having been approved for use in some part 121, 125, or 135 operations.

4.    Training centers may advertise that they have courses designed to meet other regulatory requirements, but they cannot advertise that that they have FAA-approved courses that meet the regulatory requirements outside of those authorized by their part 142 certificate.

d)    Surrender of Certificate. When a training center certificate has been surrendered, suspended, revoked, or has expired (foreign certificate holders only), the center must remove all indications of FAA approval and cease advertising that the training center is certificated by the FAA. The center must remove all advertising signs and cancel radio, television, newspaper, magazine, billboard, and other associated advertisements for the training center.
e)    Suspending or ceasing operations at a particular facility. A training center, satellite, or remote site that suspends or ceases operations at a particular facility must promptly remove all signs indicating that an FAA-approved center is located at that facility.
f)    Flight Simulators and Flight Training Devices (FTDs). Evaluate the following areas for compliance with program approval and training specifications authorizations: (PTRS codes 1630 and 1654.)

    Functional evaluations.

    Accurate replication of the aircraft type for the curriculum in which used.

    Logbook or other use records.

    Simulator component inoperative guide (SCIG), if developed.

    Discrepancy and/or maintenance logbooks to determine if any recorded item would or would not have affected the training, checking, or testing conducted.

    Records of daily preflight to determine if discrepancies are being recorded and if maintenance is deferred on any discrepancies that would affect training, checking, or testing.

    Training specifications to ensure all flight simulators and FTDs have been properly authorized and approved.

    When installed, inspect oxygen masks, smoke goggles, and audio control panels to ensure proper operation.

    Randomly select operational functions of authorized FTDs and simulators to ensure their initial qualification standards are being maintained.

NOTE: When the CHDO is a Certificate Management Office (CMO) or a Certificate Management Unit (CMU) operational responsibility and surveillance of all Satellite Training Centers will be through the CMO/CMU. Aviation safety inspectors assigned to the CMO/CMU will ensure operational responsibility and conduct the surveillance at all satellite locations.

g)    Facilities. Ensure that the centerís training specifications list all satellite training centers and their remote training sites. (PTRS codes 1640 and 1647)
h)    Center Training Records. The centerís record keeping processes must contain a quality program that enables responsible managers and/or personnel to evaluate the accuracy and adequacy of the record keeping system. This process must include at least the following elements/procedures:

1.    A review to determine compliance with the approved training program. Each record must show a chronological record of the studentsí participation in the training program, as required by the part 142 , ß 142.73(a) recordkeeping requirements. (PTRS code 1649.)

2.    An evaluation to ensure that the student prerequisites for entry into training were verified and documented.

3.    A review of the instructor and evaluator records to determine compliance with the requirements of ß 142.73(b) . (PTRS code 1650.)

4.    A review of the centers training specifications to determine the approved location for maintaining required center and student records as well as the approved method(s) for keeping such records.

NOTE: A checklists to assist inspectors with their inspection requirements of training center records may be found on AFS-210ís Part 142 Web site.

4)    Training Center Evaluators (TCE). Ensure that each evaluator is observed annually by a qualified FAA inspector. The surveillance (which may be unannounced) will consist of the following: (PTRS codes 1641, 1642, 1643, 1668, and 1673.)
a)    Observation of the conduct of an oral evaluation.
b)    Observation of the flight simulator portion of a practical test, which should include the observation of the evaluator operating the simulator control panel during a certification practical test or check.
c)    Observation of the aircraft portion of a practical test, if appropriate.
d)    Compare the centers training specifications or individual TCE listing against the centerís copy of each TCEís LOA for consistency, and to ensure each authorized TCE has received training appropriate to their LOA.
5)    Advanced Qualification Program (AQP) Curricula. Survey and inspect approved AQP curricula in accordance with the guidance provided by Volume 3, Chapter 4, Section 4, and Volume 6.
a)    Record all activity connected with an AQP by using the existing PTRS activity codes and 14 CFR combinations. When reporting certification, surveillance, or other activities associated with an AQP curriculum, ensure that the letters AQP are annotated in the National Use field of the PTRS. No other changes to PTRS reporting procedures are entailed.
b)    The PTRS form may be overprinted or modified to provide the TCE or AQP evaluator with additional guidance and aid in standardization of data entry.
c)    PTRS Activity Codes. All of the operations activity codes that are defined in FAA Order 1380.51 continue to apply under AQP. Some unique AQP tracking requirements may be necessary in the future, and recording procedures will be provided at that time.
d)    Ensure that AQP curricula being used are authorized in the training specifications.
6)    Training Programs, Curricula, and Courses.
a)    Evaluate the courseware, syllabuses, equipment, and personnel to ensure that they continue to meet part 142 regulatory requirements. A checklist to assist with the internal evaluation of training centers can be found on AFS-210ís Part 142 Web site. (PTRS codes 1626 and 1646.)
b)    Ensure that the training specifications include all approved curricula/courses.
7)    Quality Assurance Programs.
a)    During surveillance of the training centers, the inspector will be able to observe the effectiveness and adequacy of quality assurance measures.
b)    TCPMs should consider the following when reviewing the centerís proposed quality control measures:

1.    Number of Inspections.

2.    Effectiveness. The effectiveness of the training centerís quality assurance audits may be measured by examining past quality assurance audits.

    Whether these audits identified any deficiencies or appear to be a routine fulfillment of a regulatory requirement; and

    Whether the training centerís auditors appear to have an in depth knowledge of the centerís objectives and regulatory requirements and responsibilities.

3.    Documentation.

    Review the reports prepared by the training centerís quality assurance department to determine if they are complete and thorough;

    Ensure that the reports reveal what was reviewed and inspected and have in-depth analyses into the deficiencies found and recommended corrective action(s); and

    Ensure the reports were reviewed by the training centerís quality assurance department, how responsible supervisors or managers responded to the report, and the corrective action taken.

c)    Determine if the program provides a realistic means to address problem areas.
d)    Determine if the program describes how training of auditors will be conducted.
e)    Determine whether all personnel understand their obligations under the quality assurance program.
f)    Does the centerís top management fully support the program and provide meaningful feed back to the employees?

G.    Inspection Results. The completion of a particular inspection will always result in one of the following:

1)    Issuing a finding of satisfactory;
2)    Issuing a list of observations; or
3)    Issuing a finding of unsatisfactory and indicating expected corrective action or other ramifications of the unsatisfactory results.

H.    Future Activities.

1)    Schedule follow-up inspections for any deficiencies.
2)    Possible enforcement investigation on items not in compliance.
3)    Continuation of routine surveillance and interaction.

I.    Surveillance of a Principal Training Center With Satellite Center(s). This subparagraph discusses the coordination required when a training center organization has one or more satellites attached to the principal center which are located outside of the principal CHDO geographical area of responsibility. While the CHDO of the principal training center retains the final authority for overall management of the centerís certificate, the FSDO/IFO with geographical responsibility for associated satellite(s) and occasionally remote sites will normally conduct required surveillance activities of those sites on behalf of the CHDO.

NOTE: Satellite training centers under the supervision of a CMU or CMO will have their surveillance conducted under the supervision of the principal centers TCPM instead of geographically assigned inspectors. The following discussion assumes the subject satellite/remote centers are not under the supervision of a CMU or CMO. However, many of the responsibilities and procedures discussed below are applicable to satellites under the supervision of a CMU/CMO and may be used as a guide during the development of their surveillance plans.

1)    Location. The principal training centerís CHDO is normally determined by its geographic location. The location of the principal training centerís satellite(s) or remote site(s) normally determines the district office with geographical responsibility for those facilities. The FAA office with geographical responsibility for a principal centerís satellite(s) is normally referred to as the satellite district office (SDO). Oversight of international satellites is also determined by the satelliteís geographic location and normally carried out by the responsible IFO.
2)    Operational Responsibility.
a)    The principal training centerís CHDO through the assigned TCPM has the surveillance and oversight authority and responsibility for the principal centerís certificate and associated training specifications. SDOs in collaboration with the principal centerís TCPM provide surveillance, oversight, and management of satellites or remote sites within their geographic area. If assigned by the SDO, a satellite TCPM (STCPM) may be assigned to assist the TCPM with surveillance activities. TCPMs and STCPMs report to their respective office managers and are jointly linked through the FAAís Vital Information Subsystem (VIS).
b)    The surveillance and periodic review of a facilities curriculum, courseware, and personnel are the responsibility of the FAA office having geographic responsibility for the site. Final approval of the curricula, courseware, training devices, and TCEs used at a satellite or remote site are the responsibility of the principal training centers TCPM.
3)    CHDO and SDO coordination and oversight Responsibilities.
a)    The Principal Centerís CHDO will:

    Conduct/coordinate initial certification and on going certificate renewals, as required.

    Authorize satellite and remote site locations.

    Obtain satellite training center designator numbers.

    Select the principal training center TCPM, assistant TCPM (ATCPM), and PPMs.

    Provide TCPM, ATCPM and PPMs administrative support.

    Approve all center and satellite site TCE Letter(s) of Authorization (LOA).

    Conduct all principal center surveillance.

    Coordinate Memorandums of Understanding (MOU) agreements between the FAA and the principal training center. (This MOU will include all authorized satellites and if appropriate remote sites.)

    Coordinate satellite/remote training center oversight and work functions with the SDO.

    Respond to local questions, inquiries, and complaints.

b)    The SDO will:

    Select the STCPM and Partial Program Managers (PPM), required to provide surveillance of subject satellites/remote sites, if required.

    Provide administrative support for the STCPM and PPMs , if required.

    Conduct evaluations of satellite center TCE(s) in accordance with their LOA.

    Coordinate satellite/remote training center oversight and work functions with the CHDO.

    Respond to local questions, inquiries, and complaints.

4)    TCPM Duties and Coordination Responsibilities. TCPMs are responsible for the following:
a)    The review and approval of center curricula, courseware, and syllabuses. If a STCPM, ATCPM or PPM(s) has been assigned, these individuals will provide assistance with the review of the curricula authorized or to be authorized for use at their particular site.
b)    Conducting and/or coordinating TCE FAA-conducted ground school, and required surveillance.
c)    Conducting and/or coordinate TCE renewal evaluations.
d)    Approving principal training center aircraft, simulators, flight training devices (FTD), to be used in the delivery of approved training center curricula.
e)    Inspecting principal training center student, personnel, and simulator daily inspection records.
f)    Supporting the National Simulator Evaluation Team on the principal training center initial and recurrent equipment inspections.
g)    Maintaining principal training center VIS and TCE files.
h)    Processing principal training center enforcement and investigative records (EIR), self-disclosures, and pilot application files.
i)    Approving principal and satellite FTDs , simulators, and aircraft through the issuance of operations specifications (OpSpecs).
j)    Coordinating satellite training center oversight with the STCPM.
k)    Assigning work to the principal training center PPMs.
l)    Responding to local questions, inquiries, and complaints and keeping ATCPM, PPMs and STCPMs advised.
m)    Issuing/updating the certificate holderís training specifications and advising ATCPMs, FTPMs, PPMs, and STCPMs.
n)    Reviewing principal training center and satellite training center PTRS surveillance records.
o)    Conduct principal training center surveillance of instructors, TCEs, and curricula delivery.
p)    Reviewing and enter principal training center TCE activity files.
5)    STCPM Duties and Coordination Responsibilities Relating to Satellite and Remote Sites. STCPMs are responsible for the following:
a)    Assisting the TCPM with the review of center curricula, courseware, and syllabuses.
b)    Conducting FAA initial and recurrent training and observations for satellite TCEs and recommend approval or disapproved to TCPM.
c)    Evaluating satellite training center aircraft, simulators, and FTDs.
d)    Conducting satellite training center surveillance curricula and instructors.
e)    Inspecting required satellite training center student and personnel records and simulator daily inspection logs.
f)    Supporting the National Simulator Evaluation Team on the satellite training center initial and recurrent equipment inspections.
g)    Maintaining satellite training center VIS and TCE files.
h)    Processing satellite training center EIR self-disclosures and pilot application files and support findings to TCPM.
i)    Coordinating satellite training center oversight with the TCPM.
j)    Determining the assignment of the satellite training center ATCPMsí work functions.
k)    Responding to local questions, inquiries, and complaints and keep TCPM advised.
l)    Reviewing satellite training center PTRS surveillance records.
m)    Reviewing and updating TCE activity files.
Indicates new/changed information.

RESERVED. Paragraphs 6-1604 through 6-1625.