10/9/15

 

8900.1 CHG 177

VOLUME 6  surveillance

Chapter 11  other surveillance

Section 8  Inspect a Flight Instructor Refresher Course

6-2316    PROGRAM TRACKING AND REPORTING SUBSYSTEM (PTRS) ACTIVITY CODE. 1690.

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6-2317    OBJECTIVE. Determine if a flight instructor refresher course (FIRC) provider conducts an approved FIRC within the guidelines of its approved training course outline (TCO). Successful completion of this task results in the determination of a satisfactory or unsatisfactory performance and the completion of the FIRC Monitoring Job Aid.

6-2318    GENERAL.

A.    Title 14 of the Code of Federal Regulations (14 CFR) Part 61. Part 61, 61.197 permits the holders of valid and unexpired flight instructor certificates to renew their certificates by satisfactorily completing an approved FIRC consisting of ground training, flight training, or a combination of both.

B.    AFS-800 Participation.

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1)    The General Aviation and Commercial Division (AFS-800) issues initial authorizations and renewals of FIRC authorizations. FIRC providers wishing to initiate a FIRC program or to renew an existing FIRC authorization must contact AFS-800. AFS-800 completes renewals on a biennial basis, as requested by the FIRC provider. Unless AFS-800 issues a continuation of approval in letter form, field personnel must be aware that Federal Aviation Administration (FAA) approvals of FIRC programs expire on the last day of the 24th month from the date of issue. The expiration of FAA approval of a FIRC automatically terminates any Airmen Certification Representative (ACR) authorization held by that FIRC provider.
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2)    To ensure continuity and technical accuracy, personnel assigned to AFS-800 will normally monitor the first course conducted by a FIRC provider organization. Also, when major changes are required in a TCO, AFS-800 will normally monitor the initial subsequent course. During follow-on courses, AFS-800 will coordinate with the jurisdictional Flight Standards Service (AFS) Regional Office (RO) and Flight Standards District Office (FSDO) whenever there is a need for monitoring of a specific course.
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C.    General Process. AFS-800 issues initial authorizations and renewals of FIRC authorizations. FIRC providers wishing to initiate a FIRC program or to renew an existing FIRC authorization must contact AFS-800. AFS-800 completes renewals on a biennial basis, as requested by the FIRC provider. Aviation safety inspectors (ASI) from local FSDOs should surveil or monitor FIRCs operating in their geographic area as frequently as possible based on available office resources. See paragraph 6-2323, Prerequisites and Coordination Requirements.

D.    Terminology.

1)    Course. The term “course” is used throughout this section in place of the previously used term “clinic.” This is to bring the terminology into alignment with that found in 61.197. Use of this term is appropriate because the term “course” may be defined as a program of study of a range of closely related topics leading to a single outcome. In this case, the outcome is a graduation certificate that may serve as the basis of renewal of a qualified flight instructor’s credentials.
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2)    FIRC Provider. This section may use the term “FIRC provider” interchangeably with the terms “organization” or “provider.” “FIRC provider” is generally the preferred term, although any of these are acceptable. The FIRC provider is always the person or organization holding the authorization and whose name is identified on the letter of authorization (LOA). A FIRC provider is not necessarily the presenter.
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3)    Presenter. A presenter is an individual who is actually presenting approved FIRC material. The presenter may or may not be the FIRC provider. In any case, all presenters must be either the FIRC provider or an employee, affiliate, or contractor of the FIRC provider. Some exceptions may be made when the FIRC provider is including other non-affiliated government or industry speakers as guest presenters for individual modules. Contact AFS-800 for exceptions.
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4)    Graduation Certificate. A graduation certificate is a uniquely numbered document that is signed and issued by an approved FIRC provider to a flight instructor who holds a valid, current instructor certificate. A completed and signed graduation certificate may be used as a basis for certificate renewal under  61.197(a)(2)(iii). This is opposed to a course completion certificate. ASIs should always be alert to the difference.
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5)    Course Completion Certificate. A course completion certificate has no FAA certificate validity and only indicates that the attendee completed the course. A course completion certificate may not be used as a basis for flight instructor certificate renewal. The FIRC provider may offer these certificates, at his or her discretion, to those attendees who do not hold valid flight instructor certificates or to flight instructors who have expired certificates and wish to refamiliarize themselves with the current state of instructor-related information prior to applying for reinstatement. ASIs should always be alert to the difference.
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6)    Credential. In context of this section, the use of the term credential refers to the actual flight instructor certificate issued by the FAA to a qualified flight and ground instructor. This term is used for consistency with the current edition of Advisory Circular (AC) 61-83, Nationally Scheduled, FAA-Approved, Industry-Conducted Flight Instructor Refresher Course.

E.    The Role of the FAA in the FIRC Process.

1)    In the past, only the FAA conducted FIRCs, which proved to be beneficial, productive, and an effective means of renewing flight instructor certificates. However, because of the Federal government’s policy of placing additional responsibility on industry and in light of fiscal restraints, effective October 1, 1977, the FAA made the decision to withdraw direct presentation of the FIRCs, and to delegate this function to industry.
2)    AFS-800 reviews and approves all FIRC TCOs to ensure national standardization of certain aspects of the FIRC content, as well as uniformity and consistency of related regulatory and policy interpretations. This also allows a single-point source of information related to the FIRC program as a whole, further contributing to uniformity and standardization. AFS-800 is responsible for all guidance and policy regarding FIRC programs nationwide.
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3)    Even though the FAA no longer presents the FIRCs directly, the overall FIRC program policy remains an FAA initiative, and the continued success of the program will only be realized through the full cooperation and support of all FAA personnel. Since the FAA reviews and approves all FIRC-providing organizations’ TCOs, the FAA is also responsible for verifying that each organization is conducting its courses according to its approved TCO. The FAA also needs to ensure that FIRC providers successfully promulgate the overall program mission of providing effective flight instructor recurrent training in pursuit of enhanced flight safety; therefore, the FAA encourages FSDOs to make frequent onsite inspections and to surveil FIRC programs in their areas as often as possible. Although not required, FSDOs should contact AFS-800 to notify them when and where the FSDO plans to conduct a FIRC surveillance.
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4)    Active FAA participation in a FIRC is when FAA personnel actually present to attendees at a particular FIRC offering, usually as a result of a request from the FIRC provider. Less frequently, FAA participation may result from a directive from the RO FIRC provider or a directive from AFS-800. If a FIRC provider contacts the FSDO for FAA participation, the FSDO manager may want to combine a full FIRC surveillance with the presentation from one of its ASIs. Often, offices assign the FAA Safety Team (FAASTeam) manager to monitor a course and offer a safety presentation. See subparagraph 6-2321B for more information regarding FAA conduct when actively participating in FIRCs.
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6-2319    SCHEDULING OF COURSES. Upon approval, each FIRC provider organization may schedule and conduct FIRC programs as often as and wherever they deem appropriate. To provide timely notification to the FAA for monitoring purposes, the FAA requires the approved organization to notify AFS-800 of its intent to conduct such courses at least 45 days in advance. AFS-800 will normally advise appropriate ROs of FIRCs conducted within that jurisdictional RO or FSDO’s area. In the future, there should be a location on FAASTeam’s Web site (http://www.faasafety.gov) where operators will be required to maintain their schedules. This site will be open to the public. Some operators may not wish for the public to see their offerings. In such cases, they will have the option to set their listings to be invisible to the public; however, they will still be required to post the data, and their schedules will be visible to FAA personnel.

6-2320    FSDO MONITORING OF FIRCS.

A.    Geographic Responsibility. Regional and field offices are responsible for the surveillance and monitoring of conventional (in-person) FIRC programs conducted within their respective jurisdictional areas. ASIs use the procedures in this section during the surveillance and monitoring of a FIRC.

B.    Monitoring Frequency. ASIs from local FSDOs should surveil or monitor FIRCs operating in their geographic area as frequently as possible based on available office resources. Additionally, the AFS-800 FIRC program office may request that FSDO personnel monitor a specific FIRC.

6-2321    ADDITIONAL FSDO RESPONSIBILITIES. As part of the approval process, the FAA has informed approved organizations not holding associated ACR designations that the organizations are responsible for arranging the necessary renewal procedures for successful graduates of their courses with the appropriate field offices as far in advance as possible. The final decision on renewal of individual instructor certificates, on the basis of the course attendance, will remain the option of the FAA.

A.    Standardization Flights. On occasion, the FSDO may receive requests from approved organizations to provide standardization flights in connection with the course. The FSDO will advise all approved organizations that FSDO personnel cannot devote themselves to this function unless:

1)    Individual offices determine that it is expedient to use personnel in this manner.
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2)    The FIRC provider organization and the FSDO have arranged for this in advance of the course.

B.    Active FAA Participation.

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1)    AFS-800 encourages FSDO personnel to actively participate in industry-conducted FIRCs when requested by the FIRC provider organization to do so. Participation is at the option of the FAA RO or FSDO. The region or FSDO will decide whether to participate for each individual request received. AFS-800, ROs, or FSDOs may take the initiative to offer to participate at a given FIRC program without the FIRC provider organization specifically requesting them.
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2)    A FSDO or other FAA personnel may not exercise their authority to insist on participating in a FIRC provider’s FIRC if the FIRC provider does not wish them to, unless specifically instructed to in writing by AFS-800. However, the FAA has the authority to surveil or monitor any FIRC program at any time without receiving permission from the FIRC provider.
3)    If the FIRC provider and the FSDO agree that it would be beneficial and practical to have an ASI participate in the FIRC provider’s FIRC program, the FSDO and the FIRC provider will coordinate on the topic, the date, the time when the FAA will present the agreed-upon topic, and the amount of time that the FIRC provider will allocate to the FAA for the course. TCOs, approved by AFS-800, are frequently very tightly time-controlled to enable the FIRC provider to adequately cover all of the topics in their approved program. Therefore, FAA personnel giving presentations at a FIRC will be strictly limited to the time allocated to them by the FIRC provider, but in no case will FAA participation exceed 2 hours. If the FSDO feels that the time allocated by the FIRC provider is inadequate to cover a particular topic, but the FIRC provider is unable to provide additional time, then the FSDO will either compress their presentation into the time allowed by the FIRC provider or decline to present at all. FAA personnel may not exercise their authority to insist on more time.
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4)    The ASI who is giving a presentation at a FIRC provider’s FIRC is, in a very real sense, serving as an ambassador of the FAA to that industry. The FAA has relatively few opportunities to make live presentations to the General Aviation (GA) flight instructor community. Such presentations put the participating ASI in the demanding position of representing the FAA as a whole, as well as being a venue for the transfer of useful FIRC-relevant knowledge. Therefore, the responsible FAA office must give consideration to the quality of the presentation materials and the abilities of the person(s) who will give the presentation.
a)    Effective speaking before an audience is, in many regards, an art form. Presenting an interesting, engaging, and stimulating program of instruction to an audience can be very demanding, and while some people seem to be born with an innate ability to accomplish this, most have to work very hard to develop these skills. This can be particularly difficult when a regulatory and enforcement agency gives the presentation to a group of people that it directly regulates and oversees. Therefore, the ASI should be thoroughly prepared before giving a presentation in front of the FIRC attendees.
b)    ASIs who exhibit these skills when making a presentation to an industry group will reflect well on the FAA as well as make it more likely that the industry group retains the presented information. If the quality of the materials or the presentation of those materials is poor or if the ASI executes the presentation poorly, it will reflect equally poorly on the FAA, as well as make it far more likely that the industry group will ignore or quickly forget the information provided. The FSDOs should consider these factors carefully when they select who they will send to a FIRC to give a presentation. Highly skilled public speaking is a relatively rare talent, particularly in technical fields, and the FSDO should capitalize on this skill whenever it is available to them.
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C.    Graduation Certificates. At the completion of each course, the approved organization will issue a printed graduation certificate to each successful graduate who is seeking a basis for flight instructor credential renewal under 61.197. The graduation certificate will be sequentially numbered and contain appropriate information. See subparagraph 6-2325D7)h) for specifics.

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NOTE:  Some attendees may be attending for reasons other than certificated flight instructor (CFI) credential renewal. Those participants may not receive a graduation certificate. The FIRC provider may, at its discretion, issue course completion certificates to those individuals that are different from the graduation certificates. Since these are individuals who are not attending for purposes related to any certificate action or regulatory or policy requirement, neither they nor their completion certificates are of concern to the FAA in this context.

1)    Section 61.3(d)(1) states that a person who holds a flight instructor certificate must have that certificate, or other documentation acceptable to the Administrator, in that person’s physical possession or readily accessible in the aircraft when exercising the privileges of that flight instructor certificate. This regulation allows for the common practice in which flight instructors surrender their flight instructor certificates upon completion of the course and that they may have to wait a few weeks to receive their new temporary flight instructor certificate. Therefore, an instructor may use the graduation certificate, or a copy, as authorization to exercise the privileges of the certificate.
2)    The intent of this rule is to allow the flight instructor to have continuing flight instructor privileges after completing the FIRC without the rule becoming an unnecessary burden. In complying with this rule, the FAA and flight instructor should be reasonable with one another. The FAA will give the flight instructor time to receive his or her temporary flight instructor certificate.

D.    Graduation Records. The approved organization will maintain a record for 24 months of all graduation certificates issued, certificates denied, and the reasons for denial. Therefore, if a flight instructor presents a graduation certificate to a FSDO as the basis for the flight instructor certificate renewal and there is any doubt of the authenticity of the graduation certificate, the ASI may check with the issuing organization. Upon request, the Airman Certification and Training Branch (AFS-810) will provide names, addresses, and telephone numbers of all approved organizations to all regions and FSDOs.

E.    Human Resource Restrictions in the FSDO. As previously discussed, the FAA anticipates that there may be limited FSDO participation in the industry-conducted courses, with the exception of the administrative processing of certificates awarded to course graduates. This renewal process may create problems for some FSDOs because of Human Resource restrictions. Several factors in the manner in which industry conducts these courses are contributing to the problem.

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1)    FIRC providers conduct most courses on weekends (Friday and Saturday or Saturday and Sunday), which may require the FSDO to process as many as 150 to 200 certificates in a short timeframe.
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2)    In some highly populated areas, FIRC providers may schedule several courses within a short timeframe and at more than one location.
3)    In many instances, the course locations are a considerable distance from the FSDO that has jurisdiction.
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4)    Many attendees do not live in the district where the FIRC provider is conducting the course.
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5)    In view of the above, and in order to best use the available human resources, the FSDO may use the following procedures to renew flight instructor certificates. At the discretion of the jurisdictional FSDO, an ASI may renew the instructor certificates in accordance with either subparagraph (a) or (b) below. Ideally, in either case, the organization conducting the FIRC will aid in completing the application forms. The FIRC provider will check the forms for completeness and accuracy and ensure the applicant indicates the graduation certificate number on the application form.
a)    The ASI that is observing the course may accept and process applications during the course. In this case, the ASI would then present FAA Form 8060-4, Temporary Airman Certificate, to course graduates upon successful completion of the course, as outlined in Volume 5, Chapter 1, Section 5.
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b)    If processing the applications during the FIRC is not feasible, the FIRC provider may collect the original application forms, graduation certificates, permanent flight instructor certificates, and a notarized copy of the applicant’s identification. The FIRC provider would then submit the applications and supporting items to an FAA representative for processing.
c)    Additionally, the FSDO may wish to consider authorizing ACRs for those FIRC providers who regularly operate in their geographic area to minimize the FSDO’s administrative efforts in the renewal process. Volume 13, Chapter 6, Section 2 contains procedures for appointing an ACR.
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F.    Coordination Between FSDOs. The FAA does not require coordination with other FSDOs or AFS‑800 before the renewal of instructors who are not based in the district where FIRC providers conduct the course. The FSDO may process all applications received as a result of course attendance regardless of the applicant’s permanent residence. If a FSDO has questions or concerns relating to the renewal of a particular instructor, FSDO personnel must notify the Airmen Certification Branch (AFS-760) regarding that instructor’s certificate renewal. If necessary when AFS-760 receives the instructor’s application, it will route the application to the FSDO that has jurisdiction for final disposition. This procedure will relieve the host FSDO of the need to check with the home FSDO regarding out-of-area course attendance.

6-2322    COURSE MATERIALS. The FAA expects the organization conducting the FIRC to provide all handout materials associated with the conduct of the course. While the organization may copy or reproduce official FAA publications, the FAA does not expect the districts or ROs to assume responsibility of furnishing materials.

A.    Section 61.197. This section permits the holders of valid and unexpired flight instructor certificates to renew their certificates by satisfactorily completing a minimum of 16 hours of ground instruction in an FAA-approved FIRC.

B.    Guidelines for Surveillance.

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1)    Unless AFS-800 issues a continuation of approval in letter form, field personnel must be aware that FAA approvals of FIRC programs expire on the last day of the 24th month from the date of issue. The expiration of FAA approval of a FIRC automatically terminates any ACR authorization held by that FIRC provider.
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2)    ASIs must, when conducting surveillance and monitoring FIRCs within their jurisdictional area, determine that the FAA approval of the FIRC and ACR designation, if held, are current and valid. FIRC providers must be able to present a current letter of authorization (LOA).
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NOTE:  The FIRC provider and AFS-800 normally transmit TCO submissions and LOAs electronically between each other. AFS-800 retains the original signed authorization letters in its files in Washington, DC; therefore, the FIRC provider will normally not possess original signed copies of their authorization letters, nor will they normally possess printed TCOs with FAA authorization stamps and signatures on each of the pages, as was the practice in the past. FIRC providers and AFS-800 may provide electronic copies of the original LOAs and TCOs to authorized FAA personnel upon request.

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3)    ASIs conducting surveillance and monitoring FIRCs within their jurisdictional area may contact AFS-800 for confirmation of a FIRC provider’s authorization if there is any question as to the validity of the FIRC provider’s authority to conduct FIRCs.

6-2323    PREREQUISITES AND COORDINATION REQUIREMENTS.

A.    Prerequisites. Knowledge of the requirements of part 61 and FAA policies. The surveillance must be accomplished by a qualified ASI (Operations).

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B.    Coordination. This task requires coordination with AFS-800, the FIRC provider organization, and possible other FSDOs or the regional Flight Standards division (RFSD).

6-2324    REFERENCES, FORMS, AND JOB AIDS.

A.    References (current editions):

    Title 14 CFR Parts 1, 61, 91, and 183.

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    AC 61-83, Nationally Scheduled, FAA-Approved, Industry-Conducted Flight Instructor Refresher Course.

    PTRS Procedures Manual (PPM).

B.    Forms. None.

C.    Job Aids:

    Flight Instructor Refresher Course Survey/Monitor Job Aid (Figure 6-99).

    Job Task Analysis (JTA): O2.4.24, O2.5.20.

    FAA FIRC Web site: http://www.faa.gov/pilots/training/firc/.

6-2325    PROCEDURES.

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A.    Obtain Schedule. The ASI should obtain a schedule of FIRCs from the FAASTeam FIRC schedule Web site (http://www.faasafety.gov), AFS-800, the RO, or the FIRC provider.

B.    Confirm Current FIRC Policy. The FIRC program is dynamic in nature, and the Administrator may approve certain changes in the conduct of FIRCs, including changes in the required core topics, at any time. ASIs should check the FAA’s FIRC information Web site for the latest information regarding FIRC conduct and current core topics before conducting a FIRC surveillance. That Web site is: http://www.faa.gov/pilots/training/firc/.

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1)    In some cases, AFS-800 may approve a FIRC provider for a program of training that is not in strict compliance with current policy or guidance. Such an example may be where AFS-800 approves the FIRC provider under guidance that the FAA revised during the FIRC provider’s authorization period. Since the FIRC provider’s period of authorization is valid for a period of 24 months, it is possible that some time will pass before they are required to come into compliance with the current policy or guidance.
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2)    Another example may be where a FIRC provider is specifically authorized to operate a program of training that is unique or innovative and does not appear to be in strict compliance with the current policy.
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3)    If there appears to be a discrepancy between the current policy information and what the ASI observes in the FIRC provider’s TCO, the ASI should contact AFS-800 for clarification. If the ASI cannot reach AFS-800 (typically because FIRC providers often present FIRCs on weekends), the ASI should assume that the FIRC provider is in compliance and should not disrupt the course. In such cases, the ASI should take careful and detailed notes of any concerns that he or she may have, then contact AFS-800 for resolution as soon as practical after the course. The ASI should also consider reviewing the current edition of AC 61-83 before attending the course.
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C.    Contact FIRC Provider. The ASI should contact the FIRC provider and advise them that the FAA will monitor their course, and request a copy of their approved TCO and LOA. The FIRC provider is obligated to provide the FSDO with a copy of their TCO upon request. The FIRC provider may request return of the TCO document. If so, the FSDO may make and retain a copy of the document, but must return the document that the FIRC provider provided. If the FSDO is concerned about the authenticity of the TCO that the FIRC provider provides, the FSDO may ask AFS-800 to provide an electronic copy for comparison. Upon initial contact with the FIRC provider, the ASI must determine:

1)    The validity date of the FIRC provider’s authorization to conduct FIRCs;
2)    The exact date, time, and location of the course or modules you intend to monitor;
3)    The subject matter that the ASI will observe (if he or she does not intend to observe the entire program) and the proposed length of the course;
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4)    The name of a person, who represents the FIRC provider, to contact upon arrival; and
5)    How the FSDO will receive the application, or how it will otherwise process the applications.

D.    Attend and Surveil the FIRC. The attending ASI should adhere to the following steps when surveilling a FIRC:

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1)    The ASI should present their identification to the FIRC provider.
2)    The ASI must advise the FIRC provider that the FAA is monitoring the course for the purpose of ensuring adherence with the approved TCO. The ASI should consistently use the term “monitor” as opposed to “surveil” or “surveillance,” as the latter terms can have negative connotations.
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3)    If the ASI has chosen not to request a copy of the FIRC provider’s TCO and/or their LOA in advance, the ASI may, prior to or at any time during the course, request the FIRC provider to show you their current FAA authorization to operate a FIRC and/or a copy of their approved TCO. The FAA must have issued the approval within the past 24 calendar-months. The approval letter will typically be a copy, rather than an original, since AFS-800 normally retains the original signed copies at the AFS-800 program office. The ASI may contact AFS-800 to confirm authorization if he or she has not otherwise received a copy of the FIRC provider’s authorization letter. AFS-800 will verify authorization and will, upon request, forward an electronic version of the authorization letter to you.
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4)    The ASI may ask the presenter for their identification to confirm their identity. In most cases, verifying the presenter’s name and comparing it against the FIRC provider’s TCO should be sufficient. However, not seeing that presenter’s name on the TCO should not normally be a cause for concern. The ASI should assume compliance and contact AFS-800 for confirmation as soon as practical.
5)    The ASI should assume a seat in the classroom area so as not to disrupt the course. The ASI should seat themselves toward the back of the class to allow observation of the class participants. The ASI should avoid sitting in a part of the room that would bring unnecessary attention to their presence.
6)    The ASIs must ensure that their cell phone or other communication devices do not disturb the class proceedings. If an ASI must make or take a call, they should quietly leave the room first. Once outside the training room, ASIs should be sure that they are far enough from any entrances or windows so that class participants cannot hear the conversation.
7)    The ASI must observe the conduct of the proceedings and the classroom instruction. During the observation the ASI should pay particular attention to the following:
a)    TCO concurrence. Observe whether the presenter(s) follow(s) the approved TCO. The course should cover topics and modules in the approved sequence. While the TCO or the course schedule frequently list the exact times, the ASI should treat these as general guidelines and not absolutes.
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1.    It may be that an unusual or unexpected level of interest is engendered in a particular topic that may require it to exceed the posted time. It may also be that the FIRC provider can adequately cover the topic in somewhat less time. Such variations are acceptable provided that they are not excessive, do not result in the elimination of an approved topic, do not compress a topic to such a degree that it reduces the adequacy of coverage, and do not result in the overall course being conducted in less than 16 hours. If the FIRC provider finds that they cannot cover each of the approved topics in the allotted time, they may extend the overall training time. In any event the FIRC provider may not present a graduation certificate to any attendee until the applicant completes the entire course. An attendee may not receive a graduation certificate if they must leave early for any reason, such as catching a flight home.

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2.    The FIRC provider may exchange preapproved elective topics on very short notice. Such short-notice changes are acceptable and FIRC providers are only required to notify AFS-800 of the change to a preapproved topic via email prior to the course. Notification must be on file (not necessarily with an FAA response) before the FIRC provider implements the change in the classroom. If the ASI becomes aware of any last-minute changes or deviations, he or she makes a note of the change or deviation and records the time that the FIRC provider notified the class or the time of the event itself, whichever occurs first. If any question arises regarding the legitimacy of a deviation from an elective topic from the TCO, you should contact AFS-800 for confirmation. If AFS-800 is not immediately available, make careful note of the deviation and contact AFS-800 later, but as soon as practical. Under no circumstances may the FIRC provider replace or eliminate a core topic without written approval from AFS-800.

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NOTE:  During times of policy or guidance transition, it may be possible that a FIRC provider is conducting a FIRC that includes a set of core topics that are not in alignment with the current published core topics. This could be due to several acceptable reasons. Since a FIRC provider’s approval is for 24 calendar months, it may be that the Administrator changed the core topics during the approval period of the FIRC provider. In most cases, AFS-800 permits the FIRC provider to continue with their established and approved course until it is time for their renewal, at which time they would comply with the new requirements. Alternatively, it may be that, through direct approval by AFS-800, a FIRC provider is presenting new core topics prior to publication of the new core topics. AFS-800 may do this to ensure that the new or renewing FIRC provider does not receive approval for an older set of topics only days or weeks before the FAA publishes the new topic requirements, which could mean that the FIRC provider would not come into alignment with the more recent requirements for up to nearly 2 years. If there are any questions regarding this issue, the ASI should contact AFS-800 for clarification.

b)    Technical accuracy. FIRCs typically cover a wide range of topics, and many are oriented to specific aircraft categories such as rotorcraft or gliders. The ASI must make every effort to ensure that the course content presented is technically accurate to the best of their ability. In general, ASIs should never speak up during a course unless specifically addressed. In no event may the ASI create any disruption in the presentation. If the presenter offers any incorrect material, the ASI should make careful note of it and discreetly inform him or her of the error as soon as practical, such as during the next break. The ASI should give the presenter the opportunity to correct the mistake or misinformation upon return from the break. It may be that the presenter disagrees with the ASI’s position on a particular point. In such a case, the ASI should make note of the point and the presenter’s position on that point and either verify or dispel the point as soon as practical through reference to either regulatory or policy documentation. If no immediate resolution is possible, either during the course or upon return to the FSDO, the ASI should contact AFS-800 for clarification.
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1.    The ASI must not make any regulatory or policy interpretations, although the inspector may explain how to apply a regulation or policy. The ASI should ensure that their response is based on specific guidance or knowledge and should be prepared to back up any response with appropriate documentation. The ASI must present any disagreement with the FIRC provider’s point or position in the most conciliatory and non‑condescending manner. The tone should serve to provide the presenter with updated information. The ASI must defer any requests for a legal interpretation to the Office of the Chief Counsel. The ASI must defer any requests for a policy interpretation to the RFSD or appropriate policy office.

2.    The ASI is not required to respond to a direct question during a presentation; it is entirely their option. If the ASI is unsure of the topic or issue under discussion, AFS-800 encourages the inspector not to engage the question. Instead, the ASI should simply respond that it is not an area of their particular expertise or that you are there merely to observe. Further, the ASI may inform the attendees and presenters that any questions relating to interpretation of specific issues should be submitted to the FAA in writing.

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c)    Course quality. There may be instances when an ASI detects areas in which changes would improve the quality of the course (as opposed to technical errors). AFS-800 encourages the ASI to describe his or her recommendations or suggestions for improvement in the comments section of the job aid before forwarding to AFS-800. The ASI may indicate to the FIRC provider the suggestions that the ASI intends on forwarding to AFS‑800, but only if the FIRC provider specifically requests this type of feedback.
Indicates new/changed information.
d)    Facilities. The ASI should confirm that the facilities are adequate with respect to seating, lighting, and general comfort. The ASI may note inconsistencies between the facilities and training aids listed in the TCO and those that the FIRC provider uses during the course. The ASI should make a note of this on the job aid, and must indicate whether or not the general environment is conducive to effective learning.
Indicates new/changed information.
e)    Attendance and course procedures. The ASI must observe whether or not the FIRC provider or their presenters ensure that attendees adhere to attendance requirements and course procedures as established in their TCO. To enroll in the FIRC for renewal purposes, the applicant must assure the course FIRC provider of their identity by showing an acceptable form of picture identification (e.g., U.S. driver’s license, passport, government identification, or military identification card).
Indicates new/changed information.
f)    Breaks. The ASI must observe if the FIRC provider provides and enforces break times as scheduled or described in their TCO. Instruction should begin promptly after the time allotted for the break has elapsed. If the ASI observes the FIRC provider failing to adhere to appropriate break times, he or she should discreetly discuss this with the presenter at the next break and should make note in the remarks section of the job aid (see Figure 6-99, Flight Instructor Refresher Course Survey/Monitor Job Aid).
Indicates new/changed information.
g)    Testing. Tests are the principal method of ensuring that there is an effective transfer of knowledge. The FIRC provider and its representatives should treat the tests with seriousness. The ASI must make note if:
Indicates new/changed information.

    The FIRC provider does not secure the tests prior to giving them to the attendees;

    The tests are not closed book;

    The presenters provide help to the attendees (other than to clarify a test question);

    The presenters do not proctor the test carefully through the testing process (i.e., the presenters leave the room unattended during the test); or

    The proctors/presenter does not recover and secure all testing materials at the conclusion of the test(s).

Indicates new/changed information.

NOTE:  The FIRC provider may provide makeup training and testing for the deficient areas under the TCO to attendees who do not achieve a passing score on one or more tests.

Indicates new/changed information.
h)    Graduation Certificates. Observe that graduation certificates are issued to qualified attendees. Examine a random sample of graduation certificates (two or three are sufficient) and ensure that they contain the information found in the current edition of AC 61-83, subparagraph 8k(2).
8)    While ASIs should generally avoid speaking up during a course unless specifically addressed, AFS-800 strongly encourages the inspector to be available before or after the course or during breaks to answer questions or discuss issues with attendees or presenters. At all times, the ASI should present a pleasant, friendly, and helpful demeanor and avoid exhibiting any behavior that the class participants may perceive as authoritarian or threatening.
Indicates new/changed information.
9)    An ACR may or may not be present at the FIRC. If an ACR is present, AFS-800 will expect the ASI to inspect the ACR as a component of the FIRC surveillance. The ASI should refer to Volume 13, Chapter 6, Section 3 for FIRC ACR inspection guidance. If the FIRC provider does not have a designated ACR, the FIRC provider may ask the ASI to provide information about the designation. The ASI should review
Volume 13, Chapter 6, Section 2 to ensure familiarity with the current ACR designation process and requirements. In either case, if time permits, the ASI should offer to aid in the processing of the Airman Certificates where possible.
10)    Following the conclusion of the FIRC surveillance, the ASI must proceed with the following steps:
a)    The ASI must complete the observation or a FIRC job aid (Figure 6-99).
Indicates new/changed information.
b)    The ASI should include any comments that might be of value to the AFS-800 FIRC program office. Forward a copy of the job aid directly to the program office, preferably by electronic means. For forwarding information, contact AFS-800 at 202-267-1100 or 9-AWA-AVS-AFS-FIRC@faa.gov.

NOTE:  For any area that was unsatisfactory, the ASI must explain the reason in the comments section of the job aid.

c)    The ASI must file the job aid under Office Procedures.
Indicates new/changed information.
11)    If the course was unsatisfactory to the point that the ASI recommends withdrawal of the FIRC provider’s FIRC approval, the ASI must contact AFS-800 through the appropriate RO as soon as practical.

E.    PTRS. Complete the PTRS record under the PPM.

6-2326    TASK OUTCOMES. Feedback from the field is important to the FIRC program office at AFS-800. Effective flight instructor recurrent training is an essential component in reducing GA accident rates, and AFS is concerned that the flight instructor is getting the best in recurrent and update training. Ensuring the effectiveness of the FIRC program depends on the efforts and care taken by the FSDO and the ASI(s) conducting the surveillance, and AFS-800 places significant value on the information provided from the field. This includes both satisfactory and unsatisfactory information, along with as much detail that the ASI is able to contribute. At a minimum, completion of this task involves the following:

    Completion of a satisfactory or unsatisfactory report as appropriate.

    Inclusion of any additional relevant information or comments that ASI may wish to provide the program office.

    Copies of the report(s) forwarded to AFS-800.

6-2327    FUTURE ACTIVITIES.

Indicates new/changed information.

    Increased monitoring of future courses conducted by a particular FIRC provider may be necessary.

    Possible withdrawal of the course’s approval by AFS-800 upon recommendation by the FSDO.

Indicates new/changed information.

    Possible request by AFS-800 that the FIRC provider revise their TCO.

Figure 6-99.  Flight Instructor Refresher Course Survey/Monitor Job Aid

OBSERVATION OF A FIRC

Page 1 of 3

Indicates new/changed information. Name of FIRC Approval Holder (FIRC Provider):

 

 

Date and Location of Surveillance (actual date/time that ASI was on site):

Indicates new/changed information. Expiration Date of Approved TCO as Stated in FIRC Provider’s Authorization Letter:

 

 

Instructor’s Name(s):

 

Airman Certification Representative Name (if appropriate):

FAA Inspector Name and Routing Code:

 

Daily Schedule

(Complete as appropriate. If unable to attend the full program, indicate actual date of inspection and arrival and departure times instead. Place “N/A” in any box[es] not used.)

 

Date:

 

Start Time:

End Time:

Day 1

 

Planned:

Actual:

 

 

Day 2

 

Planned:

Actual:

 

 

Day 3

 

Planned:

Actual:

 

 

 

Figure 6-99.  Flight Instructor Refresher Course Survey/Monitor Job Aid (Continued)

OBSERVATION OF A FIRC

Page 2 of 3

Please check each of the following as SAT, UNSAT, or N/A as appropriate.

(Any UNSATs must be described in the comments box.)

 

SAT

UNSAT

N/A

Was the training facility adequate (e.g., room size, etc.)?

 

 

 

Was adequate and comfortable seating provided?

 

 

 

Was there adequate lighting?

 

 

 

Was the physical environment (e.g., heat, air conditioning, etc.) within norms?

 

 

 

Did the program begin at the time scheduled? (Check N/A if you did not arrive at the beginning of the day.)

 

 

 

Did the program continue until the scheduled end-of-day stop time? (Check N/A if you did not stay until the end of day.)

 

 

 

Indicates new/changed information. Did the FIRC provider ensure attendance (e.g., roll call, etc.)?

 

 

 

Was the TCO followed?

 

 

 

Was course content technically correct?

 

 

 

Were breaks appropriate and well controlled?

 

 

 

Were testing materials adequately secured and unavailable to attendees before test?

 

 

 

Were tests given “closed-book”?

 

 

 

Were tests adequately proctored at all times?

 

 

 

Were test materials retrieved and secured at the end of test(s)?

 

 

 

Were graduation certificates issued appropriately (i.e., after the final test and not earlier)?

 

 

 

Were attendees’ IDs checked upon issuance of graduation certificates or earlier?

 

 

 

Did the presenter(s) present a generally positive, or at least neutral, attitude toward the FAA?

 

 

 

 

GRADUATION CERTIFICATES

Please confirm each of the following was found on two or more graduation certificates:

 

SAT

UNSAT

N/A

Indicates new/changed information. Full Name and address of FIRC provider:

 

 

 

FIRC provider contact info (e.g., email, phone number, etc.):

 

 

 

Full name of graduate:

 

 

 

Date of issuance:

 

 

 

Sequential number:

 

 

 

Signature of chief instructor (or authorized representative):

 

 

 

Indicates new/changed information. Expiration date of FIRC provider’s authorization:

 

 

 

A statement that the graduation certificate expires 3 calendar-months from the date of issuance:

 

 

 

 

Figure 6-99.  Flight Instructor Refresher Course Survey/Monitor Job Aid (Continued)

OBSERVATION OF A FIRC

Page 3 of 3

Comments/Impressions/Observations/Notes/Recommendations:

Your expert input is highly valued. Please be candid.

Please be as detailed as possible use more paper if necessary.

 

Indicates new/changed information.

RESERVED. Paragraphs 6-2328 through 6-2345.